Bank of America is restructuring. Cutting jobs, in other words. 3,500 this quarter, and many more to come - possibly as many as 10,000 by the end of September. These layoffs follow a survey the bank sent to its staff in April asking them for ideas on how BofA could "tweak" its operations to reduce expenses, among other things.

The bank called the fact finding mission Project New BAC (BAC is the bank's ticker), which sounded hopeful and forward-thinking. Today the bank is spinning the layoffs program as an aggressive overhaul, which it's calling ... Project New BAC.

The bank needs an overhaul. The company's stock has been hammered over the last few weeks, and has fallen 44 percent this year. Investors are worried about the effect of the toxic debt that the company is still carrying, and settlements that it has made with claimants from BlackRock to Fannie Mae. The bank has been hoarding cash to cope with future settlements, boosting its reserves to $17.8 billion from $4 billion. But Chris Gamaitoni of a Compass Point Research and Trading told Bloomberg the bank's losses could go as high as $44 billion.

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