You want me to come up?
Yeah.
I didn't know what you were doing.
Okay.
If everybody could take their seats, we are going to get started with what is going to be the final presentation at this conference. I do think we have kept the best till last. So, Brian, thank you very, very much for joining us. It is actually the 16th consecutive year. You know, that is definitely a record, so thank you very, very much.
You don't look any older.
I look exactly the same as I did 16 years ago, so do you. You actually look younger. Anyway, so let's start off with just your take on the macroeconomic backdrop. We've obviously just had the Fed just came out, but I'm curious about how you're thinking about the path for the economy next year, what you're seeing in terms of consumer and corporate engagement heading into 2026, and I think you have some of the best spending data, and I think you do some of the best analytics around it. What have you seen over the fourth quarter, and what does that tell you about the outlook for next year?
Well, so thanks, Rich, for having me. The first thing is, our team had the Fed cutting rates today, so I guess they got that one right. Yeah, I think there's a little surprise about the dot plots and what happens next year. But if you look at, you know, our team has the economy in the U.S. growing 2.4% or so next year. That from this time last year to now isn't a lot changed, but in between, they dropped 100 basis points off the growth rate, Liberation Day, all that stuff, and then put it back. And so you kind of got around this trip. I think the certainty that passed forward from six months ago to now is higher because the trade and tariff has largely worked through the system in terms of people's understanding of what will happen. I think taxes is done.
So I think, you know, immigration, deregulation are the issues that are still working through. And I think business looks at that and says, "I've got some basics right now. I can invest." They're still worried about making sure the immigration gets settled down so they have the workforce they need to do their work, is what the clients tell us all over the country, and our small business surveys show that labor availability is becoming a bigger issue. It was that a few years ago, then inflation, and now it's back to that. And that's just if you're a lot of the services-related business or construction business or things like that, getting workers. Our consumers in the month of November, across all different things. So Liz Everett was on CNBC today. She talks about the credit and debit card because they can track that most carefully.
But if you look across the whole platform, that's about 20-25% of the money movement. If you look across the whole platform in a year, it's about $4.5 trillion -$5 trillion, 70 million consumers putting money in the economy. That is up 4.3% November this year versus November last year. If you think of that in a historical context, that's consistent with the 2%+ growth rate in the economy. The way they're spending the money has a little bit of the elements of the K-shaped economy to it, not as much as people think if you actually watch what's happened over the last few months in three terciles. The bottom tercile has been growing at a slower rate, still growing. The top tercile is growing at a faster rate. It's been keeping that rate.
It's the middle one that's moved more, a little bit less to the higher growth rate of the upper end and above the lower. And that, that's just a recent phenomenon. So that number was 5% in October, 4%, 4.5% in November. But I wouldn't overly read into a half a percent movement because weekends, how the calendar works, can affect all that. So consumers are in good shape. Our credit quality improved in the quarter, last quarter. It's still there. It's good. Small businesses are fine. They're making money. Middle-sized companies, credit quality is strong. They're still using their lines at a lesser rate than they did pre-pandemic. And, you know, that, that's probably an indication of, you know, it costs more, honestly. The biggest beneficiary of a lower Fed funds rate is a lower SOFR rate and therefore a lower rate for middle market and small business borrowers.
It's counterintuitive to the consumer because the mortgages are locked in. It's really more beneficial to that group, so we'll see if they start using our lines a little more aggressively, but they're all fine. Credit quality is good, so we're very constructive, and in the capital market side, all of you participate in that, I think, as you look, we think it's a constructive time and deals are getting done and, you know, people are out there bidding on stuff. It's all pretty good. The derailments are all the existential issues you can have: kinetic wars, rate structure not good, people not getting the Fed rate path right, or the Fed not getting it right, hyperinflation, all those debt and all that stuff, but over in 2026, we see in pretty good shape.
Just from a consumer balance sheet standpoint, anything to note in terms of normalization of cash levels, you know, and how that looks relative to history?
Three years ago, people stood up and said they're going to spend all their money and they're going to be out of money. If you take the cohort of customers from early 2020 and look at them six years later, almost six years later now, they still have a lot more money in their accounts, except for the highest balances from that time, like more than $250,000 in there. They've moved the money into money market funds and stuff. Everybody else is up somewhere between a multiple two and a multiple three. Now, remember, across six years, people get job promotions and stuff. So you've got to be, there should be a natural progression to all that. And cash inflation went up. But there's no indication. If you look year- over- year at the account balance, the consumer will continue to push forward.
There's really they're not spending the money down. The credit quality is good. The FICOs and the portfolios are very strong, like you'd expect. Then, you know, the housing is going to be slow just because of rate structure. But that's not a credit quality and it's not an issue for the consumers that are locked in the mortgages. They're in good shape.
Okay. So you just had the investor day. I think it was a month, pretty much a month ago, right? Just over a month ago. You set out both broader targets for the firm. You gave a very significant number of KPIs by business. From your perspective, what are the two or three main points coming out of the investor day that you want to reiterate? But the other thing I wanted to ask is, I know you've spent time with investors since the investor day. What do you think is most underappreciated in terms of the message that you wanted to get across?
So I'd start from the point was to say we have an organic growth engine, which has a competitive position. And around that competitive position, there's some serious moats that are hard to people to discern in sort of the day-to-day flow of the world. And it's been growing organically. And with all the things on an interest income, you'll see it even grow faster from an earnings perspective. So we came off a quarter with EPS was up 30%. Operating leverage was 600 basis points, you know, et cetera, et cetera. Revenue growth 10%. Expense growth 4%. You know, you came off a good quarter and you said, "This is because of all the work we've done, organically grown this franchise and the product quality, et cetera." We want to make that message understood. That's number one.
The competitive moats by showing how much the technology spend, the complexity of running a markets business on a global basis with 50 regulators, those types of things. We want to make sure people saw that, and then they saw where we had unique programs that we could grow. Our employee banking investments program, our local markets capabilities, the way businesses work together, our international capabilities, which is critical to the middle market business, United States nowadays, and even business banking, which is $50 million revenue companies and under. Those three ideas, organic growth engine, already doing it, returns increasing, efficiency increasing because the NII kicks in. That was it.
That's what the investors see and say, "We got it." You know, we probably talked to investors a whole 25 or 30% of the stock since then because we have a routine that we go through every fall with all of them.
Okay. So the plan does incorporate a significant pickup in growth rates and market shares in a number of businesses. So a couple of questions here. I mean, the first is, do you feel the current distribution footprint and platforms are set up for the growth from here? And then secondly, look, a lot of your peers do seem to be leaning into growth. Obviously, one of your peers announced a step up in terms of strategic and investment spend yesterday. Can you talk a little bit about the competitive environment, what you've seen in the competitive environment so far this year, and how you're expecting that to unfold next year?
Right. So if you look at, you know, the market share of consumer banking, we have grown that consistently. But the difference between us and others is we've grown primary checking account deposit holds for the mass market consumer. That's a place where you're going to be in the middle of the finances and the household and where you're going to make the most money. And so the $950 billion in balances they have is a substantial part of the total rate paid, in 50-odd basis points or 60 basis points. I mean, you know, that's because the mix of deposits is all core. Average deposit in our checking accounts is 9,000 industries for a year . You know, that difference is immeasurably different. And that's because we're not just trying to sell things. We're trying to sell stuff that sticks to the ribs.
And so we had a time in this company when we sold 10 million checking accounts a year, and we grew a million checking accounts. Today we sell four and grow a million primary checking accounts. Think about the difference in terms of the amount of work that goes on for those two dynamics. And so that just kept kicking, 27 straight quarters of growth. So those types of investments in organic growth are there. And the organic growth in commercial, we're up 8% year- over- year. The market was up half that or something. You know, we're seeing the numbers of what we call logos of clients we had in the mid-size business, the 50 new bankers we put to work across the private banking.
I'd say Wealth Management, we pointed out to the group that we need to, we've taken them out of the recruiting, of experienced advisors for a bunch of years just because the economics weren't there. We've now gone back into that to where we need advisors plus the training program. So that's probably the most aggressive, you know, Eric and Lindsay put the most aggressive targets on the table from going from 2% to 3% in net new assets to, you know, 4%. And they're working at it. They got the plans. Everybody else, frankly, what people saw as growth rates were just a compounding of all the work they've done and really a continuation of the growth they've been seeing. Global Markets, we invest a lot, $500 billion, $400 billion, $300-$400 billion in balance sheet letting the G-SIB move up because that's what it's required.
Jim and the team have done a good job. So, the place is growing organically now. We just got to keep hammering home. And the investment rate is interesting, and we can talk more about that when we talk about expenses because if you're going to talk about expenses,
we'll talk about expenses
because what we've been able to do for a number of years is consistently take money out of stuff we didn't want to do and put it in this stuff we want to do. And that number is staggering. And that's what we tried to show that in slide Investor Day showed 285,000 people coming down to 203,000 people. And we were setting up two points. When you go from that period of time to now, we added 4,000 more coders.
We've added 2,000 more client-facing people in the correlation business and the American business. We had another 1,000 people in the markets business. We added, yes, we've been adding people all over the world to support that. Meanwhile, the headcount has been basically flattish since 2022. You know, went low point at maybe 208, high point at 216, but basically last three years, 213.1, 212.9, 213.1, and 213.1. Meanwhile, you're putting tons of people in and you're taking people off the back end of the process. What AI gives is different. That gives us a chance to attack a different group of people. The point of that slide was of the 80,000 people that came out, 80,000 came out of retail and operations. That's not really, that will do that, but there's only 50,000 people left in retail. So there's only so much you can go.
What you're really going to do is take it out of places you haven't been able to do.
Yeah. And then on the competitive environment, I mean, what have you actually seen and what are you expecting? And then I guess, look, added to that, obviously regional bank consolidation is obviously a big theme. Is that an opportunity for you because those organizations become inward-focused as the integrator or is it a threat because they actually have more scale? How do you think about that?
So a couple of things. One, when stuff goes on, people have to switch banks, switch names of banks, the client base turns, and that's an opportunity for us. How do we know that we did it? Literally, if you go back in the history of company, almost probably you can count up a 1,000 of them. So this is not new to us. We've been on the other side of the trade. We know what happens. So we do. The second is talent comes to us because if you're covering client, middle market companies in the market, I'm covering middle market companies and we're two competitors merging. Chances of us having an overlap are high. So we don't need two of us to do it. And then talent comes available. So we go in and take advantage of that. Will that consolidation continue? Absolutely.
We run our consumer business at, you know, at a cost of goods sold, which you take the cost we pay on deposits plus all the operating costs of all the platforms, you know, get into 150 or whatever it is today. You know, that is several 100 basis points off a lot of the competitors. That allows you to have low fee structures, allows churn to not take place, allows you to invest in a competitive advantage. And that's, that's what you're doing. As NII picks up that business, we'll go from earning X to almost double X in the next few years. So that, that's going on. Mid-market space, we'll take advantage. It has to keep happening because as much as people debate about scale in our industry, the industry, if you look across many years, the ROA of the industry keeps inching down.
And so what we've done is taken the expense out to keep below that and get a constant, you know, sort of return on tangible common equity. So we're good in a 4,000-person competitive market to pass through the benefits to the market on a lot of that. But if you aren't doing it, you can't do that. And that's where, you know, that's where the fees and other things and the churn and the customers we just don't see in our customer base. And that's what allows us to price well and grow and get the core household. And meanwhile, it also gives us the right to invest a lot.
Okay. So let's talk about efficiency. It's everybody's favorite topic. And you gave a lot of data around this, and I think it's very encouraging. You know, you talked about getting the efficiency ratio back below 60% near term into the high 50s, sustained, operating leverage of 200 basis points -300 basis points. Talk us through what the efficiency agenda looks like from here, where you see the greatest opportunities. And obviously, look, AI is still a very, very dominant theme. I mean, do you think that AI will allow you to reduce the expense space in absolute terms, not necessarily in the next one to two years, but as you think out over the next three to five years?
So the very last part of that is it'll absolutely allow us to reduce the expense base of a particular product, service, or capability. The question of what you do with that money is going to be based on all the other things we talked about, competitive concerns, need to invest in stuff. So, but let's back up. Our efficiency ratio was overstated because of a way versus other people's efficiency ratio for two basic reasons. One is three basic reasons. One is NI is still kicking in. So that basically all goes to the bottom line. The second was, we have a higher percentage of our business in the least efficient business, which is a great business, which is a wealth management business, but that's a higher percentage of our revenues. And so until the NI kicks in, that also dilutes it down.
We're more efficient than anybody in the business. But the third reason is the way we accounted for these tax credit deals, which goes away. And so that was 200 basis points. So whenever they said your operating was 63, we're actually at 61 on apples to apples before you make anything. So we forgot about getting it below 60 because frankly, what happens over the course if you get the growth rate in the NI, which, you know, which basically pours the bottom line, the fee-based business brings a lot of expense. Obviously, the wealth management business brings $0.50 cents on a dollar, you know, investment banking brings another chunk and markets the same. So you'll see that as that pours through, that's what drives it. And that's what we've seen so far.
We had years we operated with operating leverage every quarter, efficiency ratio in the mid-50s, mid-to-upper 50s in investing, and you'll see that come back, and that's largely really all things being equal, it's just largely due to the NI rolling over and going the other way from eight quarters ago, whatever it is now.
Okay. So 16%-18% ROTCE, I think you said you plan to get to the lower end in two years, the higher end in three years. How should we think about the improvement in returns from here? I mean, is it linear over that time period or is it more back-end loaded? So maybe talk a little bit about the nearer term versus the longer term opportunity.
I'd say you'd be careful of a particular quarter generates different activity. So this quarter's mark is a little lighter than the first quarter and, you know, that stuff happens. But generally you'll see a progression year- over- year in the current plan. We put together a multi-year plan. You basically see a breakthrough towards the middle end of the second year breaks in and then it breaks the higher of that towards the 12th quarter. So I actually said, you know, seven, eight quarters and 12 quarters, eight to 12 quarters. It's really kind of rolls into and then rolls out. You know, it's three-year to five-year target. I just told you we should hit it in the third year and it'd be pretty ratable, although a particular quarter could go up and down depending on how the markets do.
Okay, so nearer term, can you just give us some high-level thoughts on the fourth quarter? Has anything changed since you last spoke, either in terms of NII or trading? Is there anything we should be aware of in terms of credit and expenses? You know, how's the fourth quarter shaping up?
They want me to do your work for you. Look, so on NIIs, there's no new news. That's good because we keep hitting that progression, and on in credit, you know, we're seeing charge-offs basically flatten out. So we don't see any news there. I think the two or three things just to make clear, if you look at investment banking fees for 2025 or 2024, we expect it to be up about 4%. That number would mean the fourth quarter implied at least sort of flattish to a little bit down from last year, $1.5, $1.6. That largely had we did $2 billion last quarter here saying what its largest deal flows and timing and stuff. So we feel good about that.
Markets, we think if you look at it year over year, as we think the fourth quarter finishes up, we'll be up 10% year- over- year and the fourth quarter will be up high single digits or close to 10%. And that's pretty good. That'd be the 15th, 16th consecutive quarter of link quarter growth. So we feel good about that. So NII, what we told you, those two items, everything else, expenses, look, the thing on expenses is that, from 2024 to 2025, you'd look at it, we're up 4%, 4 and a quarter or 4 and a half, 4, 4, I think it is. If you come in at the year end, last year's fourth quarter, this year's fourth quarter, you're going to be up four and change.
and that the pressure on that is all due to the wealth management business and that's incremental on some of their, what they call BCE, the clearing expense of markets. But if you look at that, look at it fairly. Last year, we had the credits and the FDIC. So it's up about 2.5%-3%. And so we think it'll be, we said it'd be flat or should be bounced around that maybe $100 million either way, but it's pretty good expense growth control year over year. That's come from headcount. That goes back to what I said. The headcount has basically been able to manage flat headcount in the aggregate with redeploying a ton of people going in different directions.
And that brings you to, you know, question of AI, which in the end of the day, AI today at Bank of America and Erica. Erica in the consumer business in the month of November, we had 1.4 billion digital connections with our customers. Erica's 20 million customers, about 200 million times a quarter. We think it saves today about 11,000 FTE equivalents. Now, the big debate of that is, does it atomize behavior? And what I mean by that is do you touch it three times a day where you wouldn't do something else three times a day, so you got to be careful about that, but the numbers of touches would equate to that, and that's today. That's not yesterday. The 24-hour period does 2 million interactions, so we feel very good about its impact.
We took that same thing to give you a completely historically different example and put it into the break fix technology widget. So when you go in and say, I need to change my password, my computer, I need something to be done, whatever. We went from people answering that or one-to-one chat, you know, to this bot answering half the questions in 60 days. So you can see how it can affect process. So we still have a lot of places where we think it can have an audit in, which is 1,200 people -1,300 people for us and risk, which is 1,000+ people and financial, which is 5,000+ people where you have not had a tool that could change process as much as this tool has the potential, and so that's where we think the upside comes from.
We've been taking out costs years and years and years out of the operations processes, out of that investing in technology, probably doubled the amount we spend every year on technology initiatives, and we spend another $10 billion just running the platform and keeping it secure and all this stuff, and we invested in new branches and all that stuff, but the gig is, you know, this is different because what you did there was a lot of process re-engineering that you didn't have this tool for, so even on those, you can go back and get more, credit offering memorandum preparation, pitch book preparation. These are all out in operating. The debate we have is, you know, how precise you can be in the very near term. We just rolled Copilot with the whole 365 Copilot.
We'll be through 200,000 people using it by the end of the year and then roll additional feature functionality. How do you say what you get out of it? And that's the question. Do you just have to focus people on the, you ought to be X% more efficient over two or three years to pay for the amount of time and effort you're putting in that? And that, that's a tougher question because it's not a process where you're applying a technology, even an AI technology and saying five steps, one, three steps, the three steps are enhanced this way and you save money. So it's going to be a little more interesting than that. But right now, we've been able to keep the headcount flat. So all the expense growth is really inflation around people cost, incentives for the wealth management business and then transactional cost.
And the inflation around people cost, the only way you're really going to manage it is to continue to drip, drip the heads down. And that's where a couple of years ago we said we had to get back on the other trail and we've done it. Meanwhile, you're putting tons of people out to the front. And, you know, we think our commercial bankers will get a 10% efficiency out of the tools we gave them this year and next year, which means they can do more logo development with the same number of people they would have otherwise done.
Okay. So you mentioned the credit picture, but anything that you've seen of note in terms of early delinquencies? You know, and I guess, and I think the bigger picture question here is on the consumer side in particular, you know, asset quality has improved despite some of the weaker data from retailers and restaurants. Why do you think we're seeing this divergence between the banks and some of these other data points?
I think the how a person spends money is a different determination whether they pay their credit. Because if they don't pay their credit, they get, you know, delinquency and a FICO, you know, that just changes their life, whether they decide to have to go out to dinner one time less or not. So the rate of spend at restaurant stuff is growing. It's just not growing at the same rate, spending like on cruises is growing double digit in our card base. So you'd say, so we don't see there's indications of consumer stress. All the spending is growing. The credit quality is good. The charge-offs in our consumer business came down and are just basically plugging along at a level that is 3.5% in the credit card business, which, you know, 20 years ago, you know, I thought that would be nirvana.
Would you expect it to decline from those levels going into next year?
I don't think so because we take risk, and so you got to take the risk, so we underwrite 100 people. Some of them are going to not turn out to have a, they're going to get divorced, they're going to get sick, they're going to lose their job, etc., so that's, even with a prime business, you're taking that risk, so we expect to have that rate or a little bit higher, actually, so it's performing about as good as it will. There will be times when it will go up and be a little better or not yet, but, but sort of structurally, if we were much below, that'd be worried we weren't taking the risk, and so, so that, but we just don't see it going anywhere, and our mortgage book, very, very little delinquency, the LTV is 50 or something like that.
The home equity book, the combined LTV is around the same. The FICO is 700. We've had credits, so to speak, you know, recoveries in the home equity book, which is really old loans that keep drifting through the system from years ago. It's all prime books. We don't see any deterioration at all. Now, we're not in a subprime space, so you've had other people who could talk about that. And so the prime credit we're seeing on, and remember, that's one of our strategies is we don't go seeking standalone credit. You know, we really go after the combined relationship, what we call the stair step on the consumer side, which is operational account, first, first borrowing, second borrowing, credit card, home equity, or car, and then home or home equity. That's the travel and investment. And so it's a very disciplined process.
So you're anchoring off a good customer, you've actually seen an action, stuff like that. And on the small business side, we've seen a normalization of the small business cards charge-offs, which, you know, are higher than the 4.5, I think, or something like that. But that's just the nature of small business success or not success. And then commercial, you know, really it's we all talked about commercial real estate two years ago. That's run through the system and it's on its way down. And then really not a lot else. And episodically you get one of these things and one of those things, but you've seen no deterioration in the core portfolio.
Okay. So I'm going to talk about a couple of your growth initiatives in a second, but just on the loan growth side, can you just touch on what you're seeing on the commercial side and the commercial real estate side? It does seem some of your peers are talking about that inflecting heading into next year. And then the other thing I'd be curious in getting your views on is the OCC rescinded some of the rules around leveraged lending. Does that in any way impact how you think about the opportunity set in commercial lending over the next few years?
So if you take the last part first, yes, it does help because the statement was, you know, you could do a handful outside of that guidance. And the guidance wasn't a rule, but you could do a handful. So let's define a handful, you know, let's define a handful when you have, you know, 10,000, you know, middle market, 20,000 middle market clients. Let's define a handful when you have, you know, a million small businesses. Let's define a handful, you know, that's like the beauty is in the eye of the beholder. So what happens when you did one, you know, get your head beaten around to do it. So getting rid of that as a principle is a good principle. Let us make credit. So we're pretty good at it.
It just improves simplicity.
Yeah. And what also just says, if this deal is a deal you want to do, go do it. So I think that'll help because it was a, you could never be right. It was only looked at after the fact. So we went through SNC exam after SNC exam. It's if we're all fine. You look at the credit portfolio. You're saying, so why, why do you, you know, so I think what they realized is let us underwrite the credit. And if our credit process doesn't work right, if we have an adverse amount of hits, you know, talk to us then, but don't, don't overprescribe, you know, the precision of which you see a credit versus what our experts see. By the way, we got people. This is all they do 24 by 7. I couldn't tell them how to do it either.
So we feel good about it. It's more the spirit of doing that. It lets us compete in the market. And when you come to the private credit side, which is one of the difficulties competing private credit has been that implied constraint or explicit constraint and the application of that, that now lets us look at a middle market company that's going, you know, doing a recap with a private equity firm or a larger, they're selling or one of our clients is buying them and they want to borrow, you know, at five times or seven times or six times in the right industry and believe the cash flow and they have a good plan, you know, we can do it. And so that's what the constraint was.
The rest of the commercial loan growth largely been. I think we're up 8% year- over- year, third quarter or something like that. The markets business has grown, but also the core, you know, the core small business has grown. I think they're up low mid-single digits. That's good, and then the commercial credit to wealthy people has grown very nicely. That was up, and that really comes from wealthy people putting more in the market, and it's commercial credit because of the structure of it. We feel good about the commercial loan growth. Now commercial real estate, I would say after years of it kind of bump along at the same level, you're seeing some life to it and well-structured deals. You know, that's a to-do for next year.
I don't, right now you're just seeing the start of it.
Okay, so you know, credit card and growth in the card business is one of the drivers to the improvement in the returns of the consumer business. You know, it does feel like that is a particularly competitive space. You know, obviously you've had a number of refreshes, a number of people looking to grow that. What do you think is your key differentiator in terms of growing the card business from here?
So we, if you look at the business we had from three or four, five years ago to now, it's actually grown at 5%. What we did is we sold off some portfolios in that timeframe. And so we can see the way we operate the business, Bank of America branded cards, few key co-branded partners driving that, you know, origination practice. We can get 5%, you know, and so it's kind of embedded in there and it has to net come out the other side. And that's the challenge for us. So Holly and the team that run the consumer business, David Tyrie that runs marketing, Mary Droesch runs products. We just announced this product for the World Cup, which is, you know, a chance to get tickets and things like that. All this is just to get people's attentions on a branded World Cup card.
And we got a lot of uptake compared to our usual promotions and stuff. So they're out there driving it. We spend, spend the money in advertising. We have some limited-grade affinity partners, but definitely we drive into the Bank of America and the combined rewards program is why our consumer business stability is different than anybody else's. And so if you look at our consumer business, the piece we call preferred, which is a higher in the consumer business, you know, a third of the customers, 80% of deposits, but also has a deep penetration of cards in a combined rewards program. That is the competitive advantage that nobody can do that across multiple products. And so that's, that's the way you play games.
We think we can move that from basically a 1% type of growth rate up to 5%, but it's more by taking away the negative than in the near term that is changing the growth rate on top. That's been going on, so to speak.
Then a similar question on the wealth business. I mean, you've obviously got great brand, great franchise, but it is a step up in growth relative to the past. You know, what again is it that you're going to do differently?
It really comes down to two or three things that they described. One is that we started recruiting experienced advisors because we just have tremendous client opportunity referrals from the commercial business to them and the consumer business to them. We just didn't have the capacity. So we bring in advisors, retool part of their book and then drive it. The second is we've created capacity in advisors, not only automatically, but also by household levels and things that they, Lindsay and Eric, have worked on. Third is the training program. We're maturing into the training program that we started, that we reinvigorated four or five, seven years ago, that those people getting more productive. Then we got the Merrill Edge piece. So that also is growing, you know, it's accounts and structures.
So it's well over $500 billion in client assets. And so that's a starter case that we can use for people. And, Maggie, within it, it's $40 billion - $50 billion of, you know, completely robot managed, so to speak, that we all talked about robot advisors five years ago. It seems trite now, but that was a big new thing. We actually do it and we have a book that it runs and it grows. And so we feel good about that because you can't forget that continuum piece. And then the Private Bank, Katy's put out 50-60 more private client advisors over the last 24 months, from other firms. They've gone through all the things that you're talking about. And so we feel good about that.
So, you know, you put that all together, it's really going to come down to the execution in the field by Lindsay and Eric's team to drive it. And they're confident they can just keep incremental. They've seen it move up and they just got to push through.
Okay. So we've got a couple of minutes left. Let's talk about capital. You set out a 10.5% CET1 target. A couple of questions here. I mean, the first is, can you talk about the path to the 10.5% in terms of increased deployment versus capital returns to shareholders? Second, look, there's obviously more regulatory reform to come. So do you think that 10.5% could change after we get the Basel III endgame, G-SIB recalibration? And then lastly, can you talk about your appetite for inorganic growth, for acquisitions as a way of accelerating what I think is a really good organic growth story?
Yeah. So, I think just on the, you know, organic. Remember that there's no legal way we can acquire a deposit. A franchise has deposits in it. So that takes off the table, you know, most of what would be interesting, except in a failed deal. So we'll see if people get bumped up or something like that. And then outside that, it's line of business oriented. And so we've acquired, you know, various payments firms. We keep doing that, smaller ones that you wouldn't see, so to speak. They just get absorbed in. So we'll continue to do that. I think we've made a decision in the wealth management business how we're going to operate, which is the asset management is a different business. And to make that have any kind of impact on us, we'd have to do something.
So we look at it and say, then it's just people and hiring people. So we're in every market around the world for markets and commercial banking and treasury services and investment banking. We just keep adding people and adding expense and then making that more efficient. So that's sort of off the table. On capital, you know. If you think about our nominal amount of capital, if that capital counts for more into the G-SIB recalibration, which is, I think, most important to us as an industry, and is also frankly the thing that has gotten most wrong, frankly, you know, so we can debate advanced standardized and all that stuff. What happened with G-SIB is, you think, it hasn't been calibrated since 2012, off of 2012 data.
And then you had this massive nominal growth rate in the economy from 2019 to now, and they didn't change any of the stuff. So what's happened is we have actually, you know, grown our G-SIB number from 250 to 300 to 350. And you're saying, but guys, we're not taking any more risk with all this size of the economy. So the whole thesis of it has been polluted by them not recalibrating. That helps us. And the question, but it's got to be ruled, it's got to be passed, and we got to understand the dynamics of it. And so with that comes Basel III finalization. And so, but that, that's the most beneficial thing to us. So I don't know until I see that, you see some of the outlines of it, but then they say, well, there'll be stuff over here, stuff over there.
We got to get a set of rules on the table that we agree with. We do that, I think, that allow us to have more excess capital. And we'll probably use that to grow into it while we take 100% of the capital and or more is going out in earnings, excuse me, in dividends and buybacks in this quarter. We'll buy back a little bit more, you know, as we go through the quarter because largely we earn more than we had in our capital plan last quarter. So we'll continue to do that. But that then keeps capital from building, for lack of a better term. And then what you do is you grow into that. And if we got a step change of relief on the G-SIB, then you can make another decision whether you can step up the buybacks more.
But right now, you know, there's a glide path. I don't want to constrain markets' ability to grow. We don't want to constrain markets' ability to grow and things like that, and that's the major users of G-SIB, so if you look at it year to year, they're 75%-80% of the points usage. That's letting Jimmy keep pushing that business out there.
Okay. I think with that, sadly, we're out of time, but pleasure as always. Look forward to seeing you again next year.
Thank you.