BAC can face loss of goodwill or reputational damage from financing operations linked to inhumane treatment of animals (such as animal testing and habitat conditions) and credit risks if borrowers experience business disruptions associated with animal welfare issues that impair ability to repay loans. According to American Banker, BAC is among the top financiers of factory farms, responsible for 20% of all loans and underwriting services to companies tied to factory farms.(1) Animal welfare concerns are linked to systemic and enterprise risks from factory farming such as food safety issues from diseases passed from animals to humans, and public health risks from overuse of antibiotics in livestock. Factory farms also contribute to biodiversity loss, deforestation, pollution, overuse of water, and soil degradation in addition to the major concerns regarding animal welfare.(2) Openlnvest stated: “A company that does not disclose or prioritize its processes or impact on animal welfare raises questions for investors on how effective that company can be in managing potential risks or opportunities down the road. It is also impossible to assess future risk without the disclosure of the right information.”(3) However, the topic of “animal welfare” is absent from BAC’s policies, governance documents, and reports. While BAC’s Environmental and Social Policy Framework asserts “...the importance of biodiversity and its environmental, cultural, religious and health contributions to societies”, the policy appears limited to certain “sensitive” or “fragile” ecosystems and conditions, without addressing the welfare of animals involved.(4) Increasingly, banks are adopting exclusionary criteria to reduce exposure to animal cruelty and associated risks(5) and otherwise taking animal welfare issues into account as part of their lending due diligence practices. Yet BAC earns a score of “0” on BanksForAnimals.org, for apparent deficiencies in key areas regarding animal welfare.(6) Non-disclosure does not necessarily indicate lack of due diligence. However, neglecting to publicly acknowledge animal welfare oversight risks the perception of failure of oversight on critical issues. Publicly disclosing how BAC addresses animal welfare in financing decisions would increase transparency and strengthen BAC’s reputation. (1) https://www.americanbanker.com/news/activists-to-jpmorgan-chase-bofa-citi-stop-lending-to-factory-farms (2) https://www.w_orlqc;mimalprotection.org/globalassets/pdfs/reports/english/closing the financing-gap.pdf at 20. (3) https://www.openinvest.com/articles-insights/support-animal-welfare (4) https://about.bankofamerica.com/content/dam/about/pdfs/environmental-and-social-risk-policy-december-2023.pdf (5) https://banksforanimals.org/ranking-list/ (6) https://banksforanimals.org/institutions/bank-of-america/