The notes, with an initial rate of 3.846%, are due 2037

Davis Polk advised the lead manager, sole book-runner and representative of the several underwriters in connection with an SEC-registered offering by Bank of America Corporation of $2.5 billion aggregate principal amount of 3.846% fixed-rate reset subordinated notes due March 2037. The notes pay interest at a fixed rate of 3.846% for the first 10 years of the term of the notes and then at a rate that will reset based on the U.S. Treasury rate for the remainder of the term.

The Davis Polk tax team also advised Bank of America Corporation in connection with the offering.

The Davis Polk corporate team included partner Christopher S. Schell and counsel Michael J. Russo. Partner Po Sit and associates Spencer Pan and Ben Silver provided tax advice. All members of the Davis Polk team are based in the New York office.