CHARLOTTE, N.C. (

TheStreet

) --

Bank of America

(BAC) - Get Report

is still going through major transitions -- in top-level management, ownership, and business model -- all while economic headwinds persist, making it a tough time for investors to decide whether its stock is attractively valued.

Today, Bank of America will be rid of the last bit of government ownership after the Treasury Department auctions its 272 million warrants to buy common stock.

B of A paid off its entire $45 billion TARP investment at the end of last year, raising capital with the issuance of 1.3 billion new common shares, after raising over $10 billion through stock issuance and asset sales in the earlier part of 2009. The bank lifted its authorized float to 11.3 billion shares from 10 billion to finalize its TARP payback plan.

Now, Bank of America has a lot less government ownership, but a lot more ownership in general.

Meanwhile, new CEO Brian Moynihan, who took over the top job on Jan. 1, has made sweeping changes to his management team. The latest maneuver came on Tuesday, as the bank announced that Ric Struthers, head of Bank of America's credit card business, will be leaving the firm. Susan Faulkner will take over his job in a newly developed role to oversee both credit cards and deposits.

The move was both practical as well as strategic. Credit cards have represented a loss-leading business for B of A through the end of the Great Recession, and while Struthers has been in charge only since January 2009, a major leadership change is perhaps unsurprising.

At the same time, Moynihan is implementing a new management structure, in which top executives are charged not just with a single business line, but with products, services and distribution. The person in charge of retail deposits would naturally have the appropriate channel to offer credit cards to consumers and small-business owners.

Overseeing those businesses at the level above Faulkner is Joe Price, who oversees not just cards, but consumer and small-business lending as well. Moynihan

rolled those three businesses into a new silo

in January, along with some other high-level changes.

Chief Risk Officer Greg Curl -- who had been in the running against Moynihan to lead the entire bank -- was replaced by Bruce Thompson, and now plans to retire at the end of March. Chief Accounting Officer Neil Cotty took over Price's position as CFO for the time being, though no permanent replacement has been named.

Since then, there have been several lower-level personnel decisions made by top managers. Tom Montag, who heads the capital markets business, has appointed Sam Chapin and Todd Kaplan as co-vice-chairmen of global banking and Paul Donofrio to lead corporate banking. There have been some other moves in research, investment banking and wealth management as well.

While all of these transitions take place, Moynihan has yet to outline any comprehensive business plan for how Bank of America will capitalize on its size and strengths to become not just the largest U.S. bank, but the best and most profitable. He has, however, indicated a shift to a new mantra: Customers first.

Moynihan seems determined to change B of A's reputation from a large, cold, corporate entity that preys on consumers with hidden fees and soaring interest rates, to one that explains terms clearly and is ready to offer appropriate financial services. Bank of America has adopted many of the government's programs to protect and assist consumers ahead of its peers -- most notably,

JPMorgan Chase

(JPM) - Get Report

, which has fought some of them tooth and nail.

But whether that's a short-term marketing tactic to tamp down negative headlines, or a long-term strategy to regain customer trust, is yet to be seen. It's also unclear whether that strategy is one that appeals to shareholders as much as borrowers and depositors.

"What shareholders need is Bank of America's point of view backed by solid analysis of the markets it participates in," Rochdale Securities analyst Richard Bove said in a note Tuesday. "This has not been forthcoming and statements that no changes are necessary only deepen investors' belief that they should rent this stock for the earnings recovery and not own it."

From a retail investor's point of view, there's certainly a lot of noise to cut through before deciding whether Bank of America's stock is cheap, expensive or fairly valued. Besides the big, but hard-to-measure, changes at Bank of America specifically,

shifting political winds

seem to change plans for financial-regulatory reform overnight, and there are conflicting signals on any given day about the country's economic health.

Stock analysts aren't much help, either. While many are bullish on B of A in a pro-forma sense, they recognize the uncertainty that lies ahead, and ratings often carry several caveats.

The average analyst estimate is for Bank of America to earn 9 cents per share this quarter, according to Thomson Reuters, but estimates range from a 5-cent per-share loss to a 26-cent per-share profit. For all of 2010, the average estimate is 82 cents per share, with forecasts ranging of 20 cents to $1.60 in profit per share.

Bank of America estimated its per-share book value at $21.48 at the end of 2009, and its tangible book value at $11.94. Its stock closed at $16.39 on Tuesday, and its 50-day moving average stock price is $15.66. Based on the average analyst's 2010 earnings estimate, and yesterday's closing price, that makes Bank of America more expensive than most big-bank peers outside of

Citigroup

(C) - Get Report

, including JPMorgan,

Wells Fargo

(WFC) - Get Report

,

U.S. Bancorp

(USB) - Get Report

,

Goldman Sachs

(GS) - Get Report

and

Morgan Stanley

(MS) - Get Report

.

Bove has a "buy" rating on Bank of America stock, and said on Tuesday that it may double in price. But he also said its business model is "deeply flawed" and based some of his math on what Bank of America could earn in a "more normal economy" with a loan-loss provision of roughly one-fifth of what the bank had reserved at the end of 2009, and securities yielding much more than current levels allow.

So what does all this mean for Bank of America shares? They may have a lot of potential, but it's unclear how they will get there, or how long that will take.

--

Written by Lauren Tara LaCapra in New York