Bank of America began permitting its wealth advisers to recommend Bitcoin allocations on Monday, January 5, 2026, rolling the change across Merrill, Bank of America Private Bank, and Merrill Edge. This is a tangible operational shift from “available on request” to a defined, adviser-supported allocation framework.
The bank’s Chief Investment Office approved a controlled advisory approach that limits suggested crypto exposure to a narrow 1%–4% range, implemented through selected U.S.-listed spot Bitcoin ETFs. The design is clearly built to standardize recommendations while keeping portfolio risk tightly capped.
Approved ETFs and the new advisory guardrails
Within that framework, the CIO cleared four spot Bitcoin ETFs for adviser use: Bitwise Bitcoin ETF (BITB), Fidelity Wise Origin Bitcoin Fund (FBTC), Grayscale Bitcoin Mini Trust (BTC), and BlackRock iShares Bitcoin Trust (IBIT). The approved list concentrates flow into a small set of liquid, regulated wrappers rather than opening the door to broad crypto product choice.
Advisers are instructed to recommend allocations within the 1%–4% band across the bank’s private and retail advisory channels, replacing the prior posture where adviser involvement was limited to executing client-initiated crypto orders. That change matters because it formalizes Bitcoin exposure as an allocable sleeve inside the firm’s portfolio-construction process.
Downstream impacts for execution, custody, and controls
For trading desks, treasury teams, and custody providers, the practical effect is more predictable, adviser-driven flow routed through ETF rails rather than direct spot custody. This reduces wallet-level custody complexity but increases operational dependence on ETF market microstructure and broker-dealer plumbing.
With that shift, ETF creation/redemption mechanics, intraday liquidity, spreads, and authorized participant relationships become more central to client outcomes than direct on-chain settlement. Execution quality will increasingly hinge on how efficiently the ETF wrapper can absorb rebalancing demand and market-impact costs.
Compliance and risk teams now have to encode suitability and guardrails around the 1%–4% recommendation range into portfolio engines and onboarding workflows. If the controls layer is not tightly implemented, the policy’s “bounded exposure” intent can break down in day-to-day advisory practice.
Operationally, teams should expect initial activity to concentrate in the approved ETFs, which raises sensitivity to spreads and trading costs during rebalancing windows and adds incremental ticketing, reporting, and reconciliation steps versus conventional equity ETFs. Near-term resilience will depend on whether liquidity, settlement capacity, and compliance tooling scale cleanly with adviser-driven adoption.