DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-81,995

BANK OF AMERICA
INTERNAL RECON CONTROL (IRC)
CORPORATE INFRASTRUCTURE FINANCE DIVISION
SEATTLE, WASHINGTON

Certification Regarding Eligibility
To Apply for Worker Adjustment Assistance

In accordance with Section 223 of the Trade Act of 1974, as
amended ("Act"), 19 U.S.C. § 2273, the Department of Labor herein
presents the results of an investigation regarding certification
of eligibility to apply for worker adjustment assistance.
The group eligibility requirements for workers of a firm
under Section 222(a) of the Act, 19 U.S.C. § 2272(a), are
satisfied if the following criteria are met:
(1) a significant number or proportion of the workers
in such workers' firm have become totally or partially
separated, or are threatened to become totally or
partially separated;
(2)(B)(i)(I) there has been a shift by the workers'
firm to a foreign country in the production of articles
or supply of services like or directly competitive with
those produced/supplied by the workers' firm; OR
(II) there has been an acquisition from a
foreign country by the workers' firm of
articles/services that are like or directly
competitive with those produced/supplied by
the workers' firm; AND
(ii) the shift/acquisition must have contributed
importantly to the workers' separation or
threat of separation.

The investigation was initiated in response to a petition
filed on September 24, 2012 by three workers on behalf of workers
of Bank of America, Internal Recon Control, Corporate
Infrastructure Finance division, Seattle, Washington (Bank of
America). The workers' firm is engaged in activities related to
the supply of internal recon control services.
During the course of the investigation, information was
collected from the workers' firm.
Section 222(a)(1) has been met because a significant number
or proportion of the workers in such workers' firm have become
totally or partially separated, or are threatened to become
totally or partially separated.
Section 222(a)(2)(B) has been met because the workers' firm
has shifted to a foreign country the supply of a service like or
directly competitive with the service supplied by the workers
which contributed importantly to worker group separations at Bank
of America.






Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of Bank of America,
Internal Recon Control, Corporate Infrastructure Finance
division, Seattle, Washington, who are engaged in activities
related to the supply of internal recon control services meet the
worker group certification criteria under Section 222(a) of the
Act, 19 U.S.C. § 2272(a). In accordance with Section 223 of the
Act, 19 U.S.C. § 2273, I make the following certification:
"All workers of Bank of America, Internal Recon Control,
Corporate Infrastructure Finance division, Seattle,
Washington, who became totally or partially separated from
employment on or after September 19, 2011 through two years
from the date of certification, and all workers in the group
threatened with total or partial separation from employment
on the date of certification through two years from the date
of certification, are eligible to apply for adjustment
assistance under Chapter 2 of Title II of the Trade Act of
1974, as amended."
Signed in Washington, D.C., this 26th day of October, 2012.

/s/ Elliott S. Kushner
______________________________
ELLIOTT S. KUSHNER
Certifying Officer, Office of
Trade Adjustment Assistance