Bank of America - Q3 2023

Transcript

Operator (participant)

Good day, everyone, and welcome to the Bank of America earnings announcement. At this time, all participants are in a listen-only mode. Later, you will have the opportunity to ask questions during the question-and-answer session. Please note, today's call will be recorded, and we will be standing by if you should need any assistance. It is now my pleasure to turn today's conference over to Lee McEntire, Investor Relations. Please go ahead.

Lee McEntire (SVP, Head of Investor Relations)

Good morning. Thank you. Welcome, and thank you for joining the call to review the Q3 results. As usual, our earnings release documents are available on the Investor Relations section of the BankofAmerica.com website, and it includes the earnings presentation that we will be referring to during the call. I trust everybody's had a chance to review the documents. I'm going to first turn the call over to our CEO, Brian Moynihan, for some opening comments before Alastair Borthwick, our CFO, discusses the details of the quarter. Before we do that, let me just remind you that we may make forward-looking statements and refer to some non-GAAP financial measures during the call. Forward-looking statements are based on management's current expectations and assumptions that are subject to risks and uncertainties.

Factors that may cause our actual results to materially differ from expectations are detailed in our earnings materials, as well as the SEC filings available on our website. Information about non-GAAP financial measures, including reconciliations to US GAAP, can also be found in our earnings materials that are on the website. With that, Brian, I'll turn the call over to you.

Brian Moynihan (Chairman and CEO)

Good morning, everyone, and thank you for joining us. As usual, we're starting on slide two. Our Q3 here at Bank of America was another strong quarter as we delivered $7.8 billion in net income. That is a 10% growth over the year-ago Q3. For the first 9 months of the year, we have earned $23.4 billion, an increase of 15% over 2022. We grew clients and accounts organically and at a strong pace across all our businesses. Our operating leverage was about flat. We improved our Common Equity Tier 1 ratio by nearly 30 basis points in the quarter to a level of 11.9%, against a current minimum of 9.5%. We saw an increase in our deposits, and we maintained our strong pricing discipline.

We continue to maintain $859 billion in global liquidity sources. We've also delivered a good return for you, our shareholders, with a return on tangible common equity of over 15% and a 1% return on assets. Just a quick note on what we see in the economy. Our team of economists predicts a soft landing with a trough in the middle of next year. We see that in our customer data, our 37 million checking customers, we see their spending slowing down. You can see that on slide 34. The Q3 was up about 4% over last year's Q3. Earlier this year, that would have been more of a 10% increase year over year, and for the entire year, 2022, it increased 10%, round numbers over 21.

This 4% level is consistent with the spending we saw in the pre-pandemic period, from 2016 to 2019. That is consistent with a low inflation, lower growth economy. As we move into October, the spending is holding at that 4% level, so growing, but growing at a basis more consistent with a low growth, low inflation economy. With that, let me turn to slide three. We provide various highlights, and Alastair is going to cover a lot of this. Our team continues to focus on driving organic growth, driving digital progress and operational excellence, which keeps us focused on operating leverage. A few words on organic growth as we flip to slide four. Every business segment had organic growth. In Consumer, in Q3, we opened more than 200,000 net new checking accounts this quarter alone.

We also opened another 1 million credit card accounts. We have 10% more investment accounts this year, Q3 end, than we did last year. In small business, we've seen 35 straight quarters of net new checking account growth. We've also seen good small business loan growth, and our loans are up 14% from last year. That was, in this quarter, our small business teammates extended $2.8 billion in credit to small businesses in America alone. In Global Wealth, we added nearly 7,000 net new relationships to the Merrill Private Bank franchises, and our advisors opened more than 35,000 new bank accounts for the third consecutive quarter, fulfilling both investing and banking needs for those clients. We also increased our number of advisors.

In the past year, across our consumer wealth spectrum, in GWIM and in consumer investments, they have combined to gather $87 billion in total net flows. Our Global Banking team, we added clients and increased the number of products per relationship. Year to date, we've added 1,900 new commercial and business banking clients. That is more than we added in the full year last year. Even while activity is low, the investment banking team continues to hold its number 3 position. In the Global Markets, we continue to see performance establish new records for our firm. I'm going to cover that in a little more detail in a moment. As you can move to slide five, you can see the digital adoption, engagement, and volumes continue to increase. We lead the industry in digital banking and continue to provide the best-in-class disclosures.

You can find those disclosures by line of business in the appendix on slides 26, 29, and 31. We also continue to receive top accolades from third parties around these capabilities. Most important, these capabilities are valued by our clients and customers and allow us to grow with great expense leverage. Let me give you a few examples. Our consumer and Merrill clients logged into our consumer banking app a record 3.2 billion times this quarter. Even at this scale and stage of maturity of this, of this operation, logins are up double digits from the year prior. Customer use of Erica continued to beat our expectations, with almost 19 million users, up 16% in the past 12 months.

Cash Pro app sign-ins with our business clients are up more than 40%, and we recently added the Erica functionality to CashPro to help corporate clients benefit from that artificial intelligence. Likewise, Zelle usage continues to grow. Zelle transaction levels are up more than 25% from last year, and Zelle is becoming a meaningful way our customers move money. In fact, customers now send money with Zelle at twice the rate they write checks. We're nearing a period where the Zelle transactions sent will exceed the combination of checks written and ATM withdrawal transactions. As you move across the lines of business on this slide, the story is the same. All these capabilities help us deliver faster, safer, and more efficiently, and all of it gets strong customer client feedback.

When you put that together, that helps us drive operating leverage, and you can see it on slide six. We have a strong record of driving operating leverage in our company. We drove operating leverage every quarter for nearly 5 years before the pandemic, and then again, more recently, we've had an 8-quarter streak leading into this quarter. We acknowledged to you this last quarter that operating leverage is gonna be tough for a few quarters as we navigate through the trough of net interest income. But as you can see on slide six, we managed to grow revenue year-over-year faster than expense in dollar terms this quarter, even though the percentage change was basically flat. Now in January, we told you we'd manage our head count down to help make sure we got our expenses in line.

Over the course of 2023, we've seen, moving from 2022's great resignation to a current level of a record low attrition in our company. All that meant the team had to work harder to manage that head count down, and they did it. Our head count is now down over 7,000 FTEs from a peak in January, even with the addition of 2,500 college grads this fall. As a result, you've seen expense decline from $16.2 billion in Q1 to $16 billion in Q2, to $15.8 billion this quarter. By the way, we've done this without special charges or large layoffs. Expense will decline again in the Q4, excluding any FDIC special assessment, of course. We expect to report $15.6 billion in expenses in Q4.

Now, interestingly, the debt is up only 1%-around 1% from Q4 of last year. This is stronger expense guidance than we thought we could do earlier in the year and sets us up nicely for next year. Shifting gears, let's focus on the balance sheet. Slide 7 shows the breakout of deposit trends on a weekly basis-ending basis across the Q3. We gave you this chart last quarter also. In the upper left-hand, you can see the trend of total deposits. We ended Q3 at $1.88 trillion, up from Q2 and better than industry results. What you should also note is the cost of these deposits. Our team has rewarded customers with higher rates for their investment-oriented cash, reinitiated deposit growth and grown share, all with superior mix and cost.

You will note that we're now paying 155 basis points all in for deposits, which is up 31 basis points from last quarter. We ask that you remember two things when you think about the deposits. The rate remains low relative to many because of the transactional nature of our deposit relationships, with $565 billion in non-interest-bearing deposits. And you can see in the upper right alone, in low interest and no interest checking, there's $504 billion in consumer. Secondly, remember the importance of the spread against the quarter's average Fed funds rate. This position is very advantaged compared to past cycles because the transactional accounts in the current cycle are a much higher mix of Bank of America's deposits.

I would also add, add that while we've maintained discipline in deposit pricing, we paid competitive rates to customers with excess cash, seeing higher yields across all the businesses. If rates fall, those particular products will see their rates come down also. Dropping into the business trends, in consumer, if you look at the top right chart, you saw a $22 billion decline. Note the difference in the movement through the quarter between the balance of low to no interest checking accounts and higher-yielding non-checking accounts. You can also see the low levels of our more rate-sensitive balances, consumer investments, and CD balances broken out. In total, we have $982 billion in consumer deposits. In consumer alone, this is $250 billion more than we had pre-pandemic.

The total rate paid on consumer deposits in the quarter is 34 basis points. This remains very low, driven by the high percentage of high-quality transactional accounts. Most of the quarter's rate increase is concentrated in CDs and consumer investment deposits, which are about 13% of the deposits. Turning to Wealth Management, balances were flat. We saw a slowing in the previous quarterly trend of clients moving money from lower-yielding sweep accounts into higher-yielding preferred deposits and off-balance sheet products. Sweep balances were down by $7 billion and were replaced by new account generation and deepening. At the bottom right, note the Global Banking deposits grew $2 billion and have hovered around $500 billion the past 6 quarters. These are generally the transaction deposits of our commercial customers use to manage their cash flows.

Non-interest-bearing deposits were 37% of deposits at the end of the quarter. Sticking with the balance sheet, but moving to capital, let me give you a few thoughts on the proposed capital rules. As you are well aware, our banking industry in the United States is the most highly capitalized and most profitable banking group in the world. It's a source of strength for our country and its economy. The annual stress test over now, over a dozen years old, using ever increasingly harsher test scenarios, have proven that capital is sufficient. Banks have proven to be a part of the solution during the more recent COVID pandemic and the banking disruption in March this year. If we add to our capital, it will reduce our lending capacity to American business consumers, and those trade-offs are being debated.

But as far as the proposed rules are concerned, there are many parts of the rules that our industry doesn't agree with because of double counts or increased trading and market risk. And we're talking to those proposals and working, and we're hopeful they'll change. But in any event, they may not. And if they don't, how will they affect us? If you go to slide eight, you can show the expected impact as we interpret those proposed rules. This assumes that they're proposed today without any changes. The proposed rules would inflate our risk-weighted assets by about 20%. So if I apply the inflation against this quarter's RWA of $1.63 trillion, that means if nothing else changed in the rules, we'd end up with about $320 billion more risk-weighted assets.

The biggest increase in RWA would be a couple of hundred billion dollars in operational RWA. The next biggest category would be driven by a fourfold increase in the RWA against non-publicly traded equity exposures. In our case, that really is mostly about the tax-advantaged investments in solar and wind. Looking at the capital to be held against the inflated RWA on the right side of the slide, I'd remind you today that our minimum capital requirement is to hold 9.5% in Common Equity Tier 1. But based on our GSIB charges that are going to come into effect on January 1, 2024, we move to 10%, so I'm going to use that as the requirement. Holding 10% today means $163 billion. That we finished the Q3 with $194 billion.

So today, we have more than $30 billion excess capital. Now, let's assume the proposed changes go through in full. Those proposed changes are phased in from the middle of 2025 to 2028 under the current proposal. When those are fully phased in, as we used to call Basel, fully phased in, if you remember, we would have a need for $195 billion of total capital. Now, if you look on the upper right-hand side of the page, you'll see that we're today, we're $194 billion. So we hold the required capital today, and of course, we'd have to build a buffer to that throughout the implementation period. But if you look at the bottom of the page, you can see just in the last 9 quarters, the kind of capital generation this company has.

Once we understand the final rules, we'll, of course, have a chance to optimize our balance sheet and appropriately price assets to improve the return on tangible common equity. Now, before I turn it over to Alastair, I just wanted to highlight one of the businesses that we've talked about over the many years. That's our Global Markets business. Global Markets represents 17% of the company's year-to-date earnings and is one of the top capital markets platforms in the world. It's one of a handful of firms that can do what it's do, providing advice and execution in every major market around the world. Jim DeMare and the team who run the business asked us for an additional investment around four years ago, and they've grown this business with an intensity that clients have appreciated and rewarded us with more of the business.

This has produced strong revenue growth. We've grown the balance sheet here, but have done it efficiently. That's allowed us to grow sales and trading revenue over the past 12 months consistently, now stands 32% higher than the average of the 5 years leading into the pandemic in the investment in the business. And through effective cost management, we also generate 11%-12% returns on capital in this business. This exceeds our cost of capital, even as we continue to allocate more capital to the business. Returns are even larger if you combine it with the Global Banking business that many show the businesses combined, and take- because our corporate clients also take advantage of these industry-leading business, capabilities. For that, let me turn over the call to Alastair to walk through the quarters. Alastair?

Alastair Borthwick (CFO)

Thanks, Brian. And on slide 10, we present the summary income statement. I'm not going to spend a lot of time here because Brian touched on this and the highlights that we show on slide three. For the quarter, we generated $7.8 billion in net income, resulting in $0.90 per diluted share. Both of those are up double digits from the Q3 of last year. The year-over-year revenue growth of 3% was led by improvement in net interest income, coupled with a strong 8% increase in sales and trading results, and that excludes DVA, and a 4% increase in investment and brokerage revenue, driven by our wealth management businesses.

Expense for the quarter of $15.8 billion included good discipline from our team, which allowed us to reduce costs from the Q2, even as we continue our planned investments for marketing, technology, and physical presence build-outs, including financial center openings and renovations. Asset quality remains stellar, and provision expense for the quarter was $1.2 billion. That consisted of $931 million of net charge-offs and $303 million of reserve build. The provision expense reflects the continued trend in charge-offs toward pre-pandemic levels and remains below historical levels. Our charge-off rate was 35 basis points. That's 2 basis points higher than the Q2, and still below the 39 basis points we saw in the Q4 of 2019. And as a reminder, that 2019 was a multi-decade low.

30-day delinquencies also remained below their Q4 2019 level. Lastly, our tax rate this quarter was 4%, driven mostly by higher than expected volume of investment tax credit, or ITC deals, for the rest of the year. We can expect other income in Q4 will reflect seasonally higher renewables investment losses when these projects get placed into service. Okay, let's turn to the balance sheet. That's on slide 11, and you can see it ended the quarter at $3.2 trillion, up $31 billion from the Q2. Not a lot to note here. The driver of the increase was a $34 billion increase in available-for-sale securities. With cash levels so high, we chose to reduce the cash and just put some of the money into short-term T-bills this quarter, and those earn essentially the same rate as cash.

Our cash remains high at $352 billion. In addition to the cash level change, we saw another $11 billion decline in hold-to-maturity securities as those securities matured and paid down. As Brian noted, global excess liquidity sources remain strong at $859 billion. That's down very modestly from the Q2 and still remains approximately $280 billion above our pre-pandemic Q4 2019 level. Shareholders' equity increased $4 billion from the Q2, as earnings were only partially offset by capital distributed to shareholders. During the quarter, we paid out $1.9 billion in common dividends, and we bought back $1 billion in shares to offset our employee awards.

AOCI was $1 billion lower, reflecting both a modest decline in the value of AFS securities, modestly impacting CET1, as well as a small change in cash flow hedges, which doesn't impact the regulatory capital. Tangible book value per share is up 12% year-over-year. Turning to regulatory capital, our CET1 level improved to $194 billion from June 30, and our CET1 ratio improved 30 basis points to 11.9%. It's now well above our current 9.5% requirement, as Brian noted. Risk-weighted assets declined modestly as loans and Global Markets RWA both moved lower. Our supplemental leverage ratio was 6.2% versus a minimum requirement of 5%, which leaves capacity for balance sheet growth, and our TLAC ratio remains well above our requirements.

LCR ratios remain well above minimums for BAC metrics and stronger at the bank level. Let's now focus on loans by looking at average balances on slide 12. Loan growth slowed this quarter as a decline in demand for commercial borrowing more than offset our credit card growth. So we saw that lower commercial demand in lower revolver utilization among higher funding costs. Commercial balances were also impacted by term loan repayments due to borrowers accessing other capital market solutions. Focusing for a moment on average deposits and using slide 13. Given Brian's earlier comments, I just note the comparisons. Relative to pre-pandemic Q4 2019, average deposits are up 33%. Consumer is up 36%, with consumer checking up 45%. You can see the other segment comparisons on the page.

Turning to slide 14, let's extend the conversation we've been having over the course of the past couple quarters around management of our excess liquidity. This slide serves as a reminder of the size of our high-quality deposit book, the magnitude of deposits we have in excess of those needed to fund loans, and the way we've extracted the value of that excess to deliver value back to our shareholders. The excess of deposits needed to fund loans increased from $420 billion pre-pandemic to a peak of $1.1 trillion in the fall of 2021. As you can see, it remains high at $835 billion today. That $1.1 trillion of excess liquidity has always included a balanced mix of cash, available-for-sale securities and securities we hold to maturity.

In late 2020 and into 2021, we concluded that additional stimulus was going to remain in client accounts for an extended period, and we increased the hold-to-maturity securities portion so we could lock in value from those deposits. We made these investments given the core nature of our customers' deposits. Note the split of the shorter-term investments in cash and available-for-sale securities, and then the longer-term hold-to-maturity securities. I just draw your attention to just how much cash we have above the actual level we need to run the company. On the available-for-sale, we would just note the duration is less than six months, as it's mostly all short-term treasuries.

The combination of the cash and available-for-sale securities represents about 47% of the total noted on this page in the Q3 of 2023 to give us the balance we're looking for. If we look at the hold-to-maturity book, it had grown from $190 billion pre-pandemic, peaking 2 years ago and now falling to just over $600 billion currently. That $600 billion consists of about $122 billion in treasuries. Those will mature in a little more than 6 years, and about $474 billion in mortgage-backed securities and a few billion other. The hold-to-maturity securities peaked at $683 billion and were now down $80 billion from the peak and $11 billion in the last quarter.

That $80 billion decline from peak was all driven by the reduction of mortgages from $555 billion-$474 billion. With less loan funding needs over the past several quarters, the proceeds from security paydowns have been deployed into higher-yielding cash, and this mix shift has been happening at about a 300 basis point spread benefit for these assets. Given the increased cash rates, the combined cash and security yield has risen now to more than 3%. It's up more than 200 basis points since the peak size of the portfolio in the Q3 of 2021, and it's risen faster than the rate paid on deposits. In fact, today it's 178 basis points above what we pay for deposits. And remember also, we have $1 trillion of loans that are largely in floating rate in addition.

From a valuation perspective, we did experience a decline in the valuation of the hold-to-maturity book this quarter, and that's in the context of mortgage rates reaching a two-decade high. Comparing the valuation change to the year-ago period, it worsened $15 billion, and over that same time period, we grew regulatory capital by $19 billion and hold global liquidity sources in excess of $850 billion. Importantly, as we move to slide 15, I'll make one final comment here, which is the improved NII over this investment period. The net interest income, excluding Global Markets, which we disclose each quarter, troughed in Q3 2020 at $9.1 billion. That compares to $13.9 billion in the Q3 of 2023, or $4.7 billion higher every quarter on a quarterly basis.

And that gives a sense of the entire balance sheet working together. Okay, let's now turn our focus to NII performance over the past quarter, and we'll talk about the path forward, and I'm gonna use slide 15 for that. On last quarter's call, we guided to expect Q3 NII to be about $14.2 billion-$14.3 billion on an FTE basis. Our Q3 performance turned out to be better than our guidance, and on an FTE basis, NII was $14.5 billion this quarter. We expect Q4 will be around $14 billion fully taxable equivalent, and that increases our full-year guidance for NII in 2023 versus 2022 to 9% growth for the year.

We believe NII will hover around this expected Q4, $14 billion level, plus or minus in the first half of next year, and then we anticipate modest growth in the second half of 2024. By the time we get to the Q4 of 2024, we believe we can see NII up low single digits compared to the Q4 of 2023. The good news is we believe NII will likely trough around the Q4 level of $14 billion and begin to grow again in the middle of next year. I'd note a few caveats around that forward view I just provided. It includes an assumption that interest rates in the forward curve materialize, and it includes rate cuts for the second half of 2024.

It also includes an expectation of modest loan and deposit growth as we move into the second half of 2024. Focusing again on this quarter, $14.5 billion NII was an increase of nearly $700 million from the Q3 of 2022 or 4%, while our net interest yield improved five basis points to 2.11%. The year-over-year improvement was driven by higher interest rates and partially offset by lower deposit balances. On a linked quarter comparison, NII improved $239 million from Q2. That comes from the benefit of an extra day of interest, a rate hike and higher Global Markets NII, partially offset by increased deposit pricing, and the net interest yield improved five basis points.

Turning to asset sensitivity and focused on a forward yield curve basis, the +100 basis point parallel shift at September 30th was $3.1 billion of expected NII benefit over the next 12 months from our banking book, and that expects or that assumes no expected change in balance sheet levels or mix relative to our baseline forecast, and 95% of the sensitivity is driven by short rates. The 100 basis point down rate scenario was $3.3 billion. Okay, let's turn to expense, and we'll use slide 16 for the discussion. Previously highlighted that we guided you to a trend of sequential declines in our expense each quarter this year, and we achieved that in Q3 with our expense down $200 million to $15.8 billion.

Additionally, we expect the Q4 to go down another $200 million to $15.6 billion, excluding any FDIC special assessment. That would mean our Q4 expense of $15.6 billion, compared to the Q4 of 2022, would be up by only $100 million or less than 1%. And we're proud of that work by the team, especially considering our regular FDIC insurance expense alone increased by $125 million quarterly starting in the Q1 of this year. So without that, we would be flat year-over-year in Q4. The decline this quarter from the second was driven by the reduction in litigation expense and lower headcount, offset somewhat by investments and inflationary costs.

Our headcount is down nearly 2,800 from the Q2 to 213,000, and that includes the addition of 2,500 or so full-time campus hires we brought into the company. So that's good work by the team after we peaked at 218,000 in January month-end. You can see the movement here across the past year at the bottom left of the slide. As we look forward to next quarter, we'd add $1.9 billion of expense for the proposed notice of special assessment from the FDIC as a possibility. Absent that, we'd expect our Q4 $15.6 billion expense target to more fully benefit from the Q3 headcount reductions, and that will allow expense to continue the decline experienced throughout the year so far.

All of that is gonna set us up well for next year.... Let's now turn to credit, and we'll turn to slide 17. Net charge-offs of $931 million increased $62 million from the Q2. The increase is driven by credit card losses as higher late-stage delinquencies flow through to charge-offs. For context, the credit card net charge-off rate rose 12 basis points to 2.72 in Q3, and it remains below the 3.03 pre-pandemic rate in the Q4 of 2019. Provision expense was $1.2 billion in Q3, and that included a $303 million reserve build. It reflects a macroeconomic outlook that, on a weighted basis, continues to include an unemployment rate that rises to north of 5% during 2024.

On slide 18, we highlight the credit quality metrics for both our consumer and our commercial portfolios. On consumer, we just note that we continue to see the asset quality metrics come off the bottom, and for the most part, they remain below historical averages. 30- and 90-day consumer delinquencies still remain below the Q4 of 2019, as an example. Commercial net charge-offs declined from the Q2, driven mostly by a reduction in office write-downs. As a reminder, our CRE credit exposure represents 7% of total loans, and that includes office exposure, which represents less than 2% of our loans. We've been very intentional around client selection and portfolio concentration and deal structure over many years, and that's helped us to mitigate risk in this portfolio.

We continue to believe that the portfolio is well-positioned and adequately reserved against the current conditions. In the appendix, we've included a current view of our Commercial Real Estate and office portfolio stats we provided last quarter. We've also included the historical perspective of our loan book de-risking and our net charge-offs, and you can see all of those on slides 36, 37, 38, and 39. Okay, let's move on to the various lines of business and their results. I'm going to start on slide 19 with Consumer Banking. For the quarter, Consumer earned $2.9 billion on good organic revenue growth and delivered its 10th consecutive quarter of operating leverage while we continued to invest for the future. Note that the top-line revenue grew 6%, while expense rose 3%.

Reported earnings declined 7% year-over-year, given credit costs continue to return to pre-pandemic level. We believe this understates the underlying success of the business in driving revenue and managing costs, because PPNR grew 9% year-over-year. Much of this success is driven by the pace of organic growth of checking and card accounts, as well as investment accounts and balances, as Brian noted earlier. Expense reflects the continued investments by the business for their future growth. Moving to wealth management on slide 20, we produced good results, and we earned a little more than $1 billion. These results are down from last year due to a decline in NII from higher deposit costs, which more than offset higher fees from asset management.

While lower this quarter, NII of $1.8 billion derives from a world-class banking offering, and it provides good balance in our revenue stream and a competitive advantage in the business for us. As Brian noted, both Merrill and the Private Bank continued to see strong organic growth, and they produced solid assets under management flows of $44 billion since the Q3 of last year, reflecting good mix of new client money, as well as our existing clients putting their money to work. Expense reflects continued investments in the business as we add financial advisors and capabilities from technology investments. On slide 21, you see the Global Banking results. This business produced very strong results, with earnings of $2.6 billion, driven by 11% year-over-year growth in revenue to $6.2 billion. Coupled with good expense management, the business has produced solid operating leverage.

Our GTS, or Global Treasury Services business, has been robust. We've also seen a steady volume of solar and wind investment projects this quarter, and our investment banking business is performing well in a sluggish environment. Year-over-year revenue growth also benefited from the absence of marks taken on leveraged loans in the prior year-ago period. The company's overall investment banking fees were $1.2 billion in Q3, growing modestly over the prior year, despite a pool that was down nearly 20%. We held on to number 3 position given our performance. Provision expense reflected reserve release of $139 million, as certain troubled industries and credits outside of commercial real estate continue to have improved outlooks. Expense increased 6% year-over-year, reflecting our continued investments in this business.

Switching to Global Markets on slide 22, the team had another strong quarter, with earnings growing to $1.3 billion, driven by revenue growth of 10%, and I'm referring to results excluding DVA, as we normally do. The continued themes of inflation, geopolitical tensions, and central banks changing monetary policies around the globe have continued to impact both bond and equity markets. And as a result, it was a quarter where we saw strong performance in our FICC trading businesses, as well as a record Q3 in equities. Focusing on sales and trading, ex-DVA, revenue improved 8% year-over-year to $4.4 billion. FICC improved 6% and equities improved 10% compared to the Q3 of last year. And at $1.7 billion, that's a record Q3 for our equities teammates.

Year-over-year expense increased 7%, primarily driven by investments for people and technology. Finally, on slide 13, all other shows a profit of $89 million. So revenue improved from the Q2, driven by the absence of prior period debt security sale losses, and available-for-sale securities, and partially offset by higher operating losses on tax credit investments in wind, solar, and affordable housing. As I mentioned earlier, our effective tax rate in the quarter was 4%, and that reflects a higher than expected volume of investment tax credits, in which the value of the deals are recognized upfront. We also had a small discrete benefit to tax expense from a state tax law change. Excluding renewable investments and any other discrete tax benefits, our tax rate would have been 25%.

As we wrap up 2023, we expect our full year tax rate, excluding discrete and special items such as the FDIC special assessment, we expect that full year tax rate should end up in the 9%-10% range. To summarize, we grew our earnings double-digit year-over-year. We reported NII that was above our expectations, and we increased our full year expectations. We've managed costs aligned with our guidance and brought expenses down in every quarter so far this year, and we expect to do that again in the Q4. We earned more than 15% return on tangible common equity. We returned $2.9 billion in capital back to shareholders, including a 9% dividend increase, and we built 30 basis points of CET1, positioning us well for the proposed capital rules.

All in all, it was a strong quarter. It was one where our teams executed well against responsible growth. With that, David, I think we'll open it up for the Q&A session.

Operator (participant)

At this time, if you'd like to ask a question, please press the star and one keys on your telephone keypad. Keep in mind, you may remove yourself from the question queue at any time by pressing the pound key. We will take our first question from Gerard Cassidy with RBC. Please go ahead. Your line is open.

Gerard Cassidy (Managing Director, Head of U.S. Bank Equity Strategy)

Thank you. Hi, Brian. Hi, Alastair.

Alastair Borthwick (CFO)

Hi there.

Brian Moynihan (Chairman and CEO)

Hey, Gerard.

Gerard Cassidy (Managing Director, Head of U.S. Bank Equity Strategy)

Brian, can you come back to your thoughts? You were talking about the consumer spending holding at 4% right now, obviously down from the very strong levels of a year, two years ago. When you look out and you mentioned how you guys are thinking the economy troughs in the middle of next year, do you think you could hold that 4% consumer spend? Do you think your consumers will hold that 4% spending number, or could it actually deteriorate from here?

Brian Moynihan (Chairman and CEO)

I think a couple of things, Gerard. One is, there's obviously external events which could change the situation in the globe and, you know, dramatically and so. But given just a pathway that that kind of event doesn't take place, you'd think that the rate they're spending out now is consistent with a lower inflation. So embedded in our team's, Candace Browning and planning team's economic projections is a return to inflation, to the 2% target at the end of 2025. The rate structure it comes down beginning in the middle of next year, but still stays around 4% at the end of 2025. And so given that the economy, the inflation's coming down, the economy will still be growing then and getting back towards trend growth, I think it would hold steady.

And so it's been pretty steady the month of August into September into October at this 4, 4.5, 5% level. And that's kind of just, you know, people get paid more, they spend a little bit more, pricing goes up, and then you have the ebbs and flows within it, what they spend on. And right now, you've kind of seen all the adjustments that came through the pandemic into the last couple of years, sort of adjust out of the system. What I mean by that is you had a lot of goods purchased, then you had a lot of travel, and you had a lot of return to office spending. We can track that, you know, people buying stuff.

All that's kind of leveled out the system, including a drop in fuel prices and an increase, and basically it's relatively, bouncing around about the same, and they're spending about the same amount of money on, gas that they spent last year. So all that being said, in the big aggregate numbers, I think, yes, it could keep bumping along at that level, which is consistent with low inflation, low growth economy, and effectively shows the consumer has been brought more in line with the scenario of the Fed reaching their target. That, that's what we see. Now, we'll take some time for all that to work through the system, and, you know, retail sales numbers seems to be stronger today, but that, that all shake through. But this is what they're doing at the moment.

Gerard Cassidy (Managing Director, Head of U.S. Bank Equity Strategy)

Very good. And then as a follow-up question, you guys give us good detail in slide 8 about the potential changes coming from Basel III Endgame, and you show us obviously the organic capital generation. Can you share with us possibly some of the mitigation strategies you might use? And specifically, if you could touch upon these changes for the equity investments, particularly, you know, in the alternative energy space. I guess they're going up from 100% RWAs to 400%. Would that, you know, change your thinking in that line of business as we go forward? Should they have to stay in the final rules?

Brian Moynihan (Chairman and CEO)

So I think, number one, I think the first thing is, you know, there'll be at the end of November, the comments are due. There'll be comments by our company, by all the other companies, by industry participants, and then, the staff at the Fed will have to sort through all that and think to what they all mean. And there'll be very rigorous points about our views of the wisdom of the changes, the need of the changes, the balance of the changes, the double counting, all the things that you've heard much about. That being said, it is a little puzzling that you see some of the RWA increases for mortgage loans or for these types of investments in the environmental and housing and other spaces, which is sort of counter to the policy that, you know, we want to do it.

Now, what would happen is we'd have to adjust the pricing, and it would become more expensive. It's been a great business for us. We continue to drive it, but we'd ultimately, it'd have to go through the market if you have the equity cost go up by a fourfold increase to get the returns. And so think about a pricing model, just increase the amount of, you know, equity we have to dedicate, therefore, we have to get returns on that. And so that would happen.

It just seems a little counterintuitive that people would be doing that on a set of rules that basically, after the financial crisis, Dodd-Frank put in a set of rules and said, "Here's how you count the RWA," without much evidence that this is an issue for companies, because the Volcker Rule and all that other stuff that are having issues with write downs or changes here. And so the idea of going up four times seems odd to us from a public policy standpoint, and also absent any evidence that this is an issue for the banking system.

Gerard Cassidy (Managing Director, Head of U.S. Bank Equity Strategy)

Very good. Thank you very much, Brian.

Operator (participant)

We'll take our next question from Jim Mitchell with Seaport Global. Please go ahead. Your line is open.

Jim Mitchell (Senior Equity Analyst)

Okay, great. Good morning. Alastair, at a conference a month ago, you noted that, you know, if the Fed is done, you think deposit pricing is close to its peak, and I think you kind of talked us through that a little bit today. Some of your peers have been more fearful of a potential future material repricing and consumer savings, for example, from greater competition or further outflows. So, and to be fair, you, you know, they've worried about that for a while, and you've been more right. But, can you just kind of discuss your thoughts on that and perhaps the outlook on deposit pricing in general?

Alastair Borthwick (CFO)

Yeah. I mean, Jim, one of the things that I think gives us some confidence around NII troughing and then growing in the back half of next year is, you know, if you think we've seen the last Fed hike, or you believe that the last Fed hike is, you know, a month from now or two months from now, then at some point, deposit pricing is going to stop going up. And there'll be a natural lag to that. That's pretty normal. And then what you see, if you look forward into the forward curve, is we've actually got Fed cuts, three of them in the forward curve for next year. So yes, we anticipate there'll be some lag.

I don't think we're any different than anyone else in that regard, but we're just pointing out that as we get towards peak rates, we're getting closer now, so we can begin to see the end of that in terms of, you know, the later innings at this point. And the other thing, just... We always have to remind everyone of this, is the deposits that we have are very relationship-based. They're a lot of them are core operating deposits, where we've got the checking. They're thinking about the way we serve them in terms of digital. We've got Preferred Rewards program. And then on the commercial side, very similar. We've got a lot of operating deposits all around the world, and they're using our world-class CashPro product. So there's a lot of relationship value here as well that we need to take into account.

But fundamentally, we're just making a judgment that we're getting towards the top of the rate cycle here for Fed funds, and then deposit pricing will sort out in the quarter or two following.

Jim Mitchell (Senior Equity Analyst)

All right. That's fair. Maybe given the thoughts that there's 3 rate cuts in the forward curve and you are asset sensitive, but yet you still expect growth in the back half or improving growth in NII in the back half, what is that just sort of the lagged effect there, too, or is there something else going on in terms of rate cuts and the impact?

Alastair Borthwick (CFO)

Yeah, I think the other things that we've got going on, especially as we get into the back half of the year, consumer balances are going to find a floor at some point. They, again, are in the late innings of returning to sort of more normal pre-pandemic balances per account. So they're going to find a floor, and at that point, they're going to start growing in the same way that wealth has found a floor and in the same way that Global Banking found a floor a while ago and is now beginning to grow. So we have a point of view that the consumer side is going to find a floor, so that's one. Two is, you know, at that point, you're poised for deposit growth, but we're also going to see loan growth through the course of the year.

It's been slower this quarter, but at some point, you return to a more normal economy. As Brian's pointed out, we're going to see the loan growth, and so we're thinking that's going to start to evidence itself in the back half. And then the final thing I'd just say is, we have securities reinvestment every month, and that's going to support and grow NII, and I think it gives us a sense that we've got a more durable NII stream underneath.

Jim Mitchell (Senior Equity Analyst)

Great. That's all very helpful. Thanks.

Operator (participant)

We'll take our next question from Erika Najarian with UBS. Please go ahead. Your line is open.

Erika Najarian (Managing Director, Equity Research Analyst, Large-Cap Banks, and Consumer Finance)

Hi, good morning. I have my first question is sort of, you know, two-pronged on the balance sheet. You know, Alastair, if you could tell us sort of how much in cash flow you forecast your HTM book will have in 2024, you know, as you think about the moving pieces underneath your NII outlook? And for Brian, you know, clearly, this hold-to-maturity portfolio has been a thorn in the side of the stock. And so, no matter what we say to the investment community, this stock hasn't quite caught up.

I'm wondering, as you think about the statistics that you share with us every quarter, like net new checking accounts, you know, maybe give us a little more statistics in terms of, you know, the strength of that growth and the strength of that retention? Because I think that, you know, no matter what sort of, you know, print that you have on total deposits at the end of the quarter, there's always sort of pushback so long as the market is not yet confident that we've hit peak rates. So that's sort of a two-part first question.

Alastair Borthwick (CFO)

All right. So I'll answer the first part, Erika. I think if you look back through the course of the, you know, last couple of years, that portfolio, you know, paydowns in terms of maturities or, or paydowns, it's sort of averaging $10 billion a quarter. So I think you could probably use that as a good starting point for the reinvestment horizon in 2024. That's, that's what I would use. And then I'll let Brian answer the second part of your question.

Brian Moynihan (Chairman and CEO)

So, you know, Erika, we drive a, you know, organic growth machine based on a responsible set across all the company, all the different operating businesses. So as you've noted, if you look at, you know, what's driving our deposit base to be larger than the industry, i.e., outperforming the industry, is if you think from, you know, everybody compares against 2019 to now, we're up $250 billion in consumer deposit loans. We also are up probably 10% in checking accounts, net checking accounts. Those are 92% core. The attrition rate and where all the deposit balances are in the preferred part of that segment is 99%... It's the retention rate is 99% plus. Long-term customers, the Preferred Rewards program drives a basis.

On cards, we're now getting the balances back up to where they were pre-pandemic, with even better credit quality than we had then. We got, you know, home equities have hit a trough and are starting to work their way out. Auto loans are starting to produce a lot. They will continue to produce a lot, you know, the market's not real strong, but we continue to produce $several billion a quarter. So all the organic growth engines in the consumer business are very strong. When you go to the wealth management, we're now producing net household growth at a faster rate than we produced in the prior years. If you go to the commercial banking businesses in the US, we noted that we produced more customers this year.

That deposit base, those in the business banking and middle-market segments, those come with a big deposit franchise, and you see that those deposits have actually been stable and growing for the last, you have 6 months. So the organic growth engine is in fine shape and just powers through all this and is the strength of the $3 trillion-plus balance sheet, and in fact, is the reason that we have $1 trillion or, you know, $900 billion on a given day that we have to put to work, because you're just having this great engine go on. And so whether it's investment accounts and consumer, checking accounts and consumer, cards and consumer, you know, home equity, all that has grown organically, dramatically over the last, you know, 4, 5, 10 years.

Frankly, the loan growth will continue to follow that as conditions improve. Then on the commercial side, as people go back to regular line usage, we saw it deteriorate this quarter, largely due to the, you know, demand side, and so we feel very good. Then you talked about the markets business, gave you detail there, and the investment banking team is gaining market share and actually, you know, fought to maintain relatively flat fees in a market that was down 20% or something. So we feel very good about the organic growth engine. That's what powers our company, and that delivered $7 billion plus in after-tax income for another quarter and 15% return on tangible common equity.

Erika Najarian (Managing Director, Equity Research Analyst, Large-Cap Banks, and Consumer Finance)

Got it. My second question is for you, Alastair. Do you have any economic ownership of Visa Class B shares remaining? Our understanding is, until the litigation was settled, you weren't allowed to sell it other than to other banks in the initial consortium. But I'm wondering if you've sold any economic ownership through swap or, you know, if you still have it on the books, because we haven't seen any disclosures on that recently.

Alastair Borthwick (CFO)

Well, I mean, we essentially sold and hedged our Visa B position years ago. And then in our markets business, we've financed the sale of Visa by other banks. You can think about that as a hedge thing that's just about a financing. So depending on how that all develops and what other banks choose to do, we may end up having some RWA or some liquidity that we can recycle for other clients' benefit in our markets business, but we don't have any meaningful economic stake in Visa B.

Erika Najarian (Managing Director, Equity Research Analyst, Large-Cap Banks, and Consumer Finance)

Got it. Thank you.

Operator (participant)

We'll take our next question from Mike Mayo with Wells Fargo. Please go ahead. Your line is open.

Mike Mayo (Managing Director, Senior Bank Analyst)

Hi. Do you expect the efficiency ratio, expenses to revenues, to improve from 63%, and when? I guess this is a two-part question. One is expenses. As you said, it's down every quarter this year, and you're guiding for the Q4. Slide five, the digital adoption, it's about three-fourths for your clients across the firm. So the sustainability of those digital trends to help lower expense or control expenses, given some of the headwinds, and especially given the threat of big tech and fintech, the sustainability of the digital trends and why you think you have an advantage when so many others think they have the advantage. And the second part of that question is revenues. Your NIM is a bit over 2%, went up a little quarter-over-quarter, but it was closer to 2.5%.

Going back five years, and maybe long term, it should be 3%. I'm not sure. So what, what do you think is a normalized NIM? Because that would help the efficiency ratio and the trend for expenses and ultimately the efficiency ratio. Thanks.

Brian Moynihan (Chairman and CEO)

Sure. So Mike, I think, yep, if expenses come down, revenue grows, the efficiency ratio continues to improve. You know, one of the big differences between us and, you know, other companies you can compare us to is the size of our wealth management business relative to the size of the company is large. And as you know, that's the business which we continue to work on... to make more efficient, but is, is the least efficient business in the platform. So Lindsay and Eric continue to drive the efficiency there.

So yes, we expect the efficiency ratio to continue to improve, and part of that will be as the net interest margin normalizes, we normalize the size of the balance sheet, you know, given it's grossed up for a lot of reasons through the pandemic and stuff, and you kind of fine-tune it, you'll get a little more effectiveness there. And, you know, in the past, we ran up to 230 in the-- in NIM, in the sort of a normalized, you know, sort of environments, and you'd expect us to keep moving up from there. Now, it'll be, it'll be bouncing around here as, you know, as we work through the trough in NII that we described, which is we're sort of in the middle of starting this quarter into the first half of next year.

So, you know, Mike, and as you know, it's all about managing heads, and that's, you know, last year at this time, we all talked about the great, you know, resignation or last year, last summer, and how we had to hire people, and we overhired because the issue was, could you hire fast enough to get what you needed? This year, we're able to bring that excess back out of the system and ended up kind of where we wanted to be at 212,000. As we think forward, you know, we continue to reposition people around the company who are freed up because of that digital application to other things.

So in the broad sense, our consumer business is down, you know, from 100,000 people to 60,000 people and continues to drift down as we continue to use the... You know, that's the place of the most leverage in digital across the board. You continue to get less branches, less ATMs. You can see the statistics in the chart. More customer interactions and more customers. That's a pretty good trade, and we continue to drive that, including sales and digital, that we disclose in the back of things. You're running nearly half the sales, and frankly, with improvements on the checking account opening, we can drive another round of growth there. So that's what we're going to do, continue to drive the efficiency ratio to level, and we'll see where we can get it to.

Mike Mayo (Managing Director, Senior Bank Analyst)

And then just on that big picture question, I mean, you've invested for over a decade, in your, your data and tech stack and digital engagement, and now we have AI and GenAI as a new opportunity and a threat. Why do you think, or maybe you don't, why do you think that you have an advantage versus, say, smaller banks, Fintechs or Big Tech?

Brian Moynihan (Chairman and CEO)

Well, we have an advantage in that we've been applying it for a number of years now. So effectively, Erica is a form of that and now has, you know, 17 million customers working on it, everything. And so think about that. This quarter, I think there's 170 million interactions or whatever the number is, 180 million interactions, something like that. If you think about that, Mike, in the days gone by, every one of those would have been an email, a text, or a phone call. And so it's obviously tremendously more efficient, and we're continuing to improve. We brought it out to the CashPro side, which is a commercial side, so that helps.

If you think about, you know, in the $3.8 billion we'll spend in 2024 on technology initiative spending, Aditya and the team continue to use the techniques that you read about in the paper to increase the efficiency of that development effort. And it's probably, you know, 10%-15% in the short term, building up higher and higher as people get more and more used to it. And that will allow those dollars to be stretched even further. So we think that's a near-term application that we're already doing and has high probability.

And then, you know, frankly, if you think about our capabilities, if you look, we have, you know, nearly, I don't know, 6,000-7,000 patents out there, 600 on AI already, related, machine learning-related activities, sitting in the application, filed. You know, we got a lot of inventors in this company, and so we feel good about our ability to compete against the types of people you said. But by the way, we use some of those, some of those people who might compete to actually be providers to help us do this stuff. And some of the big Big Tech companies are, you know, as you listen to them, they have—it's a business for them to sell that AI capabilities to companies like ours to make us more efficiently.

So near term, customer help, near term, employee effectiveness, near term, coding enhancements, et cetera, et cetera. But one of the things you mentioned is we have invested heavily to have the data in a tech stack ready to go, and, you know, $3 billion, 1 billion interactions this quarter, digital, show that the people are ready to use the services we provide them.

Mike Mayo (Managing Director, Senior Bank Analyst)

Okay. Thank you.

Operator (participant)

We'll take our next question from Steven Chubak with Wolfe Research. Please go ahead. Your line is open.

Steven Chubak (Managing Director)

Hey, good morning, Brian. Good morning, Alastair.

Brian Moynihan (Chairman and CEO)

Morning.

Steven Chubak (Managing Director)

So, wanted to start off with a question on expense. You cited headcount actions that should provide relief in Q4 and positive flow-through into next year. Was hoping you could either help size the benefit from expense actions or just frame how we should be thinking about expense growth as we look out to next year?

Alastair Borthwick (CFO)

I think what we've tried to do this year, Steven, is communicate pretty clearly what our plan was. As Brian said, we overachieved last year on hiring. So, you know, we started the year with 218,000 in expense of $16.2 billion, and we've really been working on the trajectory over the course of this year. So this point of getting the headcount in to a place where we're comfortable, $16.2 billion turns into $16 billion, turns into $15.8 billion. We're now determined to deliver on the $15.6 billion. And I think that's going to set us up really well. So our plan is to finalize our strategic planning over the course of the next few weeks, and I think we'll give you more guidance next quarter.

Steven Chubak (Managing Director)

Great. And just, two clarifying questions or cleanup questions at my end. On the NII remarks. You talked about deposits. I was hoping you could help frame, Alastair, what are the assumptions you're making in terms of reinvestment yields and loan growth that are underpinning that higher NII exit rate for next year?

Alastair Borthwick (CFO)

Yeah, so I'd say reinvestment, just assume the forward curve. And with respect to loan growth, I'd use low single digits, consistent with a slow growth economy.

Steven Chubak (Managing Director)

Okay, and just one quick one here on the tax advantage investments. I just wanted to confirm, given the long duration, the Forex increase in capital, are you still planning to fund tax advantage investments on the platform before the rules are finalized, or are you going to take a wait-and-see approach?

Alastair Borthwick (CFO)

Well, I mean, this remains something that's important for our clients. We've yet to see a final rule, so we'll be supporting transactions. But obviously, as Brian said, it is informing us with respect to pricing, and it's informing us with respect to appetite. But no, until there's a change, we'll continue to support the clients in that regard.

Steven Chubak (Managing Director)

Understood. Thank you so much for taking my questions.

Operator (participant)

We'll take our next question from Matt O'Connor with Deutsche Bank. Please go ahead. Your line is open.

Matt O'Connor (Managing Director)

Good morning. First, just to clarify, what's driving the drop in net interest income from Q2 to Q4? Is that core net interest income, or is that on the market side?

Alastair Borthwick (CFO)

Well, you're, you're talking about the fact that we think that we're going to be around $14 billion or so in Q4?

Matt O'Connor (Managing Director)

Exactly.

Alastair Borthwick (CFO)

I'd say first one is you've got a little bit of deposit pricing lag there, so we got to keep thinking about that. Second is we're sort of baking into it some continued normalization of consumer balances, so that's just continued to drift slowly lower. I think third, you know, if we had hoped for loan growth in Q3, we just didn't see that. So that's going to flow through with lower loan growth balances in Q4. Then the only final thing I'd just say is, you know, the Global Markets NII may not repeat in quite the same way. Some of that depends on client behavior. And they benefited this particular quarter by just rates, long-term rates going up so significantly and that helping the carry side.

So it's all those things and probably a little bit of, rate hike probability or timing delayed, but it's, it's all those sorts of things. [crosstalk] it hasn't changed from our expectation a quarter ago, in any way.

Matt O'Connor (Managing Director)

Yeah. Okay, that's helpful. And then just conceptually, as we think about your, your interest income guidance for next year, you know, what if we get higher for longer rates, there's not cuts? You know, is that good or bad versus the guidance that you gave earlier? Obviously, you've got puts and takes, so some reinvestment on the asset side. But again, coming back to the deposit pricing issue, you know, I think there's a view that, you know, higher for longer eventually drives up those consumer rates. So what would be the net of those two in the higher for longer? Thank you.

Alastair Borthwick (CFO)

Well, higher for longer is going to be better. So you're right, we've got the forward curve in our expectations. If that doesn't turn out to be the case, we'd expect NII would be higher.

Matt O'Connor (Managing Director)

That's simply the assets we're pricing more than the deposits, or you're still thinking there's minimal consumer deposit repricing even in the higher for longer?

Alastair Borthwick (CFO)

It, it'll be both. I mean, there'll be the repricing for sure. And in addition, you know, we'd expect to capture a little bit of margin from any short-term rate hike.

Matt O'Connor (Managing Director)

Yeah. Okay, understood. Thank you.

Operator (participant)

We'll take our next question from John McDonald with Autonomous Research. Please go ahead. Your line is open.

John McDonald (Senior Analyst Large-Cap Banks)

Yeah, I was hoping you could give a little color on what you're seeing on credit, your outlook as you look at roll rates and migrations, how are you thinking about the trajectory of charge-offs in the near term?

Alastair Borthwick (CFO)

Well, John, I'll just point out, as you can see the trajectory, we've laid it out on the slide. Most all of the net charge-off increase over time has been really due to card and consumer card. And the charge-offs at this point are still lower than they were in the Q4 of 2019, which was a stellar period. And, you know, I'd anticipate in the short term that you'd see things begin to... Well, just continue that trend because it normally follows ninety days past due delinquencies, and those are up ever so slightly again this quarter. So we're inching closer to the Q4 of 2019, and at some point, that's going to begin to stabilize. From there, it's just a question of what does the economy do?

So right now, as Brian's pointed out, we've got a slow growth economy in the plan, so I'd anticipate as we get back towards that kind of Q4 2019 number, it's going to normalize in there. But from that point, it will be very economic dependent. On the commercial side, the asset quality has been excellent, and the only place where we've got, you know, particular elevated concern is office, which is a very small part of our portfolio. It's less than 2% of our loans. But the commercial side has been terrific, and again, that will depend on how the economy plays out and whether we're talking about a soft landing, whether we're talking about a recession, or whether we're talking about robust growth. So all of that's going to have to play itself out.

With the commercial numbers being so low, you know, that one could bounce around a little bit, but it's only because it's coming off a base that's so low at this point.

Brian Moynihan (Chairman and CEO)

John, just one thing on the... As you think about the commercial credit, remember, we have a strong discipline, ratings change, you know, ratings capabilities company. And so, you know, we are the commercial real estate portfolio, et cetera. We put them on, you know, criticized quickly. We did, you know, deal with the charge-offs, and that's why you see it come back down already. And, you know, and, and we're adjusting those, those activities as we show in the slides in the part of the deck, you know, to current appraisals, you know, under current market conditions, under current rent rolls, et cetera.

And so even though it's a very small part of our portfolio, frankly, a lot of the issues are through the system for us because the high, you know, ratings integrity and ratings conservatism we've had in this company for, you know, many, many years. And that holds us well, and I always remind you, if you think back, like, in the oil and gas thing in the 2015, end of 2015, 2016, we put up all of this reserve that was pre-CECL, and then ended up bringing it back in because the charge-offs were very modest.

So I think we feel very good about the original underwriting, but you also have because of our ratings integrity on the office part of the portfolio, we pushed a fairly significant amount through, you know, reappraisal and relook, and we have the CECL reserves, but importantly, the charge-offs, you know, are falling already.

John McDonald (Senior Analyst Large-Cap Banks)

Got it. And one bigger picture question, as you think about the Basel III and the opportunity to mitigate and optimize, does a 15% ROTCE feel like a good aspiration for the company over time, Brian, through the cycle? I mean, recognizing that's where you are already today, but as you factor in, you know, the potential for new rules, how do you think about that?

Brian Moynihan (Chairman and CEO)

Yeah. So I, I think if we're doing on a hundred and ninety-four billion dollars of capital, which we did at this quarter. And that is, you need about another, say, $10 billion to put a buffer on the end state need, you know, $10-$11 billion, 195 plus, you know, half a percent, which is our normal buffer, without any mitigation. You know, that would be, you know, ten over 200, let's make it simple. And that would hit the ROTCE a bit, and we-- I'm sure we can figure out ways to price to get that back.

But remember that we're different than everybody else, John, because we're actually sitting on this amount of capital today, and so we are getting a 15% return on it. So I don't want to. Don't take that as saying, I agree with the rules, but saying, we got to deal with the cards that are dealt to us. The rules say that you have to have $195 billion plus about $10 billion or, you know, cushion for, and, you know, maybe a little bit more of cushion, but depending on, you know, for 50 basis points or so. But, you know, if we're doing 15% today, so that'd be a slight dilution to that number, but not something we couldn't make up, and that's before any mitigation, honestly. And there's always mitigation.

You know that. You've been around this industry for a long time. So there's always mitigation, how you construct things, what you'll do, what you'll not do. And those and I fully expect there'll be modifications in the rules which ought to, which ought to help also. But I think the simple point is, we earned it on it, that amount of capital today, so it's not like some calculation I have to think through. It's right there today.

John McDonald (Senior Analyst Large-Cap Banks)

Yeah, that's good perspective. Thanks, Brian.

Operator (participant)

We'll take our next question from Vivek Juneja with JP Morgan. Please go ahead. Your line is open.

Vivek Juneja (Managing Director, Senior Equity Research Analyst)

Thanks. Alastair, question, just want to clarify your NII comment. So if rates, let's say, higher are better, are you implying that rate cuts would therefore be negative for you from an NII standpoint?

Alastair Borthwick (CFO)

Yeah, I'm saying right now, Vivek, that if you think about what rate cut- rate cuts look like in the back half of next year, in the absence of that, we, we might guide NII higher. Yes, that's, that's what I'm trying to communicate.

Vivek Juneja (Managing Director, Senior Equity Research Analyst)

Is that because your assets, you have that many floating rate assets that will reprice faster than you can cut funding costs?

Alastair Borthwick (CFO)

Yeah, on the way down, I'd anticipate that as rates are going down, it's going to cut into our margin on our deposit spreads. So that's essentially what we're talking about.

Brian Moynihan (Chairman and CEO)

Yeah, Vivek, I think I've just listened to you and Alastair. I think, remember, the forward curve has multiple cuts in it next year, and I think the question earlier was, if those didn't occur, what would happen? And I think Alastair said NII would be higher if those cuts didn't occur. It's not a rate, you know, it's that just mathematically, that 75 basis points in the second half of next year of not being cut would hold us higher because of all the, you know, deposits being worth more and the floating rate assets holding pricing up better. Dominant part of our balance sheet. I just sense that you're talking by each other, but maybe not.

Vivek Juneja (Managing Director, Senior Equity Research Analyst)

Okay, thanks.

Operator (participant)

We'll take our next question from Ken Usdin with Jefferies. Please go ahead. Your line is open.

Ken Usdin (Managing Director, Equity Research)

Thank you. Just a follow-up on the securities portfolio on the AFS side. Alastair, how much of that $180 billion is still swapped? And can you kind of help us understand, like, you know, what the kind of all-in yield is on that book, and if you would still also have repricing help going forward on that book, as well as you had mentioned earlier on the HTM maturities?

Alastair Borthwick (CFO)

Yeah. So, most of the book we swapped to floating. We've tried to establish that over the course of time. So you can almost think about most all of the available-for-sale securities repricing kind of every day, every week, every two weeks, whatever it may be. So that tends to look a little bit more like the cash type moves over time. There's a few securities in there that are fixed rate, but very, very little in terms of the total complexion, Ken.

Ken Usdin (Managing Director, Equity Research)

... Okay, that, that helps. Thank you. And then just wanted to also say, on the fee side, obviously, another really good job, both on the investment bank and the trading businesses. Still in uncertain environments. Just wanted to get your thoughts. You were able to hold the IB fees flat sequentially, which was, I think, better than you had indicated. Just your thoughts on reopening here in the markets and, how you're kind of expecting the business to, you know, hopefully act, albeit, you know, understanding it's still an uncertain environment.

Alastair Borthwick (CFO)

Yeah. So, you know, this is, this is, I suppose, unusual and not unusual. Investment Banking obviously has the potential for swings in fees. And what's interesting about this one is we've now been bouncing around this sort of $1.1 billion-$1.2 billion per quarter. And, you know, normally, Investment Banking you'd expect to return within a year or so, and we're now 7 quarters into this. So we've got a good pipeline. And mostly what I think corporate America and around the world, C-suite executives are looking for is the confidence that comes from macroeconomic certainty, geopolitical certainty. So for as long as we've got the volatility, it's gonna stay in this kind of a range.

But if you were to look back in periods past, investment banking can come back very, very quickly to a you know, a more historical range of kind of $3 billion, $4 billion, $5 billion per quarter. It's just that we've grown tired of predicting when that might be, Ken.

Brian Moynihan (Chairman and CEO)

Yeah, Ken, let me give you two other pieces. One, the pipeline still is strong, but more importantly, Matthew and the team have done a good job of building out our capabilities to serve our huge, you know, middle market client base, our global commercial banking client base under Wendy's leadership. And, you know, that number is growing quickly, and that's a market which is we're relatively unpenetrated in. We had good market share with our clients, but that we did business with, but we meaning investment banking business with. And so that's generating, probably better performance for us than others, in terms of holding our position flat relative, you know, up a little bit, year-over-year, flat year-over-year versus a down market. So we added up...

We basically doubled the size of that team, and we'll double it again. It's that, it's that kind of opportunity for us.

Ken Usdin (Managing Director, Equity Research)

Got it. Great. Thank you for the call.

Operator (participant)

We'll take our next question from Manan Gosalia with Morgan Stanley. Please go ahead. Your line is open.

Manan Gosalia (Executive Director, Equity Research)

Hi, good morning. My question was around deposit growth and what level of deposit growth do you think you need from here? Should it be in line with loan growth, or are you happy to let some of the more maybe non-transaction deposits run off? And the reason I ask is because you know, as noted in some of the prior questions, some of your peers are saying that there's more room for consumer deposits to reprice higher, especially core checking accounts. It sort of sounds like you disagree with that. So wanted to assess how much you might need to respond if competitors act differently.

Brian Moynihan (Chairman and CEO)

So a couple things. One, you know, just broad-based, we have a $1.9 trillion deposit, $1 trillion of loans, so we have a tremendously high deposit base. But also, you know, if you think about if you look at the slide, five or whatever, as we show the deposits by business. In the, in the banking business, Global Banking, you know, I think 6 quarters we've been relatively flat, so, and starting to grow off of that. That is fully priced at, you know, it's not like corporate treasurers wait around to you know, to talk to you about what you're paying in, in a non-interest-bearing percentage that has drifted down. The amount they hold in excess of that, to, part of that to pay fees has been relatively stable.

So, you know, we feel very good about that. You look at wealth management, basically all the movement was made has been made pretty much to the higher rate environment, i.e., buying Treasury securities directly. If you look in our wealth management business, the amount of short-term, cash-oriented type investments, money market funds, and et cetera, treasuries, et cetera, has gone from, like, $500 billion to $700 billion or $800 billion over the last couple of years. So, yeah, that move has taken place. And then, so the rest of it is now in a relatively stable base, and you can see those numbers flat. If you go to the consumer side, there's basically two or three things.

One is, you know, in the form of median income households, plus or minus, you're seeing the slow spend down, even though they still have multiples of what they had pre-pandemic in their accounts. And even though that's a small part of the overall deposit base, there's still a slow trend of where that's drifting down as all the things you read about go on. In the higher end part of that base, in the broad consumer base, they're actually below the pandemic by about 20%, and that's because they moved the money into the market, and you can see that in some of the preferred category pricing. So, you know, where people think about, you know, checking and money markets and this, we think... I always have thought about it a little more straightforward, which is transactional cash and investment cash.

The investment cash has largely been resuited across the businesses. The transactional cash holds because it's money in motion moving every day. And for our consumer business, you know, that's represented by the $0.5 trillion of checking account balances you can see on the page, with some modest, you know, amounts in money markets and stuff that are carried as the cushion people have. And, you know, if they move the money in the market, they've moved it. And so we're watching consumer because there's a little more drifting there, and it's up $250 billion since pre-pandemic. And you're saying you have the dynamics of loans, student loan repayments starting. That's 1 million of our customers pay student loans. You have the dynamics of interest rate impacts on cash carry....

of loan balance, so that's higher, and that'll sort out, but just takes a lot longer. That's across 37 million people, so it's a you know, the impact takes a while to sort through, and so we feel good about it. But I think people look by category and this and that. You have to think about it more how a customer, whether it's a business or consumer, behaves. And what we've seen them is adjust their behavior based on their household circumstances and largely through the system, and most of it coming a little bit slower in consumer, just because the natural question, if there are a lot of stimulus went in those accounts, you know, what do I do with it over time? You know, and now they're doing something with it.

Manan Gosalia (Executive Director, Equity Research)

Got it. That's, that's helpful detail. So, I, I guess just in terms of deposit growth from here, do you- would you still prefer to, to grow deposits in line with loans, or is there a little bit more room for that to come down?

Brian Moynihan (Chairman and CEO)

We prefer to grow deposits in line with customer growth and activity. So, you know, in the last four quarters, in consumer, I think we're up another 900,000, you know, net new checking accounts, which average balance is around $11,000. They come in at, you know, lower than that, mature up to that. You know, we grow—we have a transactional banking business for all types of customers, and we grow it irrespective of it. That produces $2 trillion. Your loan—you have a loan business to customers, that produces $1 trillion, and that difference then is a wonderful thing to have every day.

Manan Gosalia (Executive Director, Equity Research)

I appreciate it. Thank you.

Operator (participant)

We'll take our next question from Chris Kotowski with Oppenheimer. Please go ahead. Your line is open.

Chris Kotowski (Managing Director)

Yeah. Good morning. Thanks. I've been looking at your average balance sheet on page 8 of the supplement, and I noticed that in this quarter, you know, your overall yield on earning assets was up 20 basis points, and lo and behold, the yield on interest-bearing liabilities was also up 20 basis points. You know, and I'm curious, was there some benefit, unusual, you know, the lower amortization or something like that? Or is it just a function of that behind all the moving parts of balances better than you thought?

Brian Moynihan (Chairman and CEO)

Well, I don't think it was an amortization issue. I think it was just the way the entire balance sheet works across assets, liabilities, when you think about all the various moving pieces. So I don't think there's anything particularly notable there.

Chris Kotowski (Managing Director)

Okay. No, it's just, stunning with all the moving pieces, how the earning asset yield and the liability yields really moved in tandem. So all right, that's it for me. Thank you.

Operator (participant)

For our final question today, we have a follow-up from Vivek Juneja with JPMorgan. Please go ahead. Your line is open.

Vivek Juneja (Managing Director, Senior Equity Research Analyst)

Thanks. Brian, trading has grown nicely in equities. You've had, you said it was led by financing. Is there room in your balance sheet from a capital standpoint to keep growing that? And, second question related to trading would be: in your guidance on NII for next year, what are you assuming for trading NII, in there?

Brian Moynihan (Chairman and CEO)

Let me just hit the first one, and Alastair can hit the second one. Yep, the capacity, if you think about the constraint on RWA, you know, as you know, Vivek, and your experience in the business, that, you know, the equity financing is not RWA intense. So, but it is asset, yeah, size intense. Now, when you look at us with our supplementary leverage ratio, 100+ basis points over the requirements, we have lots of room on the asset size if we want, and the return on equity, return on the risk on that business is very strong. So, Jim and the team have done a good job and Soof and the equities side, and, you know, we continue to experience it. So there's plenty of room.

And in fact, we have brought the balance sheet up by over $200 billion, largely due to the financing side. A lot of that due to equities, and we can continue to do that if the clients need the capabilities and the products. So that, that's the simple answer. Yes, there's a lot of capacity and largely driven by our huge capital base and our effect, you know. On all the size measures, we're way over the requirements. I think, you know, 100 basis points on that is probably almost $50 billion of overage, so you have a lot of room to go.

Alastair Borthwick (CFO)

Then, Vivek, in terms of the NII guidance, we include Global Markets in there, so, you know, it's just part of a big diversified portfolio. I think, you know, we would point to Global Markets remains liability sensitive. You can see that in the way NII has come down in 2021 and 2022 and into 2023 with rates going up. So it'll perform according to the rate curve, and then, you know, we may put a little bit of modest balance sheet growth in there, as Brian pointed out, just to continue investing in the business. But it's in the NII guide, and it'll follow the forward curve.

Vivek Juneja (Managing Director, Senior Equity Research Analyst)

Thank you.

Brian Moynihan (Chairman and CEO)

So thank you for joining us. Just in closing, go back to the key points. Strong earnings for the company. Earnings growth year-over-year for the three months and nine months in double-digit. The returns of 15% return on common equity are very strong. We have the capital to meet the new capital rules as proposed, before any mitigation, before any changes in those rules. And we're returning 15% on that capital today, so we feel good about the path ahead for the company. We continue to do it the old-fashioned way, growing our clients, growing our revenues from those clients, and driving responsible growth. Thank you.

Operator (participant)

This does conclude today's program. Thank you for your participation, and you may now disconnect.