BANK OF AMERICA CORP DE

Trading Arrangements

During the fiscal quarter ended March 31, 2025, none of the Corporation’s directors or officers (as defined in Rule 16a-1(f) of the Securities Exchange Act of 1934, as amended)adopted orterminated a Rule 10b5-1 trading arrangement or non-Rule 10b5-1 trading arrangement (in each case, as defined in Item 408 of Regulation S-K) for the purchase or sale of the Corporation’s securities.

Disclosure Pursuant to Section 13(r) of the Securities Exchange Act of 1934

Pursuant to Section 13(r) of the Exchange Act, an issuer is required to disclose in its annual or quarterly reports, as applicable, whether it or any of its affiliates knowingly engaged in certain activities, transactions or dealings relating to Iran or with individuals or entities designated pursuant to certain Executive Orders. Disclosure may be required even where the activities, transactions or dealings were conducted in compliance with applicable law. Except as set forth below, as of the date of this Quarterly Report on Form 10-Q, the Corporation is not aware of any other activity, transaction or dealing by any of its affiliates during the quarter ended March 31, 2025 that requires disclosure under Section 13(r) of the Exchange Act.

During the first quarter of 2025, Bank of America, National Association (BANA), a U.S. subsidiary of Bank of America Corporation, processed 85 authorized wire payments totaling $29,281,906 pursuant to four separate general licenses issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) regarding Afghanistan or governing institutions in Afghanistan and activities of international organizations and the U.S. government. 82 of the 85 payments for two BANA clients were processed to Afghan state-owned banks, which are subject to Executive Order 13224. The remaining three payments, on behalf of three BANA clients, were processed to a bank in Yemen that is subject to Executive Order 13224. There was no measurable gross revenue or net profit to the Corporation relating to these transactions, except nominal fees received by BANA for processing payments.

In addition, during the first quarter of 2025, BANA processed 26 payments as an intermediary bank, totaling $146,543, for an entity designated under Executive Order 13224, which was a customer of BANA’s non-U.S. bank client. The payments were processed the day after OFAC’s designation of the entity, and BANA has subsequently disclosed the payments to OFAC. There was no measurable gross revenue or net profit to the Corporation relating to these transactions, except nominal fees received by BANA for processing payments.

The Corporation may in the future engage in authorized transactions for its clients to the extent permitted by U.S. law.