BofA Needs to Rework Countrywide Deal

"You're dealing with a cyclical industry and ... it wasn't that hard to figure out where we were in the cycle," he says. "We have a long history with dealing with subprime borrowers and we know what happens. We know they don't pay back."

To be sure, not all analysts are convinced that BofA should reconfigure the deal

BofA "remains comfortable with the terms of its announced acquisition of Countrywide," according to a note written by Jeff Harte, an analyst at Sandler O'Neill & Partners, who met with several company executives this week. "This implies that the evolution of Countrywide since the acquisition was announced in January remains within the band of management's expectations."

Even FBR's Miller, the analyst who went so far as to suggest that BofA back away from the deal, said that is unlikely to happen. BofA may choose not to walk away from the deal or lower its offer, as doing so might result in "negative publicity" the firm does not want, he wrote.

Bove agrees that BofA will not walk away from the deal but is one of many in the camp that believes it should renegotiate the deal.

BofA will be "absorbing a company with huge losses, enormous amount of debt, and $200 billion of assets [requiring them to] adjust capital ratios so dramatically that it might force them to raise more capital. [BofA] could even cut their dividend," he says.

IRA's Whalen agrees. "Overall the Golden West business was so simple," he says. "If I had a choice between the retained portfolio of Countrywide and the retained portfolio of Golden West, I'd take Golden West."