U.S. Bancorp was a distant fourth, losing $460 million in annual revenues. The rule went into effect in July 2010.
The differential comes in part from the fact that, unlike other banks, which allow customers to "opt-in" on overdraft fees so that they can access funds when their accounts are empty, Bank of America chose not to give customers that option.
A Bank of America spokesman declined to comment on the Credit Suisse estimates, though Orenbuch's figure is not substantially different from the $2.8 billion impact Bank of America had estimated it would see from the rule in its 2010 annual report.
Bank of America also saw a significantly larger revenue hit from the Durbin Amendment than its peers, according to Orenbuch's research.
The analyst estimates the amendment, which limits fees banks can charge to retailers on debit card transactions, will cost Bank of America $2 billion annually in revenues, versus $1 billion at JPMorgan Chase, $1.538 billion at Wells Fargo and $300 million at U.S. Bancorp.
This differential is largely explained by the fact that Bank of America is the largest consumer deposit bank in the country as measured by retail checking account customers, according to Orenbuch's research.
The estimated impact does not include the potential mitigating effect of other actions taken by banks, though such efforts have proven difficult in some instances.
In perhaps the most talked-about instance of an attempt by a bank to make up lost revenues, Bank of America said earlier this year it would charge customers $5 per month for using their debit cards.
Following widespread public condemnation, Bank of America dropped the fee Nov. 1, just one month after it had announced it.
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