Too Big To Fail banks aren’t known to be activist investors’ favorite targets, which is why I was shocked to hear that there’s some nascent chatter in activist circles that the nation’s second largest bank, Bank of America, could be on the so-called target list. 

The bearish-thinking goes that if big banks fail, the entire US economy will crash – which means they’ve been largely off limits to activists looking to exert boardroom change. 

But that doesn’t mean under the right circumstances, an activist play against a big bank is impossible, particularly if conditions meet something like a financial perfect storm, which brings us to the underperforming BofA run by its underwhelming CEO Brian Moynihan.

Here’s what the activist chatter is saying: The bank’s five-year chart of the stock is weak; of all the big banks it only beats Citigroup, the perennial basket case in stock performance, and Wells Fargo, and just barely in that case even though Wells was crushed by the fake account scandal and hyper-government regulation.

But Wells has a new CEO, Charlie Scharf, a JPM-Jamie Dimon protege, who is fixing things up enough that its stock has appreciated about twice as much as the S&P over the past year. CEO Jane Fraser is rebuilding Citi, slimming down non-core businesses and hiring some smart people to key positions. 

Meanwhile, Moynihan seems to be doing much of nothing. There are no big new hires, his inability to use his massive balance sheet is costing the bank deals, and he thinks he deserves to stick around for five more years until he’s 70.

A spokesperson for the bank noted that its stock increased by more than 60% over the last year.

“Bank of America is one of just four US companies to earn more than $15 billion a year in each of the last nine years,” the rep added.

Nonetheless, I’m hearing some activists are looking at the stock and thinking they can get a decent bounce if they can get Moynihan bounced – or at least get him to announce an earlier-than-expected retirement date.

Stay tuned.

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