Bank of America's $1.375T Q4 Filing: SPY Cut in Half, NVIDIA Trimmed 22%, and $26B in Vanguard ETFs Nobody Talks About

Bank of America's Q4 2025 13F filing is the last piece of the megabank puzzle. We've already dissected JPMorgan's $1.59 trillion, Morgan Stanley's $1.68 trillion, and Goldman Sachs' $811 billion. Now we can see what Bank of America — the second-largest U.S. bank by assets — does with $1.375 trillion in client equity holdings.

The answer is surprisingly distinct from its peers. Where JPMorgan concentrates in individual mega-cap stocks and Goldman leans into high-conviction active positions, Bank of America has built a portfolio that looks more like a wealth management platform than a trading operation. And the data proves it.

The Most Diversified Megabank Filing

At 12.9% top-5 concentration, Bank of America has the flattest portfolio among the Big Four banks. For comparison:

• JPMorgan Chase: 15.1% top-5 concentration
• Morgan Stanley: 13.8% top-5 concentration
• Goldman Sachs: 17.2% top-5 concentration
• Bank of America: 12.9%

This isn't accidental. Bank of America's 13F includes holdings from Merrill Lynch wealth management, BofA Securities, and the bank's own investment portfolio. Merrill Lynch alone manages over $3.3 trillion in total client assets, making it the largest U.S. wealth management platform. The extreme diversification reflects thousands of individual Merrill client accounts aggregated into one filing — not a concentrated investment thesis.

28,105 Positions: The Merrill Lynch Fingerprint

With 28,105 distinct positions, Bank of America files more line items than JPMorgan's 31,783 but in a comparable range. What distinguishes BofA is the composition. The top 15 holdings include not just individual stocks but a massive allocation to Vanguard ETFs and iShares products that signal Merrill Lynch's model portfolio construction.

Here's what stands out in the top 15:

• Microsoft #1 at $35.4B (2.57%) — narrowly edging NVIDIA for the top spot
• NVIDIA #2 at $34.9B (2.54%) — after a brutal 22% share reduction
• Apple #3 at $33.6B (2.44%) — also trimmed 13.2%
• VTV (Vanguard Value) #4 at $26.0B (1.89%) — this is Merrill's model portfolio at work
• VUG (Vanguard Growth) #5 at $23.4B (1.70%) — paired with VTV for style-box allocation

The VTV + VUG pairing is the tell. No hedge fund or trading desk puts $49 billion into Vanguard style-box ETFs. That's wealth management — Merrill's advisors allocating client portfolios across growth and value factors using low-cost index products.

The $24 Billion SPY Reduction

The single largest move in Bank of America's Q4 filing was cutting its SPY position by 54.8% — from $45.4 billion to $21.0 billion, a reduction of roughly $24.4 billion in notional value. This was the largest SPY drawdown of any megabank filer we've tracked this quarter.

But the context matters. BofA simultaneously increased its IVV (iShares Core S&P 500) position by 27.7%, adding $3.5 billion. It also grew its VOO (Vanguard S&P 500) stake by 4.4%. The net move: rotating from SPY into cheaper S&P 500 alternatives. SPY charges 9.45 basis points; VOO charges 3 basis points; IVV charges 3 basis points. On $45 billion in AUM, that fee difference saves clients over $28 million annually.

This is Merrill Lynch optimizing fee drag at scale — a pure wealth management move with zero alpha implications.

NVIDIA Trimmed 22%, But Not the Way You Think

Bank of America cut its NVIDIA position by 22% in Q4, reducing from 240 million shares to 187 million. That's a $10 billion reduction in value terms. Combined with the 13.2% cut to Apple and 5.8% trim to Microsoft, the megacap tech rebalance was aggressive.

But here's the nuance: BofA still holds $35 billion in NVIDIA, making it the second-largest megabank holder of the stock after Morgan Stanley. The trim looks like systematic rebalancing — trimming a position that had grown from ~2% to potentially 3%+ of the portfolio through appreciation, back down to the 2.5% target. Merrill's model portfolios likely have sector and position limits that trigger automatic rebalancing.

This pattern matches what we've seen across multiple megabank filers in Q4: the "trim winners, reallocate to value and international" playbook that suggests coordinated risk management across wealth platforms.

The Alphabet Build — BofA Joins the Consensus

Despite trimming NVIDIA, Apple, and Microsoft, Bank of America was a net buyer of Alphabet (GOOGL). The share count decreased by 7.9%, but the combined GOOGL + GOOG position still rose in value due to price appreciation. More importantly, the proportional weight of Alphabet within the portfolio increased.

This matches the cross-filer pattern we've documented extensively. Every major institutional filer we've analyzed — from Fidelity to Northern Trust to UBS — increased their Alphabet allocation in Q4 2025. It's the most unanimous institutional consensus trade of the quarter.

The International Allocation No One Else Has

The most distinctive feature of Bank of America's portfolio versus its megabank peers is the heavy international ETF weighting:

• IEFA (iShares Core MSCI EAFE) at $20.4B — 8th largest position, up 1.3% QoQ
• VEA (Vanguard FTSE Developed Markets) at $12.9B — 15th largest, up 2.1%
• IEMG (iShares Core MSCI EM) likely present further down the list

JPMorgan and Goldman Sachs don't carry this kind of international ETF exposure in their top 20. It's another Merrill Lynch signature: financial advisors building globally diversified portfolios for individual clients who need international equity exposure but don't want to pick individual foreign stocks.

How BofA Compares to the Other Megabanks

With all four megabank 13F filings now analyzed, a clear hierarchy emerges:

• Morgan Stanley ($1.68T): The most traditional wealth management profile — Apple #1, heavy individual stock picks
• JPMorgan Chase ($1.59T): The most concentrated megabank — NVIDIA #1, aggressive Broadcom build
• Bank of America ($1.375T): The most diversified — Vanguard ETF core, heavy international allocation
• Goldman Sachs ($811B): The most active — Tesla in top 5, highest individual stock concentration

Each filing tells you something different about how the bank's clients are positioned. Goldman's clients are more aggressive. Morgan Stanley's are more concentrated in blue chips. JPMorgan's are the most tech-heavy. And BofA's Merrill Lynch clients are the most broadly diversified, with a clear preference for low-cost index products as portfolio building blocks.

What Investors Should Watch

Bank of America's filing is less a signal about any individual stock and more a signal about where $1.375 trillion in U.S. wealth management capital is flowing. The key themes for Q1 2026:

• SPY → VOO/IVV rotation: The fee-optimization trade has room to continue. SPY still holds $21B in the portfolio.
• NVIDIA rebalance: The 22% trim may continue if NVIDIA keeps appreciating, as model portfolio limits kick in again.
• International exposure growing: IEFA and VEA both increased, suggesting Merrill's strategists are tilting global.
• Value/Growth balance: The VTV/VUG pairing grew on both sides — no style rotation, just parallel scaling.

This is a portfolio that moves slowly, deliberately, and with the gravity of a million individual accounts behind it. It's the boring filing, but boring at $1.375 trillion is anything but boring.