For more than a decade following the merger between NationsBank and BankAmerica Corporation, the new Bank of America (NYSE:BAC) set upon a path of greedy acquisition, culminating in the crisis-era buyout of the failing Merrill Lynch brokerage. Of the top 10 bank mergers and acquisitions between 2000 and 2011, Bank of America was involved in four, according to the American Bankers Association.

Acquisitions such as MBNA were problematic, but the Countrywide and Merrill purchases nearly did the bank in. Since taking the helm in 2010, CEO Brian Moynihan has been trying to undo the damage wrought by his predecessors, dumping $60 billion of extra baggage through his Project New BAC.

But the pace of selling assets has slowed, and Moynihan seems less interested in a continuous pruning of the megabank than he once was. But Bank of America is still a behemoth, and there's quite a bit of trimming that could be done if the CEO is serious about restoring the bank's pre-bloat grandeur.

Layoffs won't cut it
For most of this year, Moynihan has been trying to focus more on creating income, rather than slashing away at expenses. Most of the cost savings for 2013 have taken the form of layoffs and branch sales, rather than the selling off of non-core assets.

But peers are also laying off, as the mortgage business tanks. Wells Fargo (NYSE:WFC), by far the biggest mortgage-maker, said in October that it will lay off nearly 1,000 employees in its mortgage division, on top of another 5,300 workers who were previously scheduled to lose their jobs. JPMorgan Chase (NYSE:JPM) also laid off more than 2,000 workers last August and plans to close mortgage refinance centers through the end of 2014, culminating in approximately 17,000 layoffs.

More to cut?
But Moynihan had predicted a workforce reduction at Bank of America long before the mortgage slowdown, estimating layoffs totaling 30,000 by the end of 2013. And while the bank has racked up more than $9 billion in pre-tax income so far in 2013, that number is a far cry from Moynihan's 2011 prediction of $35 billion to $40 billion annually once business normalized. Where is that money supposed to come from?

With the mortgage business slowing, Bank of America needs to put asset sales back on the table, despite Moynihan's wish to move beyond cost-cutting. Not only is this the most viable way to free up cash, but it is what investors wish as well.

At an investors' conference in June, shareholders made it resoundingly clear that they want the bank to continue cutting expenses. To see where the reductions might come from, a look at the bank's 2012 10K report shines a bright light onto the true width and breadth of Bank of America.

From my calculations, the bank appears to have a global conglomeration of more than 1,100 direct and indirect subsidiaries at the current time. Might some of these subsidiaries be saleable entities, outside of the bank's stable of core assets? No one would know better than Moynihan -- and if he is committed to rehabilitating Bank of America as well as pleasing investors, he should give that list a long, hard look.