Bank of America : Europe D.A.C. (formerly Bank of America Merrill Lynch International D.A.C. and Merrill Lynch International Bank D.A.C.) June 30, 2023 Interim Report -September 20, 2023 at 10:39 am EDT

Bank of America Europe Designated Activity Company Pillar 3 Disclosure for the Half Year Ended 30 June 2023

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Bank of America Europe Designated Activity Company Pillar 3 Disclosure for the Half Year Ended 30 June 2023

1. Overview and Purpose of Document

This document contains the Pillar 3 disclosures as at 30th June 2023 in respect of the capital, leverage and liquidity of Bank of America Europe Designated Activity Company, (“BofA Europe”), an Irish credit institution.

This document provides details on BofA Europe’s available Capital Resources (“Capital Resources”), regulatory defined Pillar 1 Capital Requirements (“Minimum Capital Requirements”) and Total Supervisory Review and Evaluation Process Capital Requirement (“TSCR”). It demonstrates that BofA Europe has capital resources in excess of these requirements and maintains robust risk management and controls.

To further increase transparency, this document also includes information on BofA Europe’s liquidity position, information on the capital requirements in respect of the Countercyclical Capital Buffer (“CCyB”), and the minimum requirement for own funds and eligible liabilities (“MREL”). BofA Europe has not omitted any information on the basis that is proprietary or confidential.

In accordance with Article 433a (2) of the EU’s Capital Requirements Regulation 2 (“CRR”), BofA Europe is required to disclose the key metrics referred to in Article 447 of CRR on a semi-annual basis.

For further information on BofA Europe’s risk management objectives and policies, please refer to BofA Europe’s annual Pillar 3 disclosure for the year ended 31st December 2022 on Bank of America’s corporate website:

Pillar 3 report – December 2022

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Bank of America Europe Designated Activity Company Pillar 3 Disclosure for the Half Year Ended 30 June 2023

2. BofA Europe

BofA Europe is a registered credit institution in the Republic of Ireland which is authorised and regulated by the Central Bank of Ireland (“CBI”) and supervised under the Single Supervisory Mechanism (“SSM”) by the European Central Bank (“ECB”). BofA Europe is classified as an Other Systemically Important Institution (“O-SII”). BofA Europe’s Legal Entity Identifier (“LEI”) is EQYXK86SF381Q21S3020.

BofA Europe is a wholly owned subsidiary of Bank of America N.A. (“BANA”) and the ultimate parent continues to be Bank of America Corporation (“BAC”).

BofA Europe is headquartered in Republic of Ireland with branches in the United Kingdom (“U.K.”), Belgium, France, Germany, Greece, Luxembourg, Italy, the Netherlands, Spain, Sweden, and Switzerland.

BofA Europe provides a range of financial services and forms part of BAC’s Global Banking and Global Markets operations in the Europe, Middle East, and Africa (“EMEA”) region. Clients principally include large multinational groups, financial institutions, governments, and government entities.

As at 30th June 2023, BofA Europe was rated by Fitch Ratings, Inc (“Fitch”) (AA / F1+) and S&P Global Ratings (“S&P”) (A+ / A-1).

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Bank of America Europe Designated Activity Company Pillar 3 Disclosure for the Half Year Ended 30 June 2023

3. Basis of Preparation

The Basel Capital Accords provides a series of international standards for bank regulation commonly known, most recently, as Basel III. Basel III was implemented in the European Union through the Capital Requirements Directive and the Capital Requirements Regulation (amended by the Capital Requirements Regulation 2 (“CRR”)).

This legislation consists of three pillars. Pillar 1 is defined as ‘Minimum Capital Requirement,’ Pillar 2 ‘Supervisory Review Process,’ and Pillar 3 ‘Market Discipline.’ Pillar 3 aims to promote market discipline through regulatory disclosure requirements. These requirements enable market participants to access key information relating to a bank’s regulatory capital and risk exposures in order to increase transparency and confidence about a bank’s exposure to risk and overall adequacy of its regulatory capital.

The information contained in these disclosures are in line with the disclosure requirements as laid down in Part Eight of the CRR, including amendments, for the purpose of explaining the basis on which BofA Europe has prepared and disclosed certain information about the application of regulatory capital adequacy rules and concepts. It therefore does not constitute any form of financial statement on BofA Europe, or of the wider Enterprise, and as such, is not prepared in accordance with International Financial Reporting Standards (“IFRS”) or International Accounting Standards (“IAS”). Therefore, the information contained in the Pillar 3 disclosure may not be directly comparable with the Annual Report and Financial Statements, and the disclosure is not required to be audited by external auditors. Any financial information for the current reporting period included herein is unaudited.

In addition, the report does not constitute any form of forward-looking record or opinion on BofA Europe. Certain forward- looking assumptions, which can represent beliefs and expectations regarding future events and are not guarantees of future results, and involve certain known and unknown risks and uncertainties that are difficult to predict and are often not controllable, may be included within the Disclosures. Actual outcomes and results may differ materially from those expressed in, or implied by, any forward-looking assumptions. Undue reliance should not be placed on any forward-looking assumptions and should consider the uncertainties and risks discussed in other publicly available disclosures of BofA Europe. Although the Pillar 3 disclosure is intended to provide transparent information on a common basis, the information contained in this document may not be directly comparable with the information provided by other banks.

BofA Europe’s financial statements have been prepared in accordance with the Companies Act 2014, Financial Reporting Standard 100 (“FRS 100”) – Application of Financial Reporting Requirements and Financial Reporting Standard 101 (“FRS 101”) – Reduced Disclosure Framework. In accordance with these it applies the recognition, measurement and disclosure requirements of International Financial Reporting Standards that have been adopted in the EU (“EU-adopted IFRS”).

BofA Europe adopted IFRS 9 for the accounting of financial instruments on 1st January 2018. The introduction of the expected credit loss (“ECL”) model did not result in a material adjustment to equity as at the date of adoption of IFRS 9. For this reason, BofA Europe is not applying the transitional arrangements for IFRS 9 as specified in Article 473a of the CRR. BofA Europe’s own funds, capital and leverage ratios already reflect the full impact of IFRS 9.

This Pillar 3 disclosure is published on BAC’s corporate website: http://investor.bankofamerica.com.

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