Earnings Call Transcript - BAC Q3 2023

Operator, Operator

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 a 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, Head of Investor Relations

Good morning. Thank you. Welcome and thank you for joining the call to review the third quarter 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. So with that, Brian, I'll turn the call over to you.

Brian Moynihan, Chief Executive Officer (CEO)

Good morning, everyone, and thank you for joining us. As usual, we're starting on Slide 2. Our third quarter 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 third quarter. And for the first nine 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 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 of 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 third quarter was up about 4% over last year's third quarter. Earlier this year, that would have been more of a 10% increase year-over-year. And for the entire year of 2022, it increased about 10% over 2021. 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 3. We provide various highlights, and Al's just 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 4. Every business segment had organic growth. In Consumer, in quarter three, 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, third quarter, than we did last year. In Small Business, we have 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. In this quarter, our Small Business teammates extended $2.8 billion in credit to small business in America alone. In Global Wealth, we added nearly 7,000 net new relationships to the Merrill and 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 wealth spectrum, in GWIM and in consumer investments, they have combined to gather $87 billion in total net flows. In 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 our number three 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 5, you can see the digital adoption, engagement and volumes continue to increase. We lead the industry in digital banking and continue to provide 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 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. CashPro 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 users continue 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 the slide, the story is the same. All these capabilities help us deliver faster, safer, and more efficiently. And all of it gets strong customer and client feedback. When you put that together, that helps us drive operating leverage, and you can see it on Slide 6. We have a strong record of driving operating leverage in our company. We drove operating leverage every quarter for nearly five years before the pandemic. And then again, more recently, we've had an eight-quarter streak leading to this quarter. We acknowledged to you this last quarter that our operating leverage is going to be tough for a few quarters as we navigate through the trough of net interest income. But as you can see on Slide 6, 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 headcount to help make sure we got our expenses in line. Over the course of 2023 we've seen a move from 2022's great resignation to our current level of record low attrition in our company. All that meant the team had to work harder to manage that headcount down. And they did it. Our headcount 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 quarter one to $16 billion in quarter two 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 fourth quarter, excluding any FDIC special assessment, of course. We expect to report $15.6 billion in expenses in 4Q. Now interestingly, the debt is up only around 1% from fourth quarter 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 ending basis across the third quarter. We gave you this chart last quarter also. In the upper left-hand, you can see the trend of total deposits. We ended quarter three at $1.88 trillion, up from quarter two 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 cash, re-initiated deposit growth and grown share with always superior mix in cost. You will note we're now paying 155 basis points all in for deposits, which is up 31 basis points from last quarter. I 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 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 advantageous compared to past cycles because the transactional counts in the current cycle are a much higher mix of Bank of America's deposits. I would also add that while we maintain discipline in deposit price and we pay competitive rates to customers with excess cash seeing higher yields across all the businesses, if rates fall, those particular products will see the 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 could also see the low levels of our more rate-sensitive balance in 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 was 34 basis points. This remains very low, driven by the high percentage of transactional high-quality transaction 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 for the past six quarters. These are generally the transaction deposits of our commercial customers used to manage their cash flows. Noninterest-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 the most profitable banking group in the world. It's a source of strength for our country and its economy. The annual stress tests, now over a dozen years old, using ever-increasing 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. We add to our capital and reduce our lending capacity to American business and consumers, and those trade-offs are being debated. But as far as the rules are concerned, there are many parts of the rules that our industry doesn't agree with because of double counting 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. If they don't, how will they affect us? If you go to Slide 8, you can see 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 hundred billion dollars in operational RWA. The next biggest category would be driven by a four-fold 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 G-SIB charges that go into effect on January 1, 2024, we move to 10%. So I'm going to use that as a requirement. Holding 10% today means $163 billion; we finished the third quarter with $194 billion. So today, we have more than $30 billion excess capital. Now, let's assume the proposed change is going through in full. The proposed changes are phased in from the middle of 2025 to 2028 under the current proposal. When those are fully phased in, if you remember Basel fully phased in, 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 today we're at $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 see just in the last nine quarters the kind of capital generation this company has. Once we understand the 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 talked about over the many years. That's our Global Markets business. Global Markets represent 17% of the company's year-to-date earnings and it's one of the top capital markets platforms in the world. It's one of a handful of firms that can do what is required, providing advice and execution in every major market around the world. Jimmy DeMare and the team who run the business asked us for additional investment around four years ago, and they've grown this business with an intensity that clients are appreciative and reward us with more of their 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, and now stands 32% higher than the average of the five years leading into the pandemic in the investment in the business. And through effective cost management, we also generated 11% to 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, because our corporate clients also take advantage of these industry-leading capabilities. With that, let me turn over the call to Alastair to walk through the quarter. Alastair?

Alastair Borthwick, Chief Financial Officer (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 3. For the quarter, we generated $7.8 billion in net income, resulting in $0.90 per diluted share. Both of those are up in the double digits from the third quarter 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 second quarter, 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 second quarter, and still below the 39 basis points we saw in the fourth quarter of '19. And as a reminder, that 2019 was a multi-decade low. 30-day delinquencies also remained below their fourth quarter '19 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. And 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 second quarter. So 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 held-to-maturity securities as those securities matured and paid down. And as Brian noted, global excess liquidity sources remain strong at $859 billion, that's down very modestly from the second quarter, and still remains approximately $280 billion above our pre-pandemic fourth quarter '19 level. Shareholders' equity increased $4 billion from the second quarter 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 $1.1 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 amid higher funding costs. And 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'll just note the comparisons. Relative to pre-pandemic fourth quarter '19, average deposits are up 33%. Consumer is up 36%, with consumer checking up 45%. And 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 of 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. And 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 held-to-maturity securities portion so we could lock in value from those deposits. And 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 term held-to-maturity securities. And 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. And the combination of the cash and available-for-sale securities represents about 47% of the total noted on this page in the third quarter of '23 to give us the balance we're looking for. And if we look at the held-to-maturity book, it had grown from $190 billion pre-pandemic, peaking two 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 six years, and about $474 billion in mortgage-backed securities and a few billion other. Held-to-maturity securities peaked at $683 billion, and we're now down $80 billion from the peak and $11 billion in last quarter. That $80 billion decline from peak was all driven by the reduction of mortgages from $555 billion to $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 third quarter of '21, 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 held-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. And 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 '20 at $9.1 billion; that compares to $13.9 billion in the third quarter of '23 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 going to use Slide 15 for that. On last quarter's call, we guided to expect Q3 NII to be about $14.2 billion to $14.3 billion on an FTE basis. Our third quarter 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 per year. We believe NII will hover around this expected fourth quarter $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 fourth quarter of 2024, we believe we can see NII up low single digits compared to the fourth quarter of 2023. The good news is we believe NII will likely trough around the fourth quarter 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 third quarter of '22, or 4%, while our net interest yield improved 5 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, and 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 5 basis points. Turning to asset sensitivity and focused on a forward yield curve basis, the plus 100 basis point parallel shift at September 30 was $3.1 billion of expected NII benefit over the next 12 months from our banking book. 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 fourth quarter to go down another couple of hundred million to $15.6 billion, excluding any FDIC special assessment. That would mean our fourth quarter expense of $15.6 billion, compared to the fourth quarter of '22, 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 first quarter 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 second quarter 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. And you 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 fourth quarter $15.6 billion expense target to more fully benefit from the third quarter headcount reductions, and that will allow expense to continue the decline experienced throughout the year so far. All of that is going to 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 second quarter. 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 fourth quarter of '19. 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. And 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 fourth quarter of 2019 as an example. Commercial net charge-offs declined from the second quarter, driven mostly by a reduction in office write-downs. And 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. And 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. And 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 continue 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. And 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. And 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 third quarter 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 advisers and capabilities from technology investments. On Slide 21, you see the Global Banking results. And 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%. And we held on to number three position given our performance. Provision expense reflected a 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 businesses, as well as a record third quarter 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 third quarter of last year. And at $1.7 billion, that's a record third quarter for our equities teammates. Year-over-year, expense increased 7%, primarily driven by investments for people and technology. Finally, on Slide 23, all other shows a profit of $89 million. So revenue improved from the second quarter, driven by the absence of prior period debt security sale losses in 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%. And 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% to 10% range. So 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 fourth quarter. 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. So all in all, it was a strong quarter. It was one where our teams executed well against responsible growth. And with that, David, I think we'll open it up for the Q&A session.

Operator, Operator

And we will take our first question from Gerard Cassidy with RBC. Please go ahead. Your line is open.

Gerard Cassidy, Analyst (RBC Capital Markets)

Thank you. Hi, Brian. Hi, Alastair.

Brian Moynihan, Chief Executive Officer (CEO)

Hi, there.

Alastair Borthwick, Chief Financial Officer (CFO)

Hey, Gerard.

Gerard Cassidy, Analyst (RBC Capital Markets)

Brian, can you come back to your thoughts. You're talking about the consumer spending holding at 4% right now, obviously down from the very strong levels of a year or two years ago. When you look out and you mentioned how you guys were 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, Chief Executive Officer (CEO)

I think, a couple of things, Gerard. One is there's obviously external events, which could change the situation in the globe dramatically. But given just the pathway that those kinds of events don't take place, you think that the rate they're spending at now is consistent with lower inflation. Embedded in our team's economic projections is a return to inflation to the 2% target at the end of '25. The rate structure comes down beginning in the middle of next year, but still stays around 4% at the end of '25. So given that inflation is coming down and the economies would still be growing then and getting back towards trend growth, I think it would hold steady. It's been pretty steady from August into September into October at this 4% to 4.5% to 5% level. People get paid more, they spend a little bit more and pricing goes up. Then you have the ebbs and flows within it, what they spend on. 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 purchases, then you had a lot of travel. You had a lot of return-to-office spending. We can track that people buying stuff. All that's kind of leveled out of the system, including a drop in fuel prices and an increase — basically it's relatively balanced and they're spending about the same amount of money on gas as they spent last year. So all that being said, in the big aggregate numbers, I think, yes, it can keep bumping along at that level, which is consistent with a 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's what we see. Now, we'll take some time for all that to work through the system and the retail sales number seems to be stronger today, but that will all shake through, but this is what they are doing at the moment.

Gerard Cassidy, Analyst (RBC Capital Markets)

Very good. And then as a follow-up question, you guys gave us good detail on Slide 8 about the potential changes coming from the Basel III end game, and you showed 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 in the alternative energy space, I guess they're going up from 100% RWAs to 400%. Would that change your thinking in that line of business as we go forward, should they stay in the final rules?

Brian Moynihan, Chief Executive Officer (CEO)

So I think, number one, 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 what they all mean. There'll be rigorous points about our views of the wisdom of the changes, the need for the changes, the balance of the changes, the double accounting, all the things 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 sort of counter the policy that we want to encourage. 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 ultimately, it would have to go through the market. You have the equity cost go up by a four-fold increase to get the returns. So think about a pricing model: increasing the amount of equity we have to dedicate, therefore we have to get returns on that. And so that would happen. It 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. 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, Analyst (RBC Capital Markets)

Very good. Thank you very much, Brian.

Operator, Operator

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

Jim Mitchell, Analyst (Seaport Global)

Hey, great. Good morning. Alastair, at a conference a month ago, you noted that 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 in consumer savings, for example, from greater competition or further outflows. So — and to be fair, they're 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, Chief Financial Officer (CFO)

Yeah. 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 if you think we've seen the last Fed hike or you believe that the last Fed hike is a month from now or two months from now. At some point, deposit pricing is going to stop going up. And there'll be a natural lag to that; that's pretty normal. Then, if you look forward into the forward curve we've actually got Fed cuts, three of them, in the forward curve for next year. So yes, we anticipate 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 the later innings. The other thing is we always have to remind everyone of this: the deposits that we have are very relationship based. 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 reward programs. 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, Analyst (Seaport Global)

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

Alastair Borthwick, Chief Financial Officer (CFO)

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 the floor at some point. They are in the late innings of returning to more normal pre-pandemic balances per account. So they are going to find a floor and at that point they're going to start growing in the same way that Wealth has found the floor, and in the same way 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 the floor. That's one. Two is, 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 has 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. I think it gives us a sense that we've got a more durable NII stream underneath.

Jim Mitchell, Analyst (Seaport Global)

All right. Great. That's all. Thanks.

Operator, Operator

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

Erika Najarian, Analyst (UBS)

Hi, good morning. I have my first question which is two-pronged on the balance sheet. Alastair, if you could tell us how much in cash flow you forecast your held-to-maturity book will have in 2024 as you think about the moving pieces underneath your NII outlook? And for Brian, clearly this held-to-maturity portfolio has been a thorn in the side of the stock. No matter what we say to the investment community, the 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 adds, maybe give us a little more statistics in terms of the strength of that growth and the strength of that retention. Because I think that no matter what sort of print that you have on total deposits at the end of the quarter, there's always 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, Chief Financial Officer (CFO)

All right. So I'll answer the first part, Erika. If you look back through the course of the last couple of years, that portfolio paydowns in terms of maturities or paydowns is averaging about $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 what I would use. And then I'll let Brian answer the second part of your question.

Brian Moynihan, Chief Executive Officer (CEO)

So, Erika, we drive an organic growth machine based on a responsible set across all the different operating businesses. So as you've noted, if you look at what's driving our deposit base to be larger than the industry, i.e., outperforming the industry, if you think from 2019 to now we're up $250 billion in Consumer deposits, but we also are up probably 10% in checking accounts, net checking accounts. Those are 92% core. The retention rate is 99% plus for long-term customers; the preferred rewards program drives that. On cards, we're now getting the balances back up to where they were pre-pandemic and with even better credit quality than we had then. Home equity hit a trough and is starting to work its way out. Auto loans are starting; it will continue to produce a lot. The market is 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 Wealth Management, we're now producing household growth at a faster rate than we produced in prior years. If you go to the Commercial Banking businesses in the US, we produced more customers this year, and that deposit base in the business banking and middle market segments comes with a big deposit franchise. You can see those deposits have actually been stable and growing for the last six months. So the organic growth engine is in fine shape and powers through all this and is the strength of the $3 trillion plus balance sheet. It is the reason that we have $1 trillion on a given day that we have to put to work because you're just having this great engine go on. Whether it's investment accounts in Consumer, checking accounts in Consumer, cards, home equity, all that has grown organically dramatically over the last four, five, ten years. And 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 and it’s due to the demand side, and so we feel very good. And then you talked about the Markets business; the investment banking team is gaining market share and actually held relatively flat fees in a market that was down about 20%. So we feel very good about the organic growth engine. That's what powers our company, and that delivered $7.8 billion in net income for another quarter and 15% return on tangible common equity.

Erika Najarian, Analyst (UBS)

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

Alastair Borthwick, Chief Financial Officer (CFO)

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 financing activity that's just about hedging. 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, Analyst (UBS)

Got it. Thank you.

Operator, Operator

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

Mike Mayo, Analyst (Wells Fargo)

Do you expect the efficiency ratio, expenses to revenues, to improve from 63% and when? 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 fourth quarter. Slide 5, the digital adoption, it's about three-quarters 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 fintechs, the sustainability of the digital trends and why you think you have an advantage on so many others. The second part of that question is revenues. Your NIM is a bit over 2%. It 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%. 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, Chief Executive Officer (CEO)

Mike, I think the expenses come down, revenue grows, the efficiency ratio continues to improve. One of the big differences between us and other companies you can compare us to is the size of our Wealth Management business relative to the size of the company is large. That's a business which we continue to work to make more efficient, but is the least efficient business in the platform. Lindsay and Eric continue to drive the efficiency there. So yes, we expect the efficiency ratio to continue to improve. Part of that will be as the net interest margin normalizes and we normalize the size of the balance sheet given it's grossed up for a lot of reasons through the pandemic and you fine-tune it, you'll get a little more effectiveness there. In the past, we ran up to about 2.3% in NIM in a sort of normalized environment, and you'd expect us to keep moving up from there. It will bounce around as we work through the trough in NII that we described, which is starting this quarter into the first half of next year. And as you know, it's all about managing heads. Last year we talked about the great resignation and how we had to hire people. We're able to bring that excess back out of the system and ended up kind of where we wanted to be at around 212,000. As we think forward, we continue to reposition people around the company who are freed up because of that digital application to other things. Our Consumer business has seen efficiencies from digital — fewer branches, fewer ATMs, more customer interactions digitally. That produces strong leverage. We continue to drive that, including sales in digital that we disclosed. You're running nearly half the sales digitally 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. We continue to drive the efficiency ratio to a level, and we'll see where we can get it to.

Mike Mayo, Analyst (Wells Fargo)

And then just on that big picture question, you've invested for over a decade in your data and tech stack and digital engagement. Now we have AI and generative AI as a new opportunity and a threat. Why do you think you have an advantage versus, say, smaller banks, fintechs or big tech?

Brian Moynihan, Chief Executive Officer (CEO)

We have an advantage in that we've been applying it for a number of years now. Erica is a form of that and now has almost 19 million users. If you think about that quarter, there were hundreds of millions of interactions. In the days gone by, every one of those would have been an email, a text or a phone call. It's tremendously more efficient. We've brought it out to CashPro which is the Commercial side. That helps. With the roughly $3.8 billion we'll spend in 2024 on technology and initiative spending, Aditya and the team continue to use the techniques you read about to increase the efficiency of development effort. That's probably 10% to 15% in the short term, building up higher as people get more used to it, and that will allow those dollars to be stretched further. We also have a lot of patents and a lot of inventors in the company. We feel good about our ability to compete against the types of people you mentioned. We also use some of those providers as partners; in many cases the big tech companies sell capabilities to companies like ours to make us more efficient. So near-term customer help, employee effectiveness, coding enhancements — these are practical near-term applications we're already doing.

Mike Mayo, Analyst (Wells Fargo)

Okay. Thank you.

Operator, Operator

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

Steven Chubak, Analyst (Wolfe Research)

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

Brian Moynihan, Chief Executive Officer (CEO)

Good morning.

Steven Chubak, Analyst (Wolfe Research)

I wanted to start with a question on expense. You cited headcount actions, it should provide relief in 4Q and positive flowthrough into next year. I 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, Chief Financial Officer (CFO)

What we've tried to do this year, Steve, is communicate pretty clearly what our plan was. We overachieved last year on hiring. So we started the year with 218,000 and expense of $16.2 billion. We've been working on the trajectory over the course of this year. Getting headcount to a place where we're comfortable — $16.2 billion turns into $16 billion, turns into $15.8 billion — and we're now determined to deliver on the $15.6 billion, and I think that'll set up really well. 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, Analyst (Wolfe Research)

Great. And just two clarifying questions on my end. On the NII remarks, you talked about deposits. I was hoping you could help frame what 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, Chief Financial Officer (CFO)

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

Steven Chubak, Analyst (Wolfe Research)

Okay. And just one quick one on the tax-advantaged investments. Given the long duration and the potential fourfold increase in capital requirement, are you still planning to fund tax-advantaged investments on the platform before the rules are finalized? Or are you going to take a wait-and-see approach?

Alastair Borthwick, Chief Financial Officer (CFO)

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 until there's a change, we'll continue to support the clients in that regard.

Steven Chubak, Analyst (Wolfe Research)

Understood. Thanks so much for taking my questions.

Operator, Operator

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

Matt O'Connor, Analyst (Deutsche Bank)

Hi, good morning. First, just to clarify, what's driving the drop in net interest income from 3Q to 4Q? Is that core net interest income? Or is that on the market side?

Alastair Borthwick, Chief Financial Officer (CFO)

You're talking about the fact that we think we're going to be around $14 billion in Q4. I'd say first is there's a little bit of deposit pricing lag there. Second, we're baking in some continued normalization of Consumer balances; they're continuing to drift slowly lower. Third, we hoped for loan growth in Q3 but just didn't see that, so that'll flow through with lower loan growth balances in Q4. And finally, Global Markets NII may not repeat in quite the same way; some of that depends on client behavior. They benefited this particular quarter by long-term rates moving up significantly which helped. So it's all those things and timing. Importantly, it hasn't changed from our expectation a quarter ago in any way.

Matt O'Connor, Analyst (Deutsche Bank)

That's helpful. Conceptually, if we get higher-for-longer rates with no cuts, is that good or bad versus the guidance you gave? I realize there are puts and takes with reinvestment on the asset side and deposit pricing, so what's the net?

Alastair Borthwick, Chief Financial Officer (CFO)

Higher-for-longer is going to be better. If the forward curve doesn't turn out to be cuts, we'd expect NII would be higher.

Matt O'Connor, Analyst (Deutsche Bank)

And that's simply because your assets would reprice more than your funding costs or is there more to it?

Alastair Borthwick, Chief Financial Officer (CFO)

It will be both: the repricing plus capture of margin from any short-term rate hike.

Matt O'Connor, Analyst (Deutsche Bank)

Okay, thanks.

Operator, Operator

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

John McDonald, Analyst (Autonomous Research)

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, Chief Financial Officer (CFO)

You can see the trajectory laid out on the slides. Most of the net charge-off increase over time has been due to card and consumer card. Charge-offs at this point are still lower than in 4Q19, which was a stellar period. I'd anticipate in the short term that you'd continue that trend. Net charge-offs normally follow 90-day past-due delinquencies, and those are up slightly versus the prior quarter, so we're inching closer to the fourth quarter of '19. At some point that'll stabilize. From there, it's economic dependent. On the commercial side, asset quality has been excellent. The only elevated concern is office, a very small part of the portfolio — less than 2% of loans. The commercial side overall has been terrific, but it will depend on how the economy plays out: soft landing, recession, or robust growth.

Brian Moynihan, Chief Executive Officer (CEO)

John, one thing I'd add: we have a strong, disciplined rating capability. We push reviews quickly, put things on criticized lists and manage reserves conservatively. Because of our ratings integrity, a lot of the adjustments in CRE and office have been through the system already. That holds us well. Charge-offs are already starting to decline.

John McDonald, Analyst (Autonomous Research)

Got it. And one bigger picture question: does a 15% ROTCE feel like a good aspiration for the company through the cycle? I realize that's where you are today, but factoring in potential new rules, anything to add?

Brian Moynihan, Chief Executive Officer (CEO)

We're doing that on $194 billion of capital today. You might need roughly $10 billion more to put a buffer to the end-state requirement absent mitigation, which would modestly affect ROTCE. But we're earning that amount of capital today, so it's not like it's an impossible task to maintain strong returns. There will be mitigation actions and likely some rule modifications. So while the rules could create a slight dilution, it's manageable, and we believe we can address it.

Operator, Operator

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

Vivek Juneja, Analyst (JPMorgan)

Alastair, question to clarify your NII comment: if rates stay higher or better, are you implying rate cuts would therefore be negative for you from an NII standpoint?

Alastair Borthwick, Chief Financial Officer (CFO)

Yes. If you think about what rate cuts look like in the back half of next year, in the absence of those cuts we'd likely guide NII higher. That's what I'm communicating.

Vivek Juneja, Analyst (JPMorgan)

Is that because many of your assets are floating rate and would reprice faster than you can cut funding costs?

Alastair Borthwick, Chief Financial Officer (CFO)

On the way down, we'd anticipate cuts would reduce our margin on deposit spreads. Essentially that's the dynamic.

Vivek Juneja, Analyst (JPMorgan)

Okay, thanks.

Operator, Operator

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

Ken Usdin, Analyst (Jefferies)

Just a follow-up on the available-for-sale side: how much of that $180 billion is still swapped? And can you help us understand the all-in yield on that book? Would you still have repricing help going forward on that book as well as the HTM maturities?

Alastair Borthwick, Chief Financial Officer (CFO)

Most of the available-for-sale book is swapped to floating. You can think of most of it repricing every day or every week. There are a few fixed-rate securities, but very little in the total composition.

Ken Usdin, Analyst (Jefferies)

That helps, thank you. Also, great job on Investment Bank and trading in a tough environment. Just your thoughts on reopening in the markets and expectations going forward.

Alastair Borthwick, Chief Financial Officer (CFO)

Investment banking has the potential for swings. What's interesting is this has been a period where fees are in a range around $1.1 billion to $1.2 billion per quarter, and normally you'd expect a return within a year or so; we're now several quarters into it. We have a good pipeline. Corporate and C-suite executives are looking for macroeconomic and geopolitical certainty. For as long as volatility persists, it'll stay in this range. If conditions normalize, investment banking can come back quickly to a more historical range.

Brian Moynihan, Chief Executive Officer (CEO)

Ken, one more point: Matthew and the team have done a good job building capabilities to serve our middle market and commercial banking clients. That's a market where we're relatively unpenetrated and it's generating better performance for us than others in terms of holding position flat in a down market. We doubled the size of that team and will expand further.

Ken Usdin, Analyst (Jefferies)

Got it. Thanks for the color.

Operator, Operator

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

Manan Gosalia, Analyst (Morgan Stanley)

Hi, good morning. My question is around deposit growth and what level of deposit growth you think you need from here. Should it be in line with loan growth? Or are you happy to let some of the more non-transaction deposits run off? Some peers are saying there's more room for consumer deposits to reprice higher, especially core checking accounts. It sort of sounds like you disagree with that. How much might you need to respond if competitors act differently?

Brian Moynihan, Chief Executive Officer (CEO)

A few points. We have a $1.9 trillion deposit base and about $1 trillion loans, so a large deposit base. In Global Banking we've been relatively flat and starting to grow; those deposits are transactionally used. In Wealth Management much of the shift was into higher-rate instruments like treasuries and money market funds. On the consumer side there are a few dynamics: middle-income households are seeing some slow spend down, though they still have multiples of pre-pandemic account balances. Higher-income customers moved money into the market and some balances are below pandemic levels as a result. We think about deposits as transactional cash versus investment cash. Investment cash has largely been reallocated. Transactional cash holds because it's money in motion. Our Consumer business has about $500 billion in checking balances with some modest cushion balances in money markets. Those transactional balances tend to be stickier. We'll watch consumer deposits carefully, but the organic growth engine remains strong across checking, cards, investments and small business accounts.

Manan Gosalia, Analyst (Morgan Stanley)

So in terms of deposit growth from here, would you prefer to grow deposits in line with loans, or is there room for deposit growth to come down?

Brian Moynihan, Chief Executive Officer (CEO)

We prefer to grow deposits in line with customer growth and activity. Over the last four quarters we added roughly 900,000 net new checking accounts. These are transactional relationships that grow with customer activity, and that's our focus.

Manan Gosalia, Analyst (Morgan Stanley)

Appreciate it. Thank you.

Operator, Operator

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

Chris Kotowski, Analyst (Oppenheimer)

Good morning. Looking at the average balance sheet in the supplement, the overall yield on earning assets was up 20 basis points and the yield on interest-bearing liabilities was also up 20 basis points. Was there some unusual benefit, like lower amortization, or is it just a function of balances and mix? It seemed notable how they moved in tandem.

Alastair Borthwick, Chief Financial Officer (CFO)

I don't think there's an amortization issue. It's the way the entire balance sheet works across assets and liabilities with all the moving pieces. Nothing particularly notable beyond that.

Chris Kotowski, Analyst (Oppenheimer)

Okay, that's it for me. Thank you.

Operator, Operator

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

Vivek Juneja, Analyst (JPMorgan)

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

Brian Moynihan, Chief Executive Officer (CEO)

If you think about constraints, equity financing is not RWA intensive; it's asset-size intensive. Given our supplemental leverage ratio and where we sit well over requirements, we have room on asset size if clients need more capacity. Returns in that business are strong. We've increased the balance sheet by over $200 billion largely due to financing activity, particularly equities, and we can continue to support client needs.

Alastair Borthwick, Chief Financial Officer (CFO)

In terms of the NII guidance, Global Markets is included as part of the diversified portfolio. Global Markets remains liability sensitive and will perform according to the rate curve. We might put a modest balance sheet growth in there to continue investing in the business, but it's included in the NII guidance and will follow the forward curve.

Vivek Juneja, Analyst (JPMorgan)

Thank you.

Brian Moynihan, Chief Executive Officer (CEO)

Well, thank you for joining us. Just in closing, a few key points: strong earnings for the company, earnings growth year-over-year for the three months and nine months in double digits; returns of 15% return on tangible 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 strong capital to shareholders. 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, Operator

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