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Vic Chen
Vic Chen

Posted on • Originally published at 13finsight.com

Bank of America's $1.37T Portfolio Has 28,105 Positions — And Vanguard ETFs Are the Foundation

Bank of America's Q4 2025 13F reveals $1.37 trillion across 28,105 positions. The architecture: Vanguard ETFs (VTV at $26B, VUG at $23.4B, IEFA at $20.4B) serve as the portfolio's structural foundation, with individual mega-cap stocks layered on top.

This is what institutional-scale portfolio construction looks like when you're managing money for millions of clients.

The numbers

Metric Value
13F AUM $1.37 trillion
Position count 28,105
Top ETF: VTV (Vanguard Value) $26.0B (1.9% weight)
#2 ETF: VUG (Vanguard Growth) $23.4B (1.7%)
#3 ETF: IEFA (iShares Int'l) $20.4B (1.5%)
Top stocks MSFT, NVDA, AAPL

The Vanguard ETF fortress

BofA's wealth management platform uses Vanguard ETFs as the core allocation framework:

VTV (Vanguard Value ETF) — $26B

The largest single position. VTV tracks U.S. large-cap value stocks. At $26B, this is BofA telling its millions of Merrill Lynch clients: "Value is the core."

VUG (Vanguard Growth ETF) — $23.4B

The growth complement to VTV. Together, VTV + VUG = $49.4B in a simple value/growth barbell. This is the most basic asset allocation framework: split between value and growth, adjust the ratio based on market outlook.

IEFA (iShares Core MSCI EAFE) — $20.4B

International developed markets (Europe, Australia, Far East). At $20.4B, BofA is giving clients meaningful international diversification — roughly 1.5% of the total portfolio.

The architecture pattern

Layer 1 (Foundation): VTV + VUG + IEFA = ~$70B core allocation
Layer 2 (Mega-cap overlay): MSFT, NVDA, AAPL = individual conviction
Layer 3 (Satellite): 28,000+ positions for breadth and customization
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Why 28,105 positions?

BofA's position count is among the highest in the 13F database. The reason: aggregation across multiple business lines.

Business line Typical contribution Position characteristics
Merrill Lynch wealth management Thousands of model portfolio positions ETF-heavy, standardized
Private banking (ultra-HNW) Hundreds of custom positions Individual stocks, concentrated
Institutional trading desk Thousands of hedging positions Short-term, flow-driven
Bank investment portfolio Hundreds of positions Conservative, income-focused

The 28,105 positions are the sum of all these business lines. No single person manages all 28,105 — they're the aggregate of a financial institution with millions of client relationships.

What the VTV > VUG tilt signals

VTV ($26B) is larger than VUG ($23.4B). The value tilt (~53/47 value-to-growth) suggests:

  • BofA's model portfolios are slightly value-overweight
  • After years of growth dominance, the wealth management recommendation is tilting defensive
  • Or: value clients tend to have larger accounts (higher AUM per position)

Tracking the VTV/VUG ratio over time would reveal BofA's house view on value vs. growth.

Bank vs. asset manager 13F: the key difference

Compare BofA's 13F to a pure asset manager:

Dimension BofA ($1.37T bank) Dodge & Cox ($185B asset mgr)
Positions 28,105 222
ETF weight High (VTV, VUG, IEFA) ~0%
Top holding type ETFs Individual stocks
Signal per position Very low High
Useful for Understanding platform-level allocation Individual stock research

BofA's 13F tells you about wealth management trends. Dodge & Cox's tells you about stock picks. Both are valuable — for different questions.

What to watch in BofA's 13F

ETF ratio shifts

  • VTV/VUG ratio changing = value/growth rotation at Merrill Lynch
  • IEFA weight changing = international allocation shifting
  • New ETF appearances = thematic or sector bets being added to models

Individual stock additions

  • When a stock like NFLX jumps 831% (previous article), it's a model portfolio event
  • Large new individual stock positions = research-driven additions to the platform

Position count trends

  • Growing count = more customization, possibly more clients
  • Shrinking count = consolidation, possibly simplifying models

Originally published at 13F Insight

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