Bank of America's $1.37 Trillion Q4 2025 Filing Runs a Vanguard ETF Fortress: VTV, VUG, and IEFA Control the Architecture

Bank of America Corp filed its Q4 2025 13F with $1.37 trillion across 28,105 positions. The most distinctive feature: a Vanguard ETF fortress where VTV (Value), VUG (Growth), and IEFA (International) rank among the top 10 holdings alongside individual mega-cap stocks.

TL;DR

• Total 13F AUM: $1.37 trillion (down 6.7% from $1.47T in Q3)
• Positions: 28,105 (down from 29,308 in Q3)
• Top holding: Microsoft (MSFT) at $35.4B (2.57%)
• Unique feature: VTV ($26.0B), VUG ($23.4B), and IEFA ($20.4B) in top 10
• SPY position: $21.0B at #7
• Key insight: BofA uses Vanguard factor ETFs as the backbone of Merrill Lynch wealth management portfolios
• QoQ decline: -6.7% — one of the few mega-filers to shrink in Q4

The Vanguard ETF Architecture

Bank of America’s top holdings tell a story about Merrill Lynch wealth management construction:

• VTV (Vanguard Value): $26.0B — broad value factor exposure
• VUG (Vanguard Growth): $23.4B — growth factor complement
• IEFA (iShares Core MSCI EAFE): $20.4B — international developed markets
• SPY: $21.0B — S&P 500 core allocation
• VOO: $17.0B (#12) — another S&P 500 vehicle

Combined, these five ETFs represent over $107 billion — roughly 7.8% of the total portfolio. This is the clearest ETF-first wealth management architecture among mega-filers.

Top Holdings

The Q4 Shrinkage

Bank of America is one of the few mega-filers to report a QoQ AUM decline in Q4 2025 (-6.7%, from $1.47T to $1.37T). Possible explanations include client outflows from Merrill Lynch advisory accounts, rebalancing out of equities, or methodological changes in aggregation. The position count also fell by 1,203.

What Analysts Might Misread

“BofA’s top-3 weights are low (2.4-2.6%).” Correct, but that’s because ETFs dilute the individual stock weights. If you strip out ETF holdings, MSFT/NVDA/AAPL weights jump above 3%.

“BofA prefers Microsoft to NVIDIA.” The $500M difference between MSFT ($35.4B) and NVDA ($34.9B) is a rounding error in a $1.37T portfolio. They’re essentially co-#1.

Why does Bank of America hold so many Vanguard ETFs?

Merrill Lynch (BofA’s wealth management arm) uses Vanguard factor ETFs (VTV for value, VUG for growth) and broad market ETFs (SPY, VOO) as building blocks in advisor-managed client portfolios.

Why did Bank of America’s AUM decline in Q4?

The 6.7% QoQ decline from $1.47T to $1.37T may reflect client rebalancing, outflows, or reporting changes. This was one of the few AUM declines among mega-filers in Q4 2025.