Bank of america has incorporated resolution planning

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Bank of America has incorporated Resolution Planning into the Risk Framework. A comprehensive process was designed and deployed to ensure the proper governance and internal controls were incorporated in developing and maintaining the Resolution Plan. In 2011, a Resolution Planning team was established to prepare and submit the initial Resolution Plan in 2012 and to maintain and submit subsequent Resolution Plans. The Resolution Planning team is also responsible for the oversight and coordination of enhancements and actions intended to mitigate impediments to an orderly resolution. The Resolution Planning team reports to the Chief Risk Officer. All processes related to development and management of the Company’s Resolution Plan are coordinated through this centralized team. The Boards of Directors of Bank of America Corporation, BANA, and FIA, respectively, approved the respective Resolution Plans. The Enterprise Risk Committee (“ERC”) of the Board is the subcommittee directly responsible for Resolution Planning. The ERC, among other things, oversees the identification of, management of and planning for, material risks on an enterprise-wide basis, including strategic, credit, market, liquidity, operational, interest rate risk, compliance, and reputational risk. It also oversees capital management and liquidity planning. A review of the Plan was also performed by the Asset Liability Market Risk Committee (“ALMRC”), which is an executive management level sub-committee of the ERC.
33 DESCRIPTION OF MATERIAL MANAGEMENT INFORMATION SYSTEMS The Company recognizes the importance that information availability plays in a resolution situation and continues to evaluate and enhance Management Information Systems (“MIS”) reporting capabilities to ensure they would allow for information needed in a resolution. MIS at Bank of America generally take the form of platform technologies and user interfaces that enable business users to perform analytics and generate standard and ad hoc reporting. Global Technology & Operations (“GT&O”) has the principal responsibility for global end-to-end technology and fulfillment and manages the critical systems and multiple platforms. MIS capabilities are enabled through data repositories and platforms used to aggregate and catalog data core to Bank of America’s operations and management. Bank of America’s key MIS generate numerous reports that are used during the normal course of business to monitor the financial health, risks, and operations of Bank of America, its material entities, core business lines and critical operations. To address financial health, accounting MIS applications are used to produce both management and legal entity reporting. Other financial MIS applications report on funding, liquidity, capital, and Bank of America’s balance sheet. Additionally, risk management MIS applications capture and report credit, market, and operational risk exposures for Bank of America.

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