NEW YORK (

TheStreet

) --

Bank of America

(BAC) - Get Report

shareholders can look forward to additional dilution in 2012 as the bank works to satisfy regulatory capital requirements, analysts say.

Analysts at Deutsche Bank are looking for an additional $15 billion worth of common equity issuance in 2012 "to meet new capital requirements" - with some or all of the issuance coming from converting additional preferred and trust preferred securities, they wrote in a note published Wednesday.

Bank of America has the weakest capital position among the largest U.S. banks by several measures, but it has been selling assets and issuing equity to strengthen its balance sheet. Bank of America

announced this month

it would issue $1.1 billion in common shares plus about $1 billion in senior debt to buy back $2.7 billion in preferred stock and trust preferred securities.

Barclays Capital analyst Jason Goldberg noted in a report published Wednesday that Bank of America deleted language from its third quarter earnings filing with the Securities and Exchange Commission that had been in previous filings. For example, Bank of America removed the word "non-dilutive," from its assertion in its second quarter filing that it would "continue to build capital through retaining earnings, actively reducing legacy asset portfolios and implementing other non-dilutive capital related initiatives." The bank also eliminated a sentence that read "we currently anticipate that we will be in excess of the minimum required ratios without needing to raise new equity capital."

Bank spokesman Jerome Dubrowski would not comment on any future plans to issue equity, but he acknowledges this month's equity raise was dilutive to shareholders, which he says is why Bank of America tweaked the language in the filing.

"Any time you issue new shares you dilute existing shareholders," Dubrowski wrote via email. However, he argued CEO Brian Moynihan had spoken truthfully when he said told shareholders July 19 that "we don't need to raise capital."

"We don't need to raise capital. It was true then and it's true now. The exchange of preferred for common helps us. It's a smart economic move near term and long term," Dubrowski told

TheStreet

.

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Written by Dan Freed in New York

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