NEW YORK ( TheStreet) -- Brian Moynihan spent most of his career in mergers and acquisitions. Today, as CEO of Bank of America ( BAC), he is in relatively unfamiliar territory as he figures out how to generate organic growth at a too-big-to-fail bank. "I spent most of my career consolidating this industry. It could never happen again," Moynihan said at a Wall Street Journal breakfast event in New York Wednesday. "Companies like us who made acquisitions now have to think of organic growth for decades." Bank of America is still paying dearly for its 2008 acquisition of Countrywide, which stuck the bank with legal losses that have now exceeded $40 billion. And in the new regulatory regime, growing through acquisitions is not even an option for the biggest banks. Regulators do not want to see big banks getting any bigger. Which is fine as far as Moynihan is concerned. "We don't need to be bigger to serve our clients," he said. He also sees plenty of potential for organic growth even without growing the balance sheet. "We need to get rid of $40 billion in home equity loans and replace them. We can grow with just that." Revenue growth has largely eluded big banks in recent years as low interest rates chipped away at the spreads earned in their lending business. Fee income has also been volatile. Banks have instead been focused on trimming costs, with Bank of America leading the way with its cost-savings initiative Project BAC. Bank of America eliminated 31,000 full-time jobs, or just under 11% of its workforce, between the second quarter of 2011 and the second quarter of 2013. Generating revenue growth is also challenging at a time when the bank is still fighting off a mountain of lawsuits. Bank of America has been focused on settling lawsuits wherever possible and moving on, but the bank said in a recent filing that it could see legal losses exceed reserves by more than $5 billion. JPMorgan Chase ( JPM), which now finds itself in the same position of defending itself against a litany of lawsuits, is merely toeing the line of Bank of America in settling cases to resolve the legal uncertainty.