Brian Moynihan

Identity and role

Brian Moynihan is chair of the board and chief executive officer of Bank of America. During the pandemic the bank made PPP loans and distributed state unemployment benefits on prepaid debit cards. Its handling of those cards drew penalty orders from two federal regulators in July 2022.

Biography / career arc

Moynihan became Bank of America's chief executive on January 1, 2010, the date he gave in his written testimony to the Senate Banking Committee in May 2021. The bank's biography lists him as a member of the Business Roundtable, the Financial Services Forum and the Bank Policy Institute. He is chancellor of the Corporation of Brown University, after eight years on its Board of Fellows and six (2010 to 2016) on its Board of Trustees.

Pandemic-relief / PPP-EIDL role

Moynihan testified that Bank of America began taking PPP applications in early April 2020, the day after the program details were announced, and that it was the first major bank to do so. The bank put more than 3,000 employees on PPP applications by the program's first week.

Judge Stephanie A. Gallagher's April 13, 2020 opinion in Profiles, Inc. v. Bank of America Corp. (D. Md. No. 1:20-cv-00894) sets out the bank's first-round terms: an applicant needed "a Small Business lending and Small Business checking relationship with Bank of America as of February 15, 2020 or a Small Business checking account opened no later than February 15, 2020," and no business credit or borrowing relationship with another bank.

In his May 26, 2021 written testimony, Moynihan described the process as open to "any business client with an existing credit relationship, or a business client that had no credit relationship with Bank of America or another bank." He said the bank "did not prioritize among client applicants" by loan size or "any broader client relationship." By then, he said, it had made PPP loans to nearly 500,000 small businesses for more than $35 billion, with 83% going to businesses with 10 or fewer employees. Dozens of CDFIs working with the bank had made PPP loans to more than 10,000 small businesses in their own communities. He said any net proceeds from PPP fees would go to support small businesses, communities and nonprofits. He also reported more than 43 million federal, state and local stimulus transactions totaling $73 billion.

An undated Bank of America small-business page, as of July 2026, gives different totals: more than 343,000 small-business clients and more than $25 billion in PPP funds. It says the SBA reported the bank as the largest PPP provider by number of approved loans.

Their own relief

Neither the SBA's public PPP loan-level data (September 30, 2024 release) nor the USAspending COVID-EIDL award files we searched list a loan to a borrower named Brian Moynihan. In the PPP data, Bank of America, National Association appears as a lender.

Legal status / controversies

Profiles, Inc. v. Bank of America Corp. Profiles, a Baltimore business, filed a class-action complaint against Bank of America Corporation on April 3, 2020 over the relationship rule. Judge Gallagher denied a temporary restraining order and preliminary injunction on April 13. The plaintiffs took an interlocutory appeal to the Fourth Circuit, and on April 17 she denied their motion for a stay pending that appeal.

Modern Perfection, LLC v. Bank of America, N.A. Six small businesses sued in 2022 (D. Md. No. 1:22-cv-02103) with breach-of-contract, fraud and other state-law claims over the bank's marketing and administration of its PPP loan program. Their PPP promissory notes had no arbitration clause, but their deposit agreements did. District Judge Lydia Kay Griggsby compelled arbitration and dismissed the complaint. On January 13, 2025 the Fourth Circuit affirmed (No. 23-1965) in an opinion by Judge Heytens, joined by Judges Harris and Berner. The courts held that the deposit agreements sent the question of arbitrability to an arbitrator; neither court ruled on the businesses' claims.

Unemployment-benefit cards. On July 14, 2022 the Office of the Comptroller of the Currency imposed a $125 million civil money penalty on Bank of America, N.A., and the Consumer Financial Protection Bureau ordered a $100 million penalty. The OCC found, and the bank neither admitted nor denied, that cards loaded with unemployment benefits grew from under 1 million in January 2020 to over 6 million in July 2020, and that between September 28, 2020 and June 8, 2021 the bank used an automated "Fraud Filter" to deny unauthorized-transaction claims and freeze card accounts "without conducting a sufficient investigation." Moynihan's name is on the OCC order's signature block for the bank's board.

None of these matters named Moynihan as a party.

Where they are now (2025–2026)

Bank of America's newsroom biography, as of July 2026, lists Moynihan as chair of the board and chief executive officer, leading more than 210,000 employees. It also lists him as chair of The Clearing House Association and of the Sustainable Markets Initiative.

Sources held in this archive

The PPP Cast, as Seen by the FEC
Why the PPP Lender Table Flipped
Big Banks and the PPP Priority Line
The Customer List Was the Product

Charlie Scharf — Wells Fargo CEO, whose Fed asset cap was eased so the bank could expand PPP lending.
Doug McMillon — Walmart president and CEO from February 2014 through January 2026; served on the Business Roundtable board.