As part of such disclosures, Bank of America made the statement copied below "Operational Risk". Such statement is alleged as fraud. 
See also "Read" notices by Brian Moynihan on letters reliably informing him on fraud in Bank of America operations:
http://www.scribd.com/doc/32312304/
09-12-20-Read-Notices-by-Brian-Moynihan-on-messages-informing-him-on-conduct-that-is-claimed-as-subject-to-reporting-duties-s

7. Operational Risk
Operational Risk is the risk of loss resulting from inadequate or failed internal processes, people and systems, or
from external events.
The Bank takes a comprehensive approach to risk management. Risk planning is integrated with strategic, financial,
customer and associate planning so that goals and responsibilities are aligned across the Bank. Risk is managed in a
systematic manner by focusing on the bank as a whole and managing risk across all operations. This approach
requires each associate and line of business to be engaged and work as a team in the risk management process.
The foundation of the Bank’s risk governance is individual accountability. Identifying and managing risk and reward
is every associate’s job. Compliance is at the core of the Bank’s cultural values and is a key component of the Bank’s
risk management discipline. This culture of accountability and compliance requires that all associates comply with
all relevant laws, regulations, ethical standards and internal policies and procedures.
The Board is responsible for overseeing the Bank’s governance framework and ensuring that appropriate policies
have been implemented to manage operational risk. Senior business executives in conjunction with chief compliance
and risk management executives are responsible for development policies, processes, procedures and risk
management framework on a bank-wide basis, as well as for directing, reviewing and approving specific business
line-area operational risk policies. Operational and Compliance Risk Management working in conjunction with
senior business executives have developed tools and appropriate methodologies to help manage and monitor risk.
Business unit managers and associates in conjunction with risk managers are responsible for identifying, measuring,
mitigating and monitoring all operational risks in each business area, both existing and emerging. They also ensure
that unit-specific policies, procedures and staff are effective and sufficient to manage operational risk and that
business controls are consistent with company-wide requirements.
The Bank’s measurement processes include a variety of measures, tools, processes and methodologies both
quantitative and qualitative in nature. These risk measures assess the likelihood, impact and detectability, and other
criteria on both inherent and residual risk basis. These indicators and tools provide assessment and direction of risk
and potential changes.
Operational and compliance risk reporting exists at a number of levels from the Board, executive and senior
management, line of business management and Legal, Compliance, Risk, Technology, Human Resources and other
support partners. The type and frequency of operational and compliance risk reporting vary depending on the risk.
Loss event data is captured monthly through bank-wide operational loss event process and is reported to the Board
and senior management on a quarterly basis. Operational risk event types captured include; internal fraud, external
fraud, employment practices / workplace safety, clients products and business practices, damage to physical assets,
business interruption / system failures and execution, delivery and process management. Comprehensive information
about these types of risk events is collected by operational risk management and includes data regarding amount,
occurrence, discovery date, business area, root cause analysis, risk drivers. Analysis of operational risk event data
helps us to understand our risks, provide historical perspective of our risk experi

09-12-31 Bank of America MBNA Canada Bank II Basel Pillar III Disclosure-s PDF

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