美國銀行 (BAC) 2009 Q2 法說會逐字稿

Welcome to today's teleconference.

At this time all participants are in listen-only mode.

(Operator Instructions).

We'll take questions in turn following the presentation.

Please note today's call may be recorded.

It's now my pleasure to turn the program over to Kevin Stitt.

Please begin, sir.

Good morning.

Before Ken Lewis and Joe Price begin their comments, let me remind you that this presentation does contain some forward-looking statements regarding both our financial condition and financial results and that these statements involve certain risks that may cause actual results in the you future to be different from our current expectations.

These factors include, among other things, changes in economic conditions, changes in interest rates, competitive pressures within the financial services industry, and legislative or regulatory requirements that may affect our businesses.

And for additional factors, please see our press release and SEC documents.

And with that, let me turn it over to Ken Lewis.

Good morning and thanks for joining our earnings review.

The past several quarters have been quite tumultuous.

For the first time in a while, though, we feel less constrained by economic events and more capable of demonstrating progress and momentum.

Driving this attitude were several accomplishments this quarter in the areas of balance sheet strength, solid core operating performance, and ongoing integration and positioning of our businesses.

During the quarter, we increased our Tier One common equity by more than $34 billion the total results of our capital actions, approximately $40 billion, exceeded the capital buffer required by the supervisory capital assessment program by approximately 17%, all while again substantially adding to our credit reserves.

In addition, there were several discernible positive trends in many of our businesses including robust activity in mortgage lending, investment banking and capital markets along with strong deposit growth.

Much like our first quarter results, we were able to generate earnings in the second quarter from various businesses and investments to offset the significant impact from the normally high credit cost and the negative accounting impact from the improvement in our credit spreads.

On the credit spread point, I want go into my opinion here on the counter intuitive accounting for certain liabilities, but suffice to say I'm pleased with both the improvements in the markets and the progress we have made to enable to benefit from this increased market confidence and I would rather see the operating improvements and take the accounting lumps that come with our Company's success.

For the second quarter of 2009, Bank of America earned $3.2 billion, before preferred dividends or $0.33 per diluted share after deducting deferred dividends of approximately $800 million.

Total revenue on an FTE basis was in excess of $33 billion, or pretax preprovision income was approximately $16 billion.

Positive drivers in the quarter included a particularly favorable capital markets environment, which produced a 56% increase in investment banking revenue versus the first quarter and core trading results that exceeded strong first quarter results.

Mortgage banking income remain elevated due to high levels of home loan production.

Benefits were recognized from the partial sale of our investment in China Construction Bank and a gain on the sale of our merchant processing business to a joint venture with First Data Corporation.

Momentum continued in new deposit generation and we focused on prudent balance sheet management, which included lower risk rated assets and significantly higher levels of Tier One common equity which enabled us to end the quarter with a Tier One ratio of 11.9%, a Tier One common ratio of 6.9%, and a tangible common equity ratio of 4.7%, up 154 basis points from March.

These benefits to common equity also pushed our tangible book value per share up 7% to $11.66.

The earnings impact of these positives were offset by continued high level of provision expense, and expense related to the FDIC special assessment for deposit insurance, the negative impact on the improvement in our credit spreads, and lower consumer and commercial customer activity across many of our businesses.

As we experienced in the first quarter, Merrill Lynch and Countrywide continue to provide a significant contribution to revenue.

And more important, both businesses position Bank of America very well to benefit as the global economy stabilizes and begins to grow.

Total credit extended in the second quarter was $211 billion including commercial renewals versus $183 billion in the first quarter.

The larger components are $111 billion in first mortgages, $78 billion in commercial, and $9 billion in commercial real estate.

The remaining $13 billion includes consumer retail loans and small business loans.

Provision expense in the second quarter was in line with the first quarter and included a $4.7 billion reserve increase versus $6.4 billion in the first quarter.

Average retail deposit levels for the quarter excluding Countrywide were up $10.5 billion or 1.7% from the first quarter, which we believe is above industry growth.

Deposit levels at Countrywide continue to drop as anticipated, driven by the alignment of pricing strategies.

I would note that almost all our growth was associated with transaction accounts versus CD or savings accounts.

Before I turn it over to Joe, let me make a couple comments about our thinking given the current environment.

The additions of Countrywide and Merrill Lynch continue to be accretive to earnings year-to-date, as these market sensitive businesses offer diversification to offset the core credit headwinds we're facing.

For the rest of the year, the build-up in late stage delinquencies and continued economic pressures will cause charge-offs to continue to trend upward, although not at the pace we had experienced recently.

Our largest jump in early stage delinquencies late last year essentially hit the 180 day charge-off period this quarter and we haven't seen such early stage jumps since then, as Joe will discuss.

At this point, I would say consumer charge-offs may be close to peaking in dollar terms around year end although we believe they will stay elevated post the peak.

Consequently, reserve increases will most likely continue for the remainder of 2009, although not at the levels we experienced during the first six months of the year.

We continue to position the balance sheet to ride out the recession which you can see in our delevering actions this quarter, adding long-term debt and capital, shrinking certain asset positions and substantially adding to reserve levels.

Having said that, we're actually seeing a lot of business activity as demonstrated by the credit originations I referenced a minute ago.

Our outlook for the economy is close to the consensus view with unemployment peaking somewhere around 10%, we anticipate bankruptcy filings for individuals even after reaching prereform levels to continue to increase, and we believe home price declines, while slowing, still have further to fall.

These are the assumptions we use to run the Company.

Based on this scenario, profitability in the second half of the year will be much tougher than the first half, given the absence of several one-time items that were positive to earnings.

I think we have to get through the next couple of quarters and into 2010 before it becomes apparent that the market strength of our various businesses will help us return to more normalized earnings.

We're still wrestling with the definition of normalized earnings given the future impact on the banking industry of proposed changes in regulatory oversight, accounting changes, and the Card Act.

But we do believe our business model at Bank of America is the best model to benefit from future economic recovery.

At this point, let me turn it over to Joe for much more additional color and commentary.

Thanks, Ken.

Over the next few minutes I'll cover the large items that Ken mentioned, the performance of each of our businesses, our capital markets exposures, credit quality, net interest income and capital levels.

Before getting into the business results, let me highlight the large items that impacted earnings in the second quarter and you can follow this on slide six.

Shares of China Construction Bank were sold for a pretax gain of $5.3 billion, which reduced our ownership to approximately 11%.

Now, any impact from appreciate in the value of the remaining shares over our purchase price is not reflected in our shareholders' equity numbers and won't be until the third quarter of next year, when it will be recognized in other comprehensive income.

Let me touch on the effective rate here as it was impacted by the capital gain in the quarter.

Essentially, the decrease in the effective tax rate was due to permanent tax preferences and the release of a part of a valuation allowance provided on acquired capital loss carry-forward benefits.

We also have a continued shift in the geographic mix of earnings due to Merrill Lynch.

Look for the tax rate to be a little more normalized toward statutory in the second half of the year.

Now, in late June we announced the formation of a joint venture with First Data to deliver next generation payment solutions to merchants.

Due to our contribution to the joint venture, we recorded a recorded $3.8 billion pretax gain.

You shouldn't expect a major change in the ongoing earnings impact to Bank of America given the business' relative size.

Additional details of the joint venture are on slide seven.

Offsetting these pose activities, structured notes issued by Merrill Lynch were mark-to-market under the fair value option resulting in a pretax hit to earnings of $3.6 billion, due to the narrowing of Merrill Lynch credit spreads and if you remember the revaluation was a positive $2.2 billion in the first quarter.

The applicable credit spreads were cut in half during the quarter, which is a good thing, but as Ken said we feel the impact to earnings.

Now, as a reminder, the impact of marking our cash liabilities does not impact Tier One capital.

Credit valuation adjustments on derivative liabilities and these are principally in Tom's trading businesses, were revalued resulted in a negative impact of $1.6 billion versus a positive impact of $1.7 billion in the first quarter.

Again, a good thing but still negative to current period earnings.

Higher deposit insurance premiums due the FDIC special assessment were accrued this quarter and cost us about $760 million.

Now, finally, I'll touch on reductions in market exposures in a few minutes, but let me give you a quick summary of the market disruption charges this quarter which totaled about $1.3 billion.

And leverage lending we wrote down an additional $107 million.

On the CMBS side we took a charge of approximately $570 million.

Primarily related to equity investments and exposure in the hotel industry.

On our remaining CDO related exposure we recorded a loss made up of super senior CDO write-downs and that was about $233 million, write-downs on positions retained from CDO liquidations and that was about $170 million and continued and hopefully the final clean-up of various other CDO related positions where we reassigned responsibility for liquidation for all in total of about $813 million.

These were offset by some net recovers on other legacy positions.

Now, let me quickly touch upon some highlights for each of the businesses this quarter.

Now, as we explained last quarter, impacted some of the segments is lower residual interest income which is the revenue allocated to the business segment that's the result of our asset and liability management and other corporate strategies.

Corporate decisions such as delevering the balance sheet that Ken mentioned or changing interest rate positions will impact a level of residual interest income allocated to the business segment.

Now, in our deposit segment on slide eight, earnings were $505 million in the quarter, down from $601 million in the first quarter.

Second quarter was impacted by a lower interest income allocation, as well as a major portion of the FDIC special assessment.

Absent these items, deposits pretax earnings for the quarter increased $597 million from first quarter, reflecting steady revenue growth and disciplined expense management.

Core net interest income increased $223 million driven by balanced growth of $39.5 billion a slight improvement in deposit spreads.

Now, this quarter reflected the migration of customers from Global Wealth Management to our deposit segment where they can be serviced more efficiently.

The migration contributed $32 billion of linked quarter balance growth.

Now, outside of the balance transfers, average balances grew $13 billion organically, not including the $6 billion of planned runoff in the Countrywide portfolio that Ken referenced a minute ago.

Now, non-interest income of $1.7 billion grew 16% from the first quarter, the result of seasonality, account growth and revenue initiatives.

In Global Card Services on slide 10, a loss of $1.6 billion was recorded and once again was impacted by high credit cost although down $700 million from the first quarter.

Average managed Consumer Credit Card outstanding were down 3% from the first quarter to $172.6 billion.

Now, in the second quarter, retail purchase volume and this would be both debit and credit increased 8% from the first quarter due to seasonality although down 10% from a year ago.

Even though the economy is contracted, we continue to add new accounts.

611,000 new domestic retail and small business credit card accounts in the quarter with credit lines of approximately $4.2 billion.

Now, Home Loans & Insurance and you see this on slide 11 continues to benefit from the low interest rates.

Total revenue for the quarter was $4.5 billion down 15% from first quarter levels, as continued high production revenue was more than offset by lower MSR hedge results.

Mortgage services right hedging was more normal this quarter as the write-up in the asset was offset by hedge losses leaving a benefit of roughly $138 million on a net basis versus $1.3 billion in the first quarter.

The capitalization rate for the MSR asset ended the quarter at 109 basis points.

Provisioning, although down from the first quarter levels, remains high, pushing earnings once again into negative territory.

Total first mortgage fundings at $111 billion were up 30% over first quarter and approximately 29% of the fundings were for home purchases and although benefiting some from seasonality, was a very positive sign for the housing market.

We maintained strong market share during the quarter.

Now, although we've seen volatility in the rate environment, that started to cause the re-fi volumes to trail off in late June and early July, we have observed volumes picking up with the recent decline in 10 year treasuries which says the re-fi market still has some legs going into the second half of the year.

Keep in mind that all of this has occurred as Barbara Desoer's team in Calabasas is managing through the mortgage industry's largest ever consolidation, significant efforts to help customers stay in their homes and a sizable re-fi boom.

Global wealth and investment management and you can see this on slide 12, earned $441 million in the second quarter, down from first quarter levels.

This business was also impacted by our overall balance sheet strategy, as net interest income absorbed over $288 million in lower allocated revenue.

Assets under management ended the quarter at $705 billion, up $8 billion from the end of March, as the improvement in market valuations more than offset outflows from the money market funds.

Non-interest income increased from the first quarter, driven by lower support to certain cash funds, and higher brokerage activity.

Turnover among our financial advisor has slowed and we ended the quarter with approximately 15,000.

We plan to add to our sales force and are ramping up up our trainee program, which was put on hold during the first six months of integration.

Global Banking, you see this on slide 13, which encompasses our commercial bank, corporate bank and the investment bank, earned $2.5 billion in the quarter versus $172 million in the first quarter, primarily due to the gain from the sale of our merchant processing business as part of our joint venture.

Loan spreads continued to widen as facilities were repriced at higher market rates.

Although commercial and corporate clients are being cautious given the economy and balances are down, we continue to see improved credit spreads as market prices reflect underlying risks.

Provisioning expense increased 40% to $2.6 billion, and reflected a reserve increase of $1.1 billion.

Average loans as reported for the quarter were down 2% from the first quarter as clients continued to reduce inventories, and capital expenditures while aggressively managing working capital levels.

However, average deposit levels increased $4 billion or almost 2% from the first quarter levels.

Investment Banking fees and this would be across the whole corporation, were $1.65 billion, and that's detailed on slide 14.

It was up 56% versus the first quarter.

High yield loan syndication and equity capital markets experienced significant growth with syndication fees during the quarter hitting record levels.

Advisory revenues dropped by 11% on the back of a substantial drop in global M&A activities and fee pools.

The combined Bank of America, Merrill Lynch franchise ranked number one in high yield debt, leveraged loans and MBS, number two in ABS bill volume, and ranked number three in global and number two in US investment banking fees for the first half of 2009.

Turning to Global Markets, on slide 15, they earned $1.4 billion in the second quarter versus $2.4 billion in the first quarter.

The trading environment in the second quarter continued to been fit from the improving credit markets and core revenue increased after normalizing for credit valuation adjustments on derivative liabilities and market disruption charges.

Our credit businesses and think of this as high grade, high yield public finance and distress had a great quarter, which more than offset a seasonal decline in Commodities and reduced opportunities in rates an currencies due to lower volatility.

Risk weighted assets declined nearly 12% reflecting a more efficient use of the balance sheet and market value changes.

As you see on slide 16, sales and trading revenue in the second quarter was $3.9 billion versus $6.3 billion in the first quarter.

Now as I mentioned earlier, results this quarter included charges on legacy positions of $1.3 billion in credit valuation adjustments on derivative liabilities of $1.6 billion.

Legacy charges in the first quarter were a negative $1.7 billion, while credit valuation adjustments on derivative liabilities in the first quarter were a positive $1.7 billion.

Excluding the corresponding impact of legacy adjustments and credit valuation adjustments, our sales and trading revenue this quarter was up approximately $422 million, to more than $6.7 billion driven mainly by fixed income.

Now, driving this improvement was strong performance in credit trading due to strong client flows in a market where liquidity rebounded.

We detail on slide 17 and 18, a number of the most pertinent legacy exposures in the capital markets businesses.

The largest reductions in exposure this quarter were centered in credit default swaps with monoline financial guarantors, where we saw $11 billion of notion come off which represents a reduction of about 20%.

Additionally, the leveraged loan exposure is down to $3 billion on a carried basis, a reduction of $1.4 billion in the second quarter with the remaining exposure made up of senior secured bank debt versus bridge or junior debt tranches.

The one area that still needs additional liquidity is CMBS.

There has been a small amount of activity in I guess what you'd call "[re-rimmicking]", evidencing some signs of life and spreads have come in, but the activity remains small and while discussions are becoming more robust, know meaningful origination or distribution of positions has occurred.

Not included in the six business segments is equity investment income of $6 billion in the second quarter and that's included on slide 19.

As Ken said earlier, we sold some our investment in China Construction Bank and booked a pretax gain of $5.3 billion.

In addition we had securities gains of approximately $632 million, offset by impairment charges of non-agency RMBS of $639 million.

These positions continued to deteriorate given the weaker underlying cash flows from consumer mortgages.

Now let me switch to credit quality that starts on slide 20.

As Ken referenced, credit quality deteriorated further during the quarter as the economy continued to weaken.

Consumers experienced increased stress from higher unemployment and underemployment levels, increased bankruptcies, as well as further declines in home prices leading to higher losses in almost all of our consumer portfolios.

These factors along with continued pull backs of spending by both consumers and businesses and weakening commercial real estate also negatively impacted the commercial portfolio.

Second quarter provision of $13.4 billion exceeded net charge-offs reflecting the addition of $4.7 billion to the reserve, versus an addition of $6.4 billion in the first quarter, as we strengthened our balance sheet to absorb expected losses going forward.

Now, sustained headwinds from the recession continued to impact our consumer portfolios, resulting in reserve increases for most consumer related products, most notably residential mortgage and home equity, albeit at lower levels than the first quarter.

On the commercial side, we added approximately $1.1 billion to the core commercial reserves, with a little over half of that in the commercial real estate portfolio, reflecting deterioration outside of residential, particularly across retail and office.

And the remainder in the commercial domestic portfolio, from deterioration, which was broad-based in terms of borrowers and industries.

Now, the reserve additions also include approximately $855 million associated with a reduction in expected principal cash flows mostly related to Countrywide, but also some on the Merrill Lynch impaired portfolios driven mainly by continued deterioration in the economy and the home price outlook.

Our allowance for loan and lease losses now stands at $33.8 billion or 3.6% of our loan and lease portfolio.

Our reserve for unfunded commitments now stands at $2 billion bringing the total reserve to $35.8 billion.

We expect continued reserve increases in the second half of 2009, but again, as Ken said, not at the levels experienced so far this year.

Obviously, the ultimate level of credit losses and reserve increases will be dependent on the severity and duration of the credit cycle.

Now, on a held basis, net charge-offs in the quarter increased 79 basis points from first quarter levels to 3.64% of the portfolio, or $8.7 billion.

On a managed basis, overall consolidated net losses in the quarter, increased 102 basis points to 4.42% of the managed loan portfolio or $11.7 billion.

Net losses in the consumer portfolios were 5.45% versus 4.26% in the first quarter.

Due to the reduction in balances, principally in the unsecured products, the loss rates are somewhat distorted so I'll talk about them more in dollar terms.

Credit card represents 53% of total managed consumer losses.

As you can see on slide 21, managed Consumer Credit Card net losses were $5 billion, compared to $3.8 billion in the first quarter.

If you remember, the largest jump in early stage delinquencies in our card business was in late 2008, so with 180 day charge-off policy you can see why losses increased this quarter.

30 day plus delinquencies in Consumer Credit Card decreased more than $600 million.

Now, while some what we're seeing in early stage delinquencies probably has a seasonality component, we're cautiously optimistic that those trends, if sustained, could eventually stabilize losses.

However, continued economic weakness in the US and Europe and higher levels of bankruptcies would obviously keep pressure on this performance.

Now, I should note here that much of our reserve increase this quarter in US card related to maturing securitizations and the need to provide reserves if that exposure came back on the balance sheet, rather than being principally related to further unexpected deterioration.

Credit quality in our consumer real estate business continued to deteriorate in the second quarter as shown on slide 22.

Before I get into the individual consumer real estate products, let me speak to a couple of important drivers.

MPAs which are highlighted on slide 27 increased $3.2 billion in the second quarter compared to an increase of $4.6 billion in the first quarter and now total $19.1 billion.

This is primarily comprised of consumer real estate with the lion's share being first mortgages.

Now, there are a number of things affecting this portfolio but as a reminder, we generally move consumer real estate to non-performing at 90 days past due and take charge-offs at 180 days.

At which time, we write the loans down to appraised value and perform quarterly refreshes, taking additional write-downs as needed.

We also have troubled debt restructurings or TDRs which I'll define in a moment that are reflected a as MPAs even though they were not 90 days past due when the restructuring or the remodification was made and lastly, as you're aware, the various moratoriums we instituted on foreclosures have had the effect of holding up loans in non-performing status versus allowing them to clear into REO and ultimate sell.

While our efforts to responsibly keep borrowers in their homes and paying as we think that reduces the overall costs, the impact is that the MPA number is inflated.

Formal moratoriums have now been lifted as the MHA program and other modification efforts are all up and running.

Therefore, once a loan has been evaluated under all our various programs, if no other alternative exists, those loans will be released into foreclosure.

Now, specifically switching to home equity, and this is back on slide 22, our home equity portfolio continued to be negatively impacted by rising unemployment and centered in higher CLTV loans particularly in the states that have experienced the significant decreases in home prices.

Home equity net charge-offs increased to $1.8 billion compared to $1.7 billion in the first quarter.

Now, as we saw in card, 30 plus performing delinquencies are down $646 million, or 39 basis points to 1.29%, which is a positive sign.

We're attributing part of the trend to early collection efforts and some seasonality until we see it sustained.

Now, we continue to see increased utilization rates and they're up about 140 basis points to 55%, although period end balances are down and net draws on home equity lines were at their lowest compared to the past several quarters, I think they were under $2 billion this quarter.

Open lines are $100 billion are for the most part to customers with refreshed FICOs greater than 740 scores and refreshed CLTVs of less than 90%.

Non-performing assets in home equity and this principally loans greater than 90 days past due, rose to $3.97 billion, an increase of $300 million, less than half of the increase we saw in the first quarter.

Now, as you're aware, we've been working with borrowers to modify their loans to terms that better align with their current ability to pay.

When we do that, under most circumstances, we identify these as troubled debt restructurings or TDRs, which are modifications where economic concession has been granted to the borrower.

Some of these modified loans were already in our non-performing assets.

However, many were accelerated into non-performing classification upon modification.

Non-performing home equity TDRs increased $700 million.

The acceleration of performing loans into MPAs upon modification was the principal driver of the MPA increase, as 75% or $650 million of the home equity non-performing TDRs done in the quarter were performing at the time of modification.

To give you some additional color on the MPAs, TDRs where we have improved the likelihood of repayment make up 36% of home equity MPAs.

In addition, about one third or $1.4 billion of the MPAs are greater than 180 days past due and have been written down to appraised values.

Now, we increased reserves for this portfolio to $8.7 billion or 5.59% of ending balances due to continued elevated levels of delinquencies and size of the unit charge-offs which is more reflective of the size of the delinquent loans than in increasing severity as severities have actually extra stabilized.

Now, our residential mortgage portfolio showed an increase in losses to $1.1 billion or 172 basis points.

That's 138 basis points net of our [resi wrap] from the $785 million, and an increase pretty consistent with what we saw in the first quarter.

As we saw in other areas, we've now seen two consecutive quarters of stable or as was the case this quarter, declining 30 day delinquencies.

On the non-performing asset front we saw an increase of $2.8 billion, about a quarter less than the $3.8 billion we saw in the first quarter.

Non-performing TDRs increased $1.3 billion in the second quarter, with about 35% of the increase being from loans that were performing at the time of modification.

Now, of the $14.5 billion of residential mortgage MPAs, TDRs make up 14%.

About 60% or $8.8 billion of the MPAs are greater than 180 days past due and have been written down to appraised value.

Given the weakness in the economy and continued declines in home prices, we anticipate continued deterioration in this portfolio and therefore would expect some additional reserve increases.

Our reserve levels were increased on this portfolio during the quarter and represent 1.67% of period end loan balances.

Now, on slide 23 we provide you with details on our direct and indirect loans which includes the auto and other dealer related portfolios, as well as consumer lending.

Net charge-offs in our auto and other dealer related portfolios actually decreased to $199 million or 1.96%, from 2.78% in the first quarter.

Probably a slight extension of the normal seasonality pattern but clearly encouraging.

We saw the expected increase in consumer lending charge-offs that were reserved for over the last several quarters and expect them to somewhat level off in dollar terms due to the improvements in both early and later stage delinquencies.

Switching to our consumer portfolios, and you can see this on slide 28, net charge-offs increased in the quarter to $2.1 billion, or 237 basis points up to 69 basis points from the first quarter.

Net losses in our $18 billion small business portfolio, which are reported as commercial loan losses increased $140 million to 16.69%, and are most pronounced in states experiencing severe housing pressure.

As we talked about before, many of the issues in small business relate to how we grew the portfolio over the past few years, which is now compounded by the current economic trends.

However, we think we're close to a peak in small business losses as indicated by linked quarter declines and 30 plus delinquencies and flat 90 plus delinquencies.

Our current allowance stands at 16% of the portfolio.

Excluding small business, commercial net charge-offs increased $461 million from the first quarter, to $1.3 billion, representing a charge-off ratio of 158 basis points.

The increase was driven by commercial domestic exposure centered in the financial sector and to a lesser extent by commercial real estate.

Now, in total, the losses in the quarter were split almost equally between non-real estate and real estate.

A couple of individual exposures drove most of the non-real estate increase and the rest was pretty granular.

Now, within commercial real estate, net losses increased 78 basis points to 3.34%.

While commercial real estate losses continued to be centered in home builders, I think that was more than 60% of the second quarter real estate losses, about 26% were related to principally office and retail.

Commercial MPAs and this is detailed on slide 29 rose $2.2 billion, $669 million less than the increase in the first quarter, to $11.9 billion.

50% of the increase was due to commercial real estate, trending more to non-residential exposure like office and retail versus home builders, which had driven much of the increase over the past few quarters.

Let me give you some color behind the makeup of our commercial MPAs.

Commercial real estate makes up about 60% of the balance or about $7 billion with a little over half of that being home builders.

Outside of commercial real estate, the balance is concentrated in housing related and consumer dependent portfolios within commercial domestic.

MPAs are most significant in commercial services and supplies, and here think realtors or employment agencies, office supplies or those types of companies, at 5% of total of commercial non MPAs followed by individuals and trusts, capital markets, and vehicle dealers at 3% each, and no other industry comprises greater than 2%.

Just under 90% of our commercial MPAs are collateralized and almost 40% are contractually current.

Total commercial MPAs are carried at about 75% of original value before considering our loan loss reserves.

Reservable criticized utilized exposure in our commercial book, increased $8.5 billion in the second quarter, compared to an increase of $11.7 billion in the first.

While the increase was still large and reflective of the continued deterioration in the economy, it slowed and was comprised of about 40% real estate and 60% non-real estate.

Commercial real estate criticized increased $3.6 billion, to $21.2 billion.

While home builders with $7.3 billion still represent the largest concentration, we actually saw a reduction there of $330 million.

Now the largest increases were in retail and office, which are our second and third largest criticized concentrations within commercial real estate.

Outside of commercial real estate, we saw further weakening and again housing related and consumer dependent businesses.

80% of the assets in the commercial reservable criticized are secured, of which 10% is in our highly secured asset based lending business.

Also remember that asset based lending shows a resurgence in recessionary environment and that many of our asset based lending credits are considered criticized as soon as the loan is made but charge-offs are exceptionally low due to the high margin requirements.

While we obviously see some continued deterioration, our past rated credit discussions this quarter have felt much better than they have over the course of the last few quarters.

Assuming no change, that should translate into lower flows into criticized.

Now, going forward, we think we'll see some leveling off or decline in home builder charge-offs offset by increases in non-residential commercial real estate as well as commercial domestic.

In the non-real estate charge-offs this quarter, we expect to see more diverse charge-offs over the next several quarters, given the economy.

Now, as we did with all portfolios, additional reserves were added in the second quarter, bringing our commercial coverage to 2.48% of loans that would be 1.76% excluding small business.

Let me get off credit quality and say a couple of things about net interest income and I'm on slide 31.

Compared to first quarter on a managed and FTE basis, net interest income was down $892 million.

Core NII dropped to approximately $527 million while market based NII, dropped by $365 million, in line directionally with our comments three months ago.

Now, the core NII decrease was due mainly to our continued delevering of the ALM portfolio and lower loan levels, which was across the board due to weaker demand, partially offset by the impact of favorable rate environment and improved pricing.

Also impacting our net interest income was the drag from asset quality, both non-performing as well as interest reversals.

This negative impact on core managed NII in the second quarter was $1.1 billion, due to non-performing assets, and that was approximately -- or non-performing assets of approximately $300 million and interest reversals of approximately $800 million.

Combined, this impact was approximately $200 million worse than first quarter.

And most of the earned interest reversals as you might imagine relate to credit card.

The core net interest margin on a managed basis increased seven basis points to 3.72% due to improved yield curve.

At this point I wouldn't expect a lot of movement in the core net interest income margin in the near term.

And the negative impact of the discretionary portfolio delevering was pretty much absorbed this quarter.

Now, prior to the fourth quarter, our risk position had been liability sensitive where we benefit as rates decline and are exposed as rates rise.

As we discussed last quarter, our risk position has evolved to become more asset sensitive due to a reduction in fixed rate mortgages because of the deleveraging and the addition of Merrill Lynch.

As you can see from the bubble chart on slide 33 which as you know is based on the forward curve, our interest rate risk position hasn't changed much from the first quarter.

Given how low rates are, we're comfortable with our current interest rate risk profile.

Let me say a few things about capital.

You can see this on slide 35.

The Tier One capital ratio at the end of June was 11.93%, up 184 basis points or $20 billion from the first quarter due mainly to our capital actions in the second quarter.

Our Tier One capital level is $95 billion in excess of the 6% well capitalized minimum requirement.

Tier One common increased $34 billion to 6.9%, an increase of 241 basis points.

Now, I should note here that we have also increased credit reserves $11 billion since year end, the effective date of the stress test.

Our tangible common equity ratio increased 154 basis points to 4.67%.

During the quarter, we raised and you can see this on slide 36 almost $13.5 billion in common equity through the direct issuance of 1.25 billion common shares at a price of $10.77 per share and exchanged an additional one billion shares at an effective price of $14.80 per share for $14.8 billion of preferred stock for a combined total of $28.3 billion in new common equity.

The exchange for preferred shares will translate into reduced dividends of almost $1 billion on an annual basis.

Quarterly preferred dividend payments going forward are projected to be $1.1 billion, $350 million for private preferreds.

And approximately $713 million for government preferreds plus an additional $180 million of non-cash amortization of the discounts related to assigning value to the warrants and the TARP deals.

Remaining private preferreds at the the end of June total $18 billion as you can see on slide 37, down $14.8 billion from the end of March.

Now, we gave you a good deal of detail on the package and previously filed 8-Ks on the impact of the share exchanges on this quarter's earnings, share count and the other applicable information that should help you in your modeling.

Going forward into the second half of 2009, and in line with what Ken said, we've been fighting the downturn for almost two years now, but think we are seeing a slowing in credit deterioration with a peak in overall credit losses over the next few quarters.

Having said that, it's difficult to call the specific quarter when credit costs start to drop substantially from the peak.

Now, however, once we hit the inflection point on losses where we no longer have to build reserves we should get some significant lift.

We have a very strong balance sheet and a robust and conservative liquidity position, strong credit reserves and a solid capital position.

As our six month results demonstrated we're engaged 100% in leveraging the strengths of the corporation to be profitable on an EPS basis, and add to our capital levels.

While we expect credit losses to trend higher in most of our businesses, we believe the level of our reserves and revenue generation over the next several quarters will enable us to get through the period with minimal impact on capital levels.

Both Merrill Lynch and Countrywide contributed positively to earnings over the first half of the year.

And the Merrill Lynch integration effort is on track and continues to make headway.

Cost saves were approximately $800 million this quarter or $1.2 billion for six months so we're well on our way towards exceeding 40% of the total cost saves which if you remember were targeted at $7 billion annually in 2009 and well ahead of our original goal.

So, while the next few will be challenging, we saw great business momentum this quarter and believe we can continue to move Bank of America forward from both a competitive and operational standpoint.

With that, let me open it up for questions and thank you for your attention.

Thank you, sir.

(Operator Instructions).

This one from Meredith Whitney with Meredith Whitney Advisory Group.

Good morning.

I have a couple unrelated questions.

My first one is related to the merchant processing business joint venture with First Data.

Is Charlie Fort the private investor who is investing along with you and then can you talk about or give us an idea about the capital structure that entity may at some point take on in terms of -- is that a potential spin out?

That's the first question.

Then I have a follow-up after that, please.

Meredith, we haven't disclosed the third party investor of either side, first data, nor us.

On the second part, what I would tell you is we're really focused on combining the two platforms, kind of focused on serving our clients and taking advantage of that.

Any subsequent actions are right now not on the horizon.

That's a down the road kind of question.

Okay.

And then my next question has to do with small businesses and unrelated but also related to the fact that your multi-seller conduit facility was down this quarter.

The broader question, understand that environment.

Is that market in any way coming back?

What's the outlook on that market?

And then if you could just speak more broadly to small businesses, obviously CIT's been in the headlines, your outlook on small businesses related to cards as well, that would be helpful.

Thanks so much.

Well, I guess we had a couple comments in our remarks where we're continuing -- we as a Company are continuing to do business and be active in lending there.

I'd say on a broader basis, and I'm going to merge slightly small business with maybe the part of middle market, if you went around the franchise, I think you would generally hear from a business standpoint, because of the consumer pullback, continued tight management of inventory levels, working capital, suspension of CapEx, all those same types of things just on a slightly smaller scale as you go down the spectrum of the size of the Company.

So all of that is still there.

I would probably then based on that characterize it as much demand driven and actions by the small businesses, as it is inability to find financing to be able to grow, obviously, there's some piece of that but that's the way we kind of are seeing it right now.

Just one last question.

I had asked this on last quarter's conference call as well.

Some think that California real estate has bottomed.

You still see a contraction in liquidity to subprime and some subprime actually looks like it deteriorated, this is for the industry, this quarter.

Could you comment on your outlook on subprime because you do have exposure there and as does the industry and if we're seeing stabilization of losses there or what your outlook is?

Yes, Meredith, I think California is so large that it's hard to always talk about it as one single market.

But what we have seen is in the hardest hit areas, you are seeing actually some home price increases and increases in sales.

But that's off a very, very low bottom.

We'll go to our next question, this one from the site of Adam [Herch] from Jupiter Advisors.

Your line is open.

Good morning.

Thank you.

Could you give us additional insight into the credit card business and maybe how losses at the credit card business on a frequency and severity basis fire compare to the industry overall?

Thank you.

Well, if you look at our credit card business, it tends to have -- each competitor is different, so it's hard to kind of just do it to the industry at large, but we tend to have a good bit of borrowing kind of business as opposed to necessarily just pure transacting business and as a result of that more of our traditional revenue stream in the last few years has come from associated revenue, interest income and the other attendant revenue flows off of that.

In addition to that, we probably have traditionally run a little higher line size and therefore, because of that, you would see slightly higher loss per account when you come through.

So that's probably the way to contrast or compare to the industry.

There are a number of other factors but that one would probably be one pointed to what you were asking.

What that would suggest is that by pulling in lines across the business, there should be an ability to control for the losses going forward.

Well, line management efforts obviously are all focused on controlling losses from there.

I'd say that that's part of the strategy but obviously the strength of the consumer will be the overriding factor.

Thank you very much.

You've actually got two variables that go a different way.

You've got increased bankruptcies and unemployment levels going up and those obviously are drivers and then on the other side you've got 90 day and 30 day delinquencies going the right way.

So at some point, the 30 day, 90 day phenomenon will win out.

That's going to take several quarters.

Thanks.

We'll go next to the site of Matt O'Connor from Deutsche Bank.

Your line is open.

Good morning.

Hi, Matt.

Some early signs that the consumer is bottoming here while at the same time maybe there's signs that the commercial buckets collectively are getting worse for the industry.

Obviously Bank of America is more tilted toward the consumer.

Think of that macro backdrop and your mix, as we think about the charge-offs peaking over the next few quarters, is the outlook do you think at this point more uncertain on the commercial side or the consumer side in terms of predicting the peak of losses?

I don't know that I -- I don't know that I have a good answer for you, Matt.

I think on the consumer side, the delinquency levels and the other factors that Ken kind of references has given us some insight if those are sustained in being able to predict leveling off and then at some point peaking on there and you do that on a portfolio basis.

For commercial, you tend to focus -- and I'm talking beyond small business -- you tend to focus individual credit by credit when you're looking at charge-offs and so you probably have a little better ability to look forward on that and it's less macroeconomic trended, it's more individual credit because of the structure of the deals and things like that.

So I think generally speaking, you tend to have more comfort, if you want to call it that, in some of the commercial outlooks than you do on consumer, but it's more because of the type of the credit and the ability to look at the structure than the economic backdrop that you talked about which your indication would otherwise be the way to think about it.

And if you think about -- if you think that the economy is beginning to bottom and you'll get some stabilization or some slight improvement in the economy, that would say that you would rather be dealing with the commercial side than what we've been dealing with on the consumer side.

I guess it's just hard to tell on the commercial side whether there's a lag in terms of the economy and I think the banks in general including you guys did a much better job underwriting commercial than maybe some of the previous cycles but it's hard to get your arms around if there's a lag.

I think there's a little bit of a lag but you do have the economy's bottoming going for you if that's the case.

Just separately, there's a lot of accounting proposals out there and regulatory proposals in general, who knows how it will all play out.

One thing that seems high probability is that the credit card receivables will come on balance sheet I believe beginning next year.

Some reserve accounting will change.

I think you've got about $85 billion, $86 billion of securitized card.

As you work on your capital planning, your reserve methodology, how have you accounted for that.

Well, it's clearly considered.

Remember that the trusts, the credit card trust came on balance sheet for regulatory accounting purposes in the first quarter.

Obviously, you still have to deal with the reserve impact of it and then from a GAAP standpoint, in January you would anticipate that coming on.

Clearly -- and it wouldn't be limited, Matt, just to cards.

Under the new accounting, it would be a number of the off-balance sheet structures but card being the biggest one.

Right now, that roll-on fits into our capital planning and our analysis of reserves, and necessary reserves, so we're assuming that both the credit card trust, the revolving home equity, and the asset based conduits come back on and some other things.

Many of those like the asset based already again carry regulatory capital wouldn't have big reserve requirements so focus back on card, we would envision putting it on and putting reserves on for that under our current methodology.

The Tier One common ratio already includes in the RWAs the securitized credit card?

Assets, Yes, Yes.

Okay.

And then the reserving, I mean, typically I guess it's nine months of reserves?

Yes, it's not quite that clean but whatever our existing policy is at the point in time would be what we would be following and we have a little more other items that stick on top of that nine, but generally and directionally you're there.

All right.

Thank you very much.

We'll take our next question from the site of Paul Miller with FBR Capital Markets.

Your line is open.

Thank you very much.

I think everybody's trying to predict when we peak out on these charge-offs but we still got an unemployment rate that continues to grow I think faster than expectations.

When do you think that -- can we see a peak in charge-offs before the unemployment rate peaks or will it most likely come after the unemployment rate peaks or the job market peaks.

I know the unemployment rate is kind of -- it's a wild card.

It's speculation from that standpoint.

What I would tell you is that we have seen in the early stage, and again, you've got to be careful because there's two quarter -- two quarters don't make a trend but you have seen reductions in early stage delinquencies and in some into the later stage in some of the -- like home equity product that we talked about that has occurred at the same time that you have seen what's happened to unemployment.

So I think there's so many factors working on a consumer's ability to pay, unemployment is one.

Underemployment is one, all the other factors, that it's hard to get comfortable that the traditional correlation really is as tight as we might have been able to predict in the past.

And the bankruptcy factor, Paul.

That's a big -- that is a big deal.

Yes, I guess the other question is I know the bankruptcy thing is convoluting the data.

The other is the cure rates.

Some of the feedback that I get is that the cure rates are not at traditional levels either.

Even though we're seeing some stabilization at 30 day, is the cure rate improving from a year ago or six months ago also or are they relatively the same or getting worse?

We'll probably have to have -- get back to you specifically on any particular portfolio.

I'd tell you, if you just kind of look at returns to early stage buckets or returns to other things for something like real estate product, it takes quite a few sustained on-time payments to get returned to accrual status and that I would say you're probably right.

You haven't seen a lot of kind of migration from cures back in on that product.

Card is probably a little more traditional.

And then moving on to I guess another big macro question, I mean, you guys did a really good job with your pretax, preprovision numbers, $14 billion range.

Which if you go back six months ago and I think Ken you made a comment that you thought your pretax, preprovision numbers for this combined Company could be in that $45 billion, $50 billion range.

I don't know if you updated that.

If you did, I missed it.

You're definitely ahead of that pace.

Do you think that that $14 billion is sustainable over the next couple quarters?

I know that's a tough question to ask but I think that goes a long way determining where the valuation of this thing is.

Yes.

I think the -- the issue is the volatility of course in your capital markets.

It's such a big factor that it's hard to say.

I would -- I feel very comfortable with the earlier comments about the annualized preprovision number and -- but to talk about it on a quarter-to-quarter basis is pretty hard, Paul.

Okay.

I know it is, Ken.

Hey, Ken, thank you very much.

Okay.

Thanks.

We'll go next to the site of Mike Mayo with CLSA.

Your line is open.

Good morning.

Good morning.

A little bit more on the 30 to 90 day stage delinquencies are looking good but the outlook is still negative for the next six months.

The first question is, what's the severity on these lines?

In other words, even if delinquencies were to stabilize, would worse severity mean higher loan losses in the future?

That's kind of number one.

Number two, Joe, can you elaborate on what you mean by the seasonal impact on delinquencies?

I guess.

Number three, I guess you're assuming 10% unemployment where as our economist here is expected 11.5% unemployment.

So what would be the impact if we got to that higher unemployment level?

Let me give these a shot, Mike.

Might have to remind me at the end of the question.

On the severity, the seasonal I'm pact and the impact of unemployment.

Yes, on the severity side, and it's easiest for me to think about that on the consumer real estate product, our increases that we experienced some increases on let's call it on a unit basis this quarter, but they really weren't driven by severity.

Severities actually held in reasonably well over the last six months.

What we've tended to see is a little bit larger loan side which kind of tells you it's a migration probably out of subprime into a different customer over the course of the last six months, so you have bigger loan size at the same severity gave you a little higher loss per unit.

That tends to be what we've seen more of in that product type.

On your seasonality, and of course that's a big part of our portfolio, on the seasonality component, it doesn't necessarily hold in all products but you generally see a slight decline in delinquencies and even charge-offs in the early part of the year, let's call it the latter part of the first quarter, into the second and kind of like a check mark, tends to trend back up a little bit.

This is a little more sustained than that and its rolled in some cases to later stage buckets but we are still attributing a good part of that improvement to seasonality until it holds on a sustained basis and works its way all the way through to charge offs.

What is it about the seasonal factor?

What's the factor behind that?

Well, for instance, tax refunds, Mike.

Anything else that comes to mind?

You tend to get -- take something like the auto business, you tend to get new models coming in.

There are a number of things that happen in the industry that tend to drive it.

Spring season, people want to in in their boats on the lake.

There are all kind of little behavioral things that might cause the consumer to be -- to come a little more current or be more timely in that first point.

Okay.

And then the last question, unemployment, if we -- instead peak at 11.5% instead of 10%, what impact would that have on your charge-off expectations?

Well, I mean, for an unemployment level to continue to increase, clearly it signals a broader weakness in the economy and continued weakness in consumer spending and all those things.

I'm not -- I don't have a pinpoint answer for you as much as it would be additional costs that we would have to absorb, probably most pertinently on the consumer side.

But it would roll through that additional weakness would roll through your commercial portfolios.

I don't know if it's as simple as saying 11% is a more than 10%.

I think it's that simple.

When we do, and we have scenarios that at higher employment levels, I just don't have it before me, Mike.

Okay.

All right.

Thank you.

Thanks, Mike.

Take the next question from the site of Ed Najarian from ISI Group.

Your line is open.

Good morning.

Thank you for taking my question.

Just a couple of quick questions.

Number one, did you actually give the amount of the tax benefit that you outlined or do you have the dollar amount of that tax benefit?

You mean -- no, we didn't disclose the specifics but think of it as driving the principal benefit in the first quarter.

Okay.

So -- but we can't get sort of an estimate of the dollar amount of that tax benefit this quarter?

Let me -- when I get to the 10-Q and we put the details in, I'll -- we'll put it in there, but think of the Merrill Lynch unrecognized capital loss carry-forwards that were basically triggered due to our change in capital gains, actual and outlook, as being the principal driver that released that.

Do you have kind of a range of what the normalized or what the -- what approximately the tax rate would have been without that benefit in 2Q?

No, the only -- again, that's kind of the backside of asking the same question.

When we get the Q out you'll see a reconciliation of the unused benefits that we'll lay out.

But just think going forward of migrating back towards something more towards I guess conceptually a statutory kind of rate.

Okay.

And then second question has to do with the change in the credit card rules, credit card holder bill of rights I guess it's called.

JPMorgan outlined that they expected that to negatively impact revenue by about $500 million to $700 million in 2010.

Do you guys have any kind of an estimate on how that will impact your credit card revenues?

It should be about the same.

They're about the same size portfolios and we're obviously working on that issue because it's enough to get your attention and seeing ways if there are ways that we can mitigate that number.

But that's a decent ballpark number.

And then would you expect to be able to sort of work around that number, so that the bulk of that revenue would come back the following year, based on changing product structures and things like that?

That's really what we're working on as we speak, Ed, trying to see how we can offset the negative impacts.

All right.

Thank you.

And then this is kind of a very long range, big picture kind of question, but just sitting here today and thinking about getting through this credit cycle, continuing to build capital ratios, what are your preliminary thoughts about the process that you would go through and maybe even if you could give any insight on the timing that you would think about in terms of repaying the TARP preferred equity.

In other words, would it be we'll take our time, we'll continue to build capital and try to pay as much of that back without issuing stock as possible or would you -- would it be more in the realm of, you know, we would like to pay it back sooner rather than later and would be willing to raise capital to do so?

Well, we've raised the capital and as you can see from some of the ratios, they -- just well north of any minimum, well capitalized numbers.

Our desire is to pay the TARP money back sooner rather than later.

We do -- we've got the capital ratios and liquidity.

We don't think we would be allowed to do it all at once and so the first thing is just conversations about when can we begin and how much.

And so those discussions have begun, Ed, but I can't give you a time frame other than saying that we're in discussions.

And just one more quick question related to that.

To the extent that you would have to raise at least some equity to pay back the $45 billion, would you expect that capital to be raised as preferred or as common?

Again, as Ken said, we think the capital that we've raised so far gives us clear flexibility on beginning a process here and the ultimate full repayment will be dependent a little bit on where the state of the economy is, the economy improves and our internal generation comes back strong, that would be the preferred approach to go after it.

Okay.

All right.

Thanks, guys.

We'll go next to the site of Betsy Graseck with Morgan Stanley.

Your line is open.

Thank you.

Good morning.

Hi Betsy.

Hey Betsy.

Hi.

Couple questions.

One's on California, just generally speaking, there is the budget issue, the IOU issue that's going on right now.

How do you think about the degree with which that impacts your portfolio?

Are you doing anything from a risk management perspective differently due to that situation?

Well, I don't know if it's incremental specifically to that situation, Betsy.

If you thing about what is kind of where you had a lot of the increase in home prices and then the subsequent hardest drops, California was obviously one of those so a lot of your risk management practices were kind of migrated over the course of the last year plus, from that standpoint.

The actual exposure, direct exposure to the state is manageable when the IOU issue was not as big as might have been predicted.

So it comes back to how's the state of the economy in California and as Ken said, we are seeing some bottoming out in some areas of California, from a consumer real estate standpoint, seeing some good signs in the terms of sales, increases and inventories coming down and things like that.

But it is still a tough unemployment situation in the state and you add the state budget to it, makes us stay very focused.

But I wouldn't say any less or any more focused than we were because we already had it as an area that you were looking at.

Then on the reinvestment of your liquidity, your liquidity's building as you indicated.

Can you give us a sense as to how you will be approaching reinvestment opportunities and is there an opportunity to reduce some of these negative drags on NII such that NII may have bottomed this quarter?

That's a tough question because as you know the dominant dimension of this Company is the stable funding base and that's what we're going to protect so as long as the outlook is still uncertain, I guess is what as the outlook is still uncertain, I guess is what I would call it, you should expect to see us to continue to protect liquidity and that would be in the forefront of what we're doing.

You couple that with where the rate structure is right now and other things and I'll call it lack of opportunity maybe for shorter duration, good spread product and it leaves you with probably being patient rather than trying to jump back into something.

Which means Betsy kind of a steady NII for the next few quarters at least.

Okay.

Thanks.

We'll go next to the site of Jefferson Harralson with KBW.

Your line is open.

I was going to follow up on an earlier question about the off-balance sheet assets coming back on.

You talked about prefunding some reserve build for those assets coming on.

Can you talk about I guess how much reserve is sitting on the balance sheet for in anticipation of the cards coming back on?

Yes, I didn't mean for you to interpret what I said earlier of prefunding.

Under the accounting rules, when the under GAAP when the structures come back on is when you need to put your reserves on.

What I was speaking to was the risk weighted assets have already come back on for regulatory capital purposes for the credit card trust and then the ways asset based conduits work your capital is pretty consistent, whether it's on or off from that standpoint but from a reserve standpoint we'll have to take that as an adoption of the new accounting standard impact when it actually comes on.

Do you thing that would be a reserve for the cards would be front end loaded into Q1 or would it be spread out over 2010 or what would that look like?

Probably have to go back and be certain here but I think the way the final rules came out it would be a transition adjustment or be a one-time charge.

There was talk at one point about it being spread but that's not the way it ended up.

The total off-balance sheet assets are coming back on with the cards included, are we talking about closer to $200 billion there or $400 billion?

Or how far -- how close are we to figuring out what that number is?

Right now, I would say the card business, our resolving home equity and the conduits would make up the bulk of that and I would think of that somewhere in the range of about $150 billion.

Of which, again, card is the biggest part and already in a regulatory capital.

Okay.

Thanks a lot, guys.

Okay.

We can go folks the site of Joe Morford with RBC Capital Markets.

Your line is open.

Thanks.

I was just curious if the second quarter numbers incorporate the results of the shared national credit exam and do you have any color on how that review went this year, both for B of A and just in general?

Yes, as you know, we can't really talk about the specifics of the exam result but I would tell you that everything that we experienced or were aware of is in our results for second quarter.

Okay.

Thanks so much.

We'll go next to the site of Chris Kotowski with Oppenheimer and Company.

Two questions.

One is a bit more of a nit and that is if you look on the consolidated P&L you see credit card fee income go down from $2.9 billion to $2.1 billion.

So like a 25% decrease.

But if you look through the segment reports, there's nothing that would indicate that kind of change.

And can you square that circle for me?

Yes.

The business units are on a managed basis so the securitizations would be reflected as if we have all the loans on but if you go to -- for the income statement.

If you go to the consolidated, we have GAAP reporting so what you're seeing is the losses on the securitized portfolio increase generally driving that discrepancy you see.

And then secondly, sort of more big picture question, and that is you mentioned at the outset sort of the reserve building would go on for next two quarters.

But is it a fair characterization that you're determined to have any reserve building done by the end of 2009?

And that next year one should see provision in charge-offs more or less tracking together?

Well, you'd have to be a psychic and be able to predict the economy so I couldn't do that but what we would -- if provision build continues into 2010, we would see it lessening each quarter.

So beginning next quarter and the next, we see less of a provision for reserve build, but I can't predict when it would end completely.

Okay.

Thank you.

And due to time constraints, our last question will come from from the site of Nancy Bush from NAB Research, LLC.

Your line is open.

Got it in under the wire.

We were missing you, Nancy.

Couple of questions here.

One just sort of procedural or more mundane.

Joe, could you just tell us what the ongoing new FDIC assessment will be on a quarterly basis, sort of just roughly?

Nancy, can I come back to you and give you the exact amount?

I mean, the special assessment of 760 is all in there so if you're thinking about kind of run rate, if you back that out, we would be at the right point is probably the best way to think about it.

Okay.

Great.

Secondly, this sort of goes hand in hand with Ed Najarian's question.

I'm not sure you'll be able to answer it but I need to ask it anyway.

This issue of the agreement on the back stops and whether or not there will be some price to be paid for a non-existent agreement, can you tell us when you expect or what your best expectation right now is when that issue gets resolved?

Well, I guess, Nancy, the first thing I would say is we've clearly been informed there's no supervisory concern with this thing dragging on and so that centers it on just how do we close it out.

And while I'd say we're not going to negotiate in public, I would fully expect us to reach resolution on this thing within the next 30 days.

Okay.

And if indeed there is a charge or some payment that goes with that, is it likely that that would be something that would have to be expensed or is there some reserve sitting around somewhere that that might come out of?

We would have looked at our own view of that but again, I wouldn't go into that specifically, so we would have something but I have no idea what might come back at me.

So, its hard to answer that.

And just thirdly, the loss rates in some of your master trust, card master trusts are quite high, and I'm wondering if there's anything particular about the MBNA portfolio, the old sort of legacy MBNA way of underwriting, if you're able to look back at that.

Is this an underwriting issue?

If you could just give us a little bit of color on those loss rates?

Well, I think over the course of the last several years, as we expanded beyond a lot of the affinity programs which may have been a little more of the center of the legacy MBNA, you got a more of a borrower than a transactor and that obviously in this kind of downturn has led to where we are.

So the trust itself, think of that as reasonably blended compared to our total portfolio and that's generally across the total portfolio what we experienced.

All right.

Great.

Thank you very much.

Thank you.

Thanks very much, everyone.

And this concludes today's teleconference.

Have a great day.

You may disconnect at any time.