The Securities and Exchange Commission brought an administrative action against Bank of America Corporation for misstating the amount of its regulatory capital and ratios in numerous financial reports filed with it from 2009 to 2013. (BofA was required to file such reports with the SEC as a public company.) This error apparently arose in connection with BofA’s acquisition of Merrill Lynch & Co., Inc. at the beginning of 2009. As part of this transaction, BofA acquired a US $52.5 billion portfolio of various Merrill-issued financial instruments. Although BofA recorded the value of these instruments at less than face value—owing to, at the time, the decline in Merrill’s creditworthiness—BofA had to redeem these instruments at face value as they matured or when BofA otherwise acquired them. However, during the relevant time, BofA failed to reflect as realized losses—and thus reductions in its regulatory capital—the negative differences between the discounted value of these Merrill securities and the amount it had to pay to redeem them. As a result, the firm overstated its regulatory capital and ratios on internal records and in filings with the SEC. According to the SEC, BofA self-detected its mistake during April 2014, issued a press release revising its regulatory capital amounts and ratios, and filed an amendment with the SEC correcting its most recently filed financial report. BofA agreed to pay a fine of US $7.65 million to resolve this matter. The SEC charged BofA with violating its requirement that public companies “make and keep books, records, and accounts which, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the issuer” and to maintain adequate internal accounting controls.