Exhibit 25.19

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM T-1

STATEMENT OF ELIGIBILITY

UNDER THE TRUST INDENTURE ACT OF 1939 OF A

CORPORATION DESIGNATED TO ACT AS TRUSTEE

¨ CHECK IF AN APPLICATION TO DETERMINE ELIGIBILITY OF A TRUSTEE PURSUANT TO SECTION 305(b)(2)

DEUTSCHE BANK TRUST COMPANY AMERICAS

(formerly BANKERS TRUST COMPANY)

(Exact name of trustee as specified in its charter)

NEW YORK	13-4941247
(Jurisdiction of Incorporation or	(I.R.S. Employer
organization if not a U.S. national bank)	Identification no.)

60 WALL STREET
NEW YORK, NEW YORK	10005
(Address of principal executive offices)	(Zip Code)

Deutsche Bank Trust Company Americas

Attention: Lynne Malina

Legal Department

60 Wall Street, 37th Floor

New York, New York 10005

(212) 250 – 0677

(Name, address and telephone number of agent for service)

Bank of America Corporation

(Exact name of obligor as specified in its charter)

North Carolina	56-0906609
(State or other jurisdiction of incorporation or organization)	(IRS Employer Identification No.)

Bank of America Corporate Center
100 North Tyron Street, Charlotte	28255
(Address of principal executive offices)	(Zip Code)

Subordinated Debt Securities

(Title of the Indenture securities)

Item 1. General Information.

Furnish the following information as to the trustee.

(a) Name and address of each examining or supervising authority to which it is subject.

Name	Address
Federal Reserve Bank (2nd District)	New York, NY
Federal Deposit Insurance Corporation	Washington, D.C.
New York State Banking Department	Albany, NY

(b)	Whether it is authorized to exercise corporate trust powers.
	Yes.

Item 2. Affiliations with Obligor.

If the obligor is an affiliate of the Trustee, describe each such affiliation.

None.

Item 3. -15. Not Applicable

Item 16. List of Exhibits.

Exhibit 1 -	Restated Organization Certificate of Bankers Trust Company dated August 6, 1998, Certificate of Amendment of the Organization Certificate of Bankers Trust Company dated September 25, 1998, Certificate of Amendment of the Organization Certificate of Bankers Trust Company dated December 16, 1998, and Certificate of Amendment of the Organization Certificate of Bankers Trust Company dated February 27, 2002 - Incorporated herein by reference to Exhibit 1 filed with Form T-1 Statement, Registration No. 333-157637-01.
Exhibit 2 -	Certificate of Authority to commence business - Incorporated herein by reference to Exhibit 2 filed with Form T-1 Statement, Registration No. 333-157637-01.
Exhibit 3 -	Authorization of the Trustee to exercise corporate trust powers - Incorporated herein by reference to Exhibit 3 filed with Form T-1 Statement, Registration No. 333-157637-01.
Exhibit 4 -	Existing By-Laws of Deutsche Bank Trust Company Americas, as amended on April 15, 2002 business - Incorporated herein by reference to Exhibit 4 filed with Form T-1 Statement, Registration No. 333-157637-01.

Exhibit 5 -	Not applicable.
Exhibit 6 -	Consent of Bankers Trust Company required by Section 321(b) of the Act. - business - Incorporated herein by reference to Exhibit 6 filed with Form T-1 Statement, Registration No. 333-157637-01.
Exhibit 7 -	The latest report of condition of Deutsche Bank Trust Company Americas dated as of June 30, 2011. Copy attached.
Exhibit 8 -	Not Applicable.
Exhibit 9 -	Not Applicable.

SIGNATURE

Pursuant to the requirements of the Trust Indenture Act of 1939, as amended, the trustee, Deutsche Bank Trust Company Americas, a corporation organized and existing under the laws of the State of New York, has duly caused this statement of eligibility to be signed on its behalf by the undersigned, thereunto duly authorized, all in The City of New York, and State of New York, on this 29th day of September, 2011.

DEUTSCHE BANK TRUST COMPANY AMERICAS
	By:	/s/ CAROL NG
		CAROL NG
		VICE PRESIDENT

DEUTSCHE BANK TRUST COMPANY AMERICAS		FFIEC 031
Legal Title of Bank		Page RC-1
NEW YORK		15
City
NY	10005
State	Zip Code
FDIC Certificate Number: 00623 Printed on 8/4/2011 at 1:23 PM

Consolidated Report of Condition for Insured Commercial

and State-Chartered Savings Banks for June 30, 2011

All schedules are to be reported in thousands of dollars. Unless otherwise indicated,

report the amount outstanding as of the last business day of the quarter.

Schedule RC—Balance Sheet

		Dollar Amounts in Thousands			RCFD	Tril | Bil | Mil | Thou
ASSETS
1.	Cash and balances due from depository institutions (from Schedule RC-A):
	a. Noninterest-bearing balances and currency and coin (1)				0081		426,000	1.a
	b. Interest-bearing balances (2)				0071		20,737,000	1.b
2.	Securities:
	a. Held-to-maturity securities (from Schedule RC-B, column A)				1754		0	2.a
	b. Available-for-sale securities (from Schedule RC-B, column D)				1773		1,865,000	2.b
3.	Federal funds sold and securities purchased under agreements to resell:				RCON
	a. Federal funds sold in domestic offices				B987		161,000	3.a
					RCFD
	b. Securities purchased under agreements to resell (3)				B989		6,000	3.b
4.	Loans and lease financing receivables (from Schedule RC-C):
	a. Loans and leases held for sale				5369		0	4.a
	b. Loans and leases, net of unearned income		B528	14,422,000				4.b
	c. LESS: Allowance for loan and lease losses		3123	78,000				4.c
	d. Loans and leases, net of unearned income and allowance (item 4.b minus 4.c)				B529		14,344,000	4.d
5.	Trading assets (from Schedule RC-D)				3545		4,428,000	5
6.	Premises and fixed assets (including capitalized leases)				2145		56,000	6
7.	Other real estate owned (from Schedule RC-M)				2150		22,000	7
8.	Investments in unconsolidated subsidiaries and associated companies				2130		0	8
9.	Direct and indirect investments in real estate ventures				3656		0	9
10.	Intangible assets:
	a. Goodwill				3163		0	10.a
	b. Other intangible assets (from Schedule RC-M)				0426		46,000	10.b
11.	Other assets (from Schedule RC-F)				2160		5,355,000	11
12.	Total assets (sum of items 1 through 11)				2170		47,446,000	12

(1) Includes cash items in process of collection and unposted debits.

(2) Includes time certificates of deposit not held for trading.

(3) Includes all securities resale agreements in domestic and foreign offices, regardless of maturity.

DEUTSCHE BANK TRUST COMPANY AMERICAS	FFIEC 031
Legal Title of Bank	Page RC-1a
FDIC Certificate Number: 00623	15a

Printed on 8/4/2011 at 1:23 PM

Schedule RC—Continued
		Dollar Amounts in Thousands			Tril | Bil | Mil | Thou
LIABILITIES
13.	Deposits:			RCON
	a. In domestic offices (sum of totals of columns A and C from Schedule RC-E, part I)			2200	19,286,000	13.a
	(1) Noninterest-bearing (1)	6631	11,995,000			13.a.1
	(2) Interest-bearing	6636	7,291,000			13.a.2
	b. In foreign offices, Edge and Agreement subsidiaries, and IBFs			RCFN
	(from Schedule RC-E, part II)			2200	11,805,000	13.b
	(1) Noninterest-bearing	6631	7,429,000			13.b.1
	(2) Interest-bearing	6636	4,376,000			13.b.2
14.	Federal funds purchased and securities sold under agreements to repurchase:			RCON
	a. Federal funds Purchased in domestic offices (2)			B993	4,151,000	14.a
				RCFD
	b. Securities sold under agreements to repurchase (3)			B995	0	14.b
15.	Trading liabilities (from Schedule RC-D)			3548	253,000	15
16.	Other borrowed money (includes mortgage indebtedness and obligations
	under capitalized leases) (from Schedule RC-M)			3190	260,000	16
17.	and 18. Not applicable
19.	Subordinated notes and debentures (4)			3200	0	19
20.	Other liabilities (from Schedule RC-G)			2930	1,860,000	20
21.	Total liabilities (sum of items 13 through 20)			2948	37,615,000	21
22.	Not applicable

(1) Includes total demand deposits and noninterest-bearing time and savings deposits.

(2) Report overnight Federal Home Loan Bank advances in Schedule RC, item 16, “Other borrowed money.”

(3) Includes all securities repurchase agreements in domestic and foreign offices, regardless of maturity.

(4) Includes limited-life preferred stock and related surplus.

DEUTSCHE BANK TRUST COMPANY AMERICAS	FFIEC 031
Legal Title of Bank	Page RC-2
FDIC Certificate Number: 00623	16

Printed on 8/4/2011 at 1:23 PM

EQUITY CAPITAL
	Bank Equity Captal			RCFD	Tril | Bil | Mil | Thou
23.	Perpetual preferred stock and related surplus			3838	1,500,000	23
24.	Common stock			3230	2,127,000	24
25.	Surplus (excludes all surplus related to preferred stock)			3839	588,000	25
26.	a. Retained earnings			3632	5,218,000	26.a
	b. Accumulated other comprehensive income (5)			B530	13,000	26.b
	c. Other equity capital components (6)			A130	0	26.c
27.	a. Total bank equity capital (sum of items 23 through 26.c)			3210	9,446,000	27.a
	b. Noncontrolling (minority) interests in consolidated subsidiaries			3000	385,000	27.b
28.	Total equity capital (sum of items 27.a and 27.b)			G105	9,831,000	28
29.	Total liabilities and equity capital (sum of items 21 and 28)			3300	47,446,000	29
Memoranda
To be reported with the March Report of Condition.
				RCFD	Number
1.	Indicate in the box at the right the number of the statement below that best describes the most comprehensive level of auditing work performed for the bank by independent external auditors as of any date during 2010			6724	N/A	M.1
1 =	Independent audit of the bank conducted in accordance with generally accepted auditing standards by a certified public accounting firm which submits a report on the bank	4 =	Directors’ examination of the bank conducted in accordance with generally accepted auditing standards by a certified public accounting firm (may be required by state chartering authority)
2 =	Independent audit of the bank’s parent holding company conducted in accordance with generally accepted auditing standards by a certified public accounting firm which submits a report on the consolidated holding company (but not on the bank separately)	5 =	Directors’ examination of the bank performed by other external auditors (may be required by state chartering authority)
		6 =	Review of the bank’s financial statements by external auditors
		7 =	Compilation of the bank’s financial statements by external auditors
3 =	Attestation on bank management’s assertion on the effectiveness of the bank’s internal control over financial reporting by a certified public accounting firm.	8 =	Other audit procedures (excluding tax preparation work)
		9 =	No external audit work
To be reported with the March Report of Condition.				RCON	MM / DD
2. Bank’s fiscal year-end date				8678	N/A	M.2

(5)	Includes net unrealized holding gains (losses) on available-for-sale securities, accumulated net gains (losses)
	on cash flow hedges, cumulative foreign currency translation adjustments, and minimum pension liability adjustments.
(6)	Includes treasury stock and unearned Employee Stock Ownership Plan shares.