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 and climate-related risk management practices. Additionally, the organization has assigned some climate-related responsibilities to two management-level committees: the Management Risk Committee and the Responsible Growth Committee, which oversee climate risks and accelerate the organization’s progress on climate.
Bank of America has identified some key physical and transition risks and has defined short-, medium-, and long-term time horizons, however, it does not disclose which risks it considers relevant over which time horizons. The organization identifies risks in an enterprise-wide risk inventory which are reviewed quarterly. Additionally, Bank of America considers climate-related risks and opportunities across all eight lines of business. It has provided several examples of how it has considered the impact of climate-related risks and opportunities on its corporate strategy planning, including assisting clients in the transition towards a low-carbon economy.
Bank of America participated in the 2023 Federal Reserve Board's pilot climate scenario-analysis exercise, using the Current Policies (Baseline) and Net Zero 2050 scenarios in its transition risk analysis, and the Idiosyncratic scenario for its physical risk analysis. It has previously used 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. The organization discloses some implications of its scenario analysis, however it does not disclose how it plans to respond to the impacts identified.
It has some disclosure around the processes used for identifying and prioritizing climate-related risks, including scenario analysis and industry and country level assessments. It also incorporates climate-related risks into its risk assessments of other risk types. Bank of America is transparent about the processes in place to manage climate-related risks, including the use of Key Risk Indicators (KRIs), daily climate risk reporting, and a monthly stress test. It also integrates climate-related risks into overall risk management, and created an internal Climate Risk Framework in 2023.
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 fully discloses Scope 1, 2, and 3 emissions, as well as some absolute financed emissions for its auto manufacturing, energy, aviation, cement, coal 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. It previously was a member of the NZBA but left the alliance in December 2024, though it appears to maintain its net zero commitment. 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. In its 2023 TCFD report, Bank of America released two more interim targets for the aviation and cement sectors. In April 2024, it released two additional 2030 interim targets for iron & steel and maritime shipping. Its targets currently cover commercial credit loan exposure 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 to the Senior-level Risk Committee. The bank has also not outlined a phase out to exit the coal sector.
Bank of America is not aligned with IPCC guidance on the role for natural gas or oil in the energy mix, and will provide financing, assuming the client meets engagement criteria, for expanding natural gas and oil infrastructure. The organization had previously established exclusion policies that prohibited financing for oil and gas exploration or production activities in the Arctic, but will now finance these activities given escalation to the Senior-level Risk Committee. In 2022, Bank of America set a 2030 interim sector target for the energy sector of 42% emission intensity reduction for Scope 1 & 2 and a 29% reduction target for Scope 3.
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.
Bank of America has communicated support for a transition to a low-carbon economy and is increasing its financing of renewables through its sustainable finance commitment of $1 trillion dedicated to the energy transition by 2030. It has developed a Sustainable Finance Taxonomy to determine the eligibility of certain sustainable finance activities, however this document is not published externally.
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 2020–2024.
Value Assessed: $1.95T
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 2020–2024.
Value Assessed: $939B
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.
Climate Lobbying Overview: Bank of America appears to be somewhat engaged on climate policy, stating topline support for climate disclosure policies and government action to decarbonize the economy.
Top-Line Messaging on Climate-Related Financial Policy: In its 2023 Environmental and Social Risk Policy Framework, Bank of America stated support for the Paris Agreement goal to limit temperature rise to well below 2C. In its 2023 TCFD Report, Bank of America appeared to support regulatory action on climate-related financial policy.
Position on Regulated Corporate Climate Disclosure: In its 2024 Sustainability Report Bank of America stated support for regulating corporate climate risk and GHG emissions disclosure. After the SEC released its proposed climate disclosure rule in March 2022, Bank of America was quoted in Reuters supporting 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 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 a July 2022 letter, 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 (ESRS), 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.
Position on Incorporating Climate Factors Into Investor Duties: 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.
Position on Incorporating Climate Factors Into Risk Management/Prudential Regulation: A 2022 memo 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. In its 2024 Sustainability Report Bank of America described efforts by regulators to incorporate climate risk into prudential regulation, but took no clear position on these efforts.
Position on Real Economy Climate Policy: In its 2023 Environmental and Social Risk Policy Framework, Bank of America stated support for a carbon tax. In its 2024 Sustainability Report, it outlined its “continuously stated support” for a price on carbon. According to the EU Transparency Register, in 2022 Bank of America met with representatives from the European Commission to discuss EU climate policy and carbon pricing, but details of this meeting are unclear.
Position on Energy, Industry, and Land Transitions: Bank of America appears generally supportive of the transition of the energy mix. In its 2024 Sustainability Report the bank committed to lobby, directly and indirectly, in support of an “orderly transition to Net Zero.” In the same report, Bank of America supported various policy measures to decarbonize the economy, including increased use of Sustainable Aviation Fuels (SAF) and US Inflation Reduction Act (IRA) incentives to drive SAF production, government policies and investments to decarbonize transportation, and permitting reform in order to support a transition to renewables. In 2022 comments on the implementation of the IRA’s clean energy tax incentives, Bank of America took a generally neutral stance on the policy but in one comment suggested that energy storage technology need not limit its use of energy from sources other than solar or wind to under 25% to qualify for investment tax credits. Additionally, a 2023 letter submitted to the Municipal Advisory Council of Texas shows evidence of Bank of America’s continued support for investing in fossil fuels.
Industry Association Governance: Bank of America has disclosed a list of its key industry association memberships, but has not disclosed an account of its industry associations' policy positions and engagement activities, including the US Chamber's opposition to climate disclosure policies in California and at the SEC or Bank Policy Institute's engagement on climate-related risk principles with federal financial regulators. Additionally, it appears to omit some groups including the Greater Boston Chamber of Commerce and the Business Council of Australia.
InfluenceMap collects and assesses evidence of corporate climate policy engagement on a weekly basis, depending on the availability of information from each specific data source (for more information see our methodology). While this analysis flows through to the company’s scores each week, the summary above is updated periodically. This summary was last updated in Q4 2024.
InfluenceMap’s methodology for assessing lobbying on climate 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 lobbying assessment, InfluenceMap considers engagement on all financial policies which intersect with climate issues, as well as “real economy” climate change policies.
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 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 policy issue, across each of the data sources.
The following table outlines the key queries and data sources, which InfluenceMap uses to assess financial institutions' 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.
