FinanceMap scores this financial institution in the following areas. Please navigate to the relevant tab for in-depth analysis
FinanceMap assesses these portfolios for this financial institution. Please navigate to the relevant tab for in-depth analysis.
The board and board committees directly oversee the organizations climate strategy, including net-zero strategy and climate risk appetite. Additionally, the organization has assigned some climate-related responsibilities to various management-level committees, and has launched a Climate Program Executive Steering Council to execute the organization’s net-zero strategy.
Bank of America has identified and disclosed key physical and transition risks, but does not disclose what risks it considers in relation to short, medium, and long term time horizons. It uses a ‘Risk ID’ process to take inventory of risks across the business. Additionally, it has provided several examples of how it has considered the impact of climate-related risks and opportunities on its corporate strategy planning, including working with clients across several lines of business to expand product capabilities and bring new financing solutions.
Bank of America has undertaken scenario analyses using a range of NGFS scenarios on various business portfolios across different transition risk types, as well as physical risk analyses on its consumer mortgage activities and bank owned or leased homes. In previous years, it tested the resilience of oil and gas clients to transitional risks and opportunities across various climate scenarios as well as its residential mortgage portfolio to physical risks. The organization discloses some implications of its scenario analysis, however it does not disclose how it plans to respond to the impacts it identified.
It has some disclosure around the processes used for identifying and prioritizing climate-related risks, including stress testing and industry and country level assessments. Bank of America is transparent about the processes in place to manage climate-related risks, including climate risk control monitoring as well as enhanced due diligence to determine a need for remediation, escalation, or stakeholder engagement. Additionally, it incorporates climate-related risks into overall risk management, including adding a new section to the company’s Risk Framework to address how it defines and manages climate risk.
Bank of America is transparent about some key metrics used to measure and manage climate-related risks and opportunities, including some credit exposure to climate-related risks, sustainable financing metrics, and remuneration policies. The organization discloses Scope 1, 2, and relevant Scope 3 emissions, as well as some absolute financed emissions for its auto manufacturing, energy, and power generation sector portfolios.
In 2021, Bank of America announced a Net Zero target by 2050 for its operations, supply chain, and financing activities. In April 2022, it released its 2030 interim targets for three sectors in line with the NZE2050 emissions pathway including auto manufacturing, energy, and power generation. Its targets currently cover the business loan exposure for the sectors and do not include capital markets activities.
Bank of America is not aligned with IPCC guidance on the role for coal in the energy mix up to 2050. In December 2023, it updated its ESRP framework and backtracked on its previous commitment to phase out of companies that generate ≥ 25% of their revenue from coal mining and will finance the construction or expansion of new coal mines and coal-fired power plants given escalation from the Senior-level Risk Committee. The bank has also not outlined a phase out to exit the coal sector.
With regard to natural gas, Bank of America also backtracked on previous commitments in its updated framework. The organization had established exclusion policies that limit financing for oil exploration or production activities in the Arctic, but will now finance these activities along with gas exploration in the Arctic given escalation. It will continue to conduct enhanced due diligence for oil sands projects and otherwise appears to be actively financing new oil infrastructure, stating that it engages with clients in the energy and power sectors to enhance GHG emissions disclosure and management.
Bank of America is partially aligned with IPCC guidance for the role of nuclear in the energy mix, and appears to support the role of nuclear, assuming clients meet enhanced due diligence standards. However, it is unclear how it sees nuclear role with regards to a full transition towards a zero-emission energy system.
Bank of America has communicated support for a transition to a low-carbon economy and increased its financing of renewables through its sustainable finance commitment of $1 trillion dedicated to the energy transition. However, it has not outlined guidelines or a framework for mobilizing this capital for renewables.
FinanceMap’s Climate Governance and Policies analysis assesses statements financial institutions (FIs) are making on how they are incorporating climate issues into their decision-making and operations using FinanceMap’s matrix methodology. This methodology is adapted from the Task Force on Climate-Related Financial Disclosures (TCFD) recommendations and guidelines, Net-Zero Banking Alliance (NZBA) or equivalent Glasgow Financial Alliance for Net-Zero (GFANZ) initiative reporting, and IPCC and IEA technology statements. The TCFD provide guidance on 11 recommendations across four areas which are reflected in our matrix: Governance, Strategy, Risk Management, and Metrics and Targets. Additional benchmarks have been introduced to strengthen the ambition of scoring criteria in the assessment of targets, which are supplemented by guidance from the NZBA or equivalent GFANZ initiatives.
Additionally, Science-Based Policy (SBP) benchmarks are used to measure alignment of an FIs technology positions with the science of climate change. These benchmarks are applied to an FIs internal policies on technologies including coal, oil, gas, nuclear, and renewables and also assesses its engagement with broader climate and energy policy issues such as advocacy on the role and importance of different strategy types in the future energy mix.
For each TCFD recommendation and technology, FIs statements are applied to a five point scoring scale ranging from +2 to -2, measuring alignment with the relevant benchmarks. The detailed scores for this FI are displayed below within each matrix cell.
The following table outlines the key queries and data sources, which FinanceMap uses to assess financial institutions climate governance, targets and policies. Every evidence piece is assessed on a five-point scale of -2,-1,0,1,2 or NA (not applicable)/NS (not scored). All queries, data sources, and evidence pieces are weighted against one another in a matrix system to arrive at a final top-level score. Clicking on specific cells will load the underlying evidence and information on how it has been assessed.
Fossil fuel companies are those whose primary sector falls within coal mining and services, or up-, mid-, and downstream oil and gas sectors. Green companies are defined as companies having over 75% revenue deriving from Substantial Contribution to Mitigation activities under the EU Taxonomy.
Portfolio Paris Alignment analysis of this institution's activities in this portfolio area assesses deals in 2020–2022.
Value Assessed: $1.21T
Sector Paris Alignment scores for the sectors to which this portfolio has exposure. FinanceMap Paris Alignment analysis is limited to the automotive, upstream fossil fuel, and power sectors.
Fossil fuel companies are those whose primary sector falls within coal mining and services, or up-, mid-, and downstream oil and gas sectors. Green companies are defined as companies having over 75% revenue deriving from Substantial Contribution to Mitigation activities under the EU Taxonomy.
Portfolio Paris Alignment analysis of this institution's activities in this portfolio area assesses deals in 2020–2022.
Value Assessed: $629B
Sector Paris Alignment scores for the sectors to which this portfolio has exposure. FinanceMap Paris Alignment analysis is limited to the automotive, upstream fossil fuel, and power sectors.
Bank of America’s engagement on sustainable finance policy has centered primarily on corporate ESG disclosure regulations, for which it has stated top-line support while objecting to specifics of policies in the US and EU.
Bank of America has stated its support for the Paris Agreement’s goal to keep global temperature rise to well below 2C. In April 2021, Bank of America joined the Net Zero Banking Alliance. In its 2023 TCFD Report, Bank of America appeared to support regulatory action on sustainable finance.
In its 2022 TCFD Report Bank of America stated support for regulating corporate ESG disclosure, asserting that voluntary disclosure efforts are insufficient. After the SEC released its proposed climate disclosure rule in March 2022, Bank of America supported the proposal, calling it “constructive and headed in the right direction,” while cautioning against immediate Scope 3 disclosure requirements. However, in its comment letter to the SEC in June 2022, Bank of America outlined major exceptions to its support for the disclosure rule, objecting to several aspects of the proposal including the financial statement metrics and some qualitative risk disclosure requirements. In July 2022, Bank of America outlined similar objections to the International Sustainability Standards Board’s (ISSB) draft climate disclosure standards. In August 2022 comments to the European Financial Reporting Advisory Group on proposed European Sustainability Reporting Standards, Bank of America opposed a double materiality approach to reporting and argued against the level of detail of the proposed requirements. The company again objected to the proposed ambition of the Standards in July 2023 comments to the Commission.
CEO Brian Moynihan has voiced his support for the ISSB disclosure standards in a January 2023 interview with CNBC, a June 2023 statement to Politico, and February 2024 remarks at the International Financial Reporting Standards (IFRS) Sustainability Symposium.
According to Florida lobbying disclosures, in 2023, Bank of America engaged on HB 3, legislation to prohibit the use of ESG factors in state and local investment decisions and procurement processes. Details of Bank of America’s engagement are unclear. CEO Brian Moynihan engaged with a federal policymaker on similar legislation in 2021, according to reporting from the Washington Post. Details of this engagement are unclear.
In 2022, Bank of America announced that it had joined the Risk Management Association’s Climate Risk Consortium, and that the Consortium was engaging with regulators and policymakers on climate-related risk management and prudential regulations for banks, but details of this engagement are unclear. A memo from the SEC shows that Bank of America, as constituents of the Bank Policy Institute, met with the Office of the Comptroller of the Currency to discuss “challenges” with the Office’s draft principles for climate-related financial risk management. Bank of America has not disclosed details of this meeting or outlined its position on climate-related financial risk regulation.
Bank of America has disclosed its key industry association memberships but has not disclosed an account of these groups’ sustainable finance policy positions and engagement activities.
InfluenceMap’s methodology for assessing lobbying on sustainable finance policy closely follows InfluenceMap’s established methodology on climate policy engagement, which is used extensively by investors, including via the Climate Action 100+ investor engagement process. Our full methodology can be found here.
Under our assessment of sustainable finance lobbying, InfluenceMap considers engagement on all financial policies which intersect with climate and/or other sustainability issues. The analysis takes into account both the engagement of the financial institution and the activities of industry associations they hold membership of.
InfluenceMap’s methodology covers seven publicly available data sources, searching for evidence of engagement and corporate positioning since 2017. To determine the policy issues within the scope of the analysis, InfluenceMap breaks down sustainable finance policy engagement into a series of subcategories, or 'queries'. These are designed to cover high-level issues relating to the importance of sustainable finance, as well as more specific areas of sustainable finance policymaking. InfluenceMap’s research process searches for evidence of an organization's engagement with each sustainable finance policy issue, across each of the data sources.
The following table outlines the key queries and data sources, which FinanceMap uses to assess financial institutions’ sustainable finance policy engagement. Every evidence piece is assessed on a five-point scale of -2,-1,0,1,2 or NA (not applicable)/NS (not scored). All queries, data sources, and evidence pieces are weighted against one another in a matrix system to arrive at a final top-level score. Clicking on specific cells will load the underlying evidence and information on how it has been assessed.
In this section, we depict graphically the relationships the corporation has with trade associations, federations, advocacy groups and other third parties who may be acting on their behalf to influence climate change policy. Each of the columns above represents one relationship the corporation appears to have with such a third party.
In these columns, the top, dark section represents the strength of the relationship the corporation has with the influencer. For example if a corporation's senior executive also held a key role in the trade association, we would deem this to be a strong relationship and it would be on the far left of the chart above, with the weaker ones to the right. Click on these grey shaded upper sections for details of these relationships. The middle section contains a link to the organization score details of the influencer concerned, so you can see the details of its climate change policy influence. Click on the middle sections for for details of the trade associations. The lower section contains the organization score of that influencer, the lower the more negatively it is influencing climate policy.
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of BPI. Bank of America reports that it is an "active participant" in BPI's Climate Working Group.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Brian T. Moynihan is on the board of BPI.
Brian T. Moynihan (CEO, Bank of America Corporation)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of BPI. Bank of America reports that it is an "active participant" in BPI's Climate Working Group.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Brian T. Moynihan is on the board of BPI.
Brian T. Moynihan (CEO, Bank of America Corporation)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Vanessa Holtz is member of AFME board of directors. Bank of America reports that it is an "active participant" in AFME's Sustainable Finance Prudential Workstream and Climate Risk Stress Testing Working Group.
Vanessa Holtz (Bank of America, BofASE CEO and France Country Executive)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Vanessa Holtz is member of AFME board of directors. Bank of America reports that it is an "active participant" in AFME's Sustainable Finance Prudential Workstream and Climate Risk Stress Testing Working Group.
Vanessa Holtz (Bank of America, BofASE CEO and France Country Executive)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a strategic partner of the MFA.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Edouard Matitia-Cohen is a board member of Managed Funds Association.
Mr. Edouard Matitia-Cohen (Managing Director and Global Head of Equity Financing Distribution, Bank of America Merill Lynch)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a strategic partner of the MFA.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Edouard Matitia-Cohen is a board member of Managed Funds Association.
Mr. Edouard Matitia-Cohen (Managing Director and Global Head of Equity Financing Distribution, Bank of America Merill Lynch)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of SIFMA. Bank of America reports that it is an "active Participant" in SIFMA's Sustainable Finance Task Force.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Laura Peters Chepucavage is Chair-Elect of SIFMA.
Laura Peters Chepucavage (Head of Global Financing and Futures, Bank of America Securities)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of SIFMA. Bank of America reports that it is an "active Participant" in SIFMA's Sustainable Finance Task Force.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Laura Peters Chepucavage is Chair-Elect of SIFMA.
Laura Peters Chepucavage (Head of Global Financing and Futures, Bank of America Securities)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Patricia Wenzel is on the board of ARA.
Patricia Wenzel (Senior Financial Advisor, Bank of America Merrill Lynch)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Patricia Wenzel is on the board of ARA.
Patricia Wenzel (Senior Financial Advisor, Bank of America Merrill Lynch)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Michael Stanley is a member of the board of directors for ISDA. (Last checked November 2023)
Michael Stanley (Co-head of Global Rates & Counterparty Portfolio Management)
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of ISDA.
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Michael Stanley is a member of the board of directors for ISDA. (Last checked November 2023)
Michael Stanley (Co-head of Global Rates & Counterparty Portfolio Management)
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of ISDA.
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Brian Moynihan is a member of the Financial Services Forum. Bank of America reports that it is an "active participant" in FSF's Climate Risk Working Group.
Brian Moynihan (Chairman and CEO, Bank of America)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Brian Moynihan is a member of the Financial Services Forum. Bank of America reports that it is an "active participant" in FSF's Climate Risk Working Group.
Brian Moynihan (Chairman and CEO, Bank of America)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of the US Chamber of Commerce. Bank of America reports that it is an "active participant" in the Chamber's Energy, Environment, Climate and Sustainability Policy Committee.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of the US Chamber of Commerce. Bank of America reports that it is an "active participant" in the Chamber's Energy, Environment, Climate and Sustainability Policy Committee.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Brian T. Moynihan is a member of Business Roundtable. Bank of America reports that it is an "active participant" in BRT's Energy and Environment Coordinating Committee.
Brian T. Moynihan (CEO, Bank of America Corporation)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Brian T. Moynihan is a member of Business Roundtable. Bank of America reports that it is an "active participant" in BRT's Energy and Environment Coordinating Committee.
Brian T. Moynihan (CEO, Bank of America Corporation)
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of the Institute of International Finance. Bank of America reports that it is an "active participant" in IIF’s Sustainable Finance Policy Expert Group.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of the Institute of International Finance. Bank of America reports that it is an "active participant" in IIF’s Sustainable Finance Policy Expert Group.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of ABA. Bank of America reports that it is an "active participant" in ABA’s Environmental, Social and Governance Working Group and Climate Task Force.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of ABA. Bank of America reports that it is an "active participant" in ABA’s Environmental, Social and Governance Working Group and Climate Task Force.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
Bank of America Merrill Lynch International Limited & Bank of America NA are members of UK Finance. Bank of America reports that it is an "active participant" in UK Finance's governance forums focused on sustainability.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
Bank of America Merrill Lynch International Limited & Bank of America NA are members of UK Finance. Bank of America reports that it is an "active participant" in UK Finance's governance forums focused on sustainability.
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of UK Finance, which is a member of EBF
not specified
--no extract--
InfluenceMap Data Point on Corporate - Influencer Relationship
(1 = weak, 10 = strong)
Bank of America is a member of UK Finance, which is a member of EBF
not specified
--no extract--