Recently, the racial justice movement together with the disproportionate impacts of the COVID-19 pandemic on communities of color have focused the public’s and policy makers’ attention on racial equity issues.  Following the June 2020 protests related to George Floyd’s murder, BofA announced it would commit $1 billion to racial equity initiatives with an additional $250 million in March 2021 because of the urgent need “to address long-standing issues of inclusion and racial inequality…”
BofA has a conflicted history when it comes to racial equity issues.  In 2018, the Treasury Department’s Office of the Comptroller of the Currency found that the bank offered disproportionately fewer home loans to minorities than to white applicants in Philadelphia.  The bank also closed 29.1% of branches in majority-Black communities compared to 18.4% in non-majority Black areas from 2010-2018, despite the important role that branches play in supporting small businesses.  From an employment perspective, while the bank recently increased representation of minorities in its senior executive team, executive/senior level officials and managers comprise only 5% of Black employees and 4% of Hispanic employees according to its last EEO-1 report although 45% of its workforce are people of color.  
While BofA has provided specific areas it plans to focus on, including funding affordable housing through minority depository institutions, its racial equity commitment does not address concerns related to its own financial products. Further, the bank provided $15 billion in affordable home lending outside of its racial equity commitment, but this earmarked amount is a fraction of the bank’s own residential mortgage lending portfolio, valued at approximately $215 billion in 2020.  The bank has yet to provide information about how it plans to evaluate the racial impact of its direct lending as part of its strategy to address racial inequality.
Lastly, the bank’s corporate contributions are not fully aligned with its public statements: it donates to 11 police foundations that critics note bypass normal procurement processes to buy equipment for police departments, including surveillance technology that has been used to target communities of color.[1]
[1] Little Sis.  “Police Foundations: A Corporate Sponsored Threat to Democracy and Black Lives.” p. 28 and 51. Oct. 5, 2021, available at https://policefoundations.org/wp-content/uploads/2021/10/Police-Report-2021_10_05_FINALV3.pdf.