A collection of businesses fraught with risk. A seedbed of cultural dissonance. A company that did too much to increase in size, and not enough to contain the rot beneath the foundation of its supersized balance sheet.

This has long been the rap on Citigroup Inc., but increasingly the description is being applied to Bank of America Corp., which seems to have taken over for Citi as the poster child for what can go wrong at a big, complicated bank.

Certainly Citi still has its problems, but the company has been keeping a relatively low profile of late as it works on selling assets, repairing relationships with regulators and slowly renewing investor confidence. In contrast, B of A, whether it is dealing with the fallout of the foreclosure mess or the threat of an informational assault by WikiLeaks, keeps finding itself in the public glare.

"For the longest time, people were criticizing Citi, saying Citi can't get out of its own way," said David Havens, a Nomura Securities debt analyst who follows U.S. financial institutions. "The general view [now] is that Citi is getting its act together, and B of A is still looking back and grappling with some of the problems that are left over from the financial crisis, specifically the mortgages."

Though both banks needed extra assistance from the government in 2008, it was Citi that became the lightning rod for an angry citizenry early in the financial crisis, while the rescue of Merrill Lynch & Co. gave B of A some cover in its request for help. But as the credit cycle churned and the mortgage mess moved front and center, the negative attention migrated to B of A.

Of course recent revelations about robo-signers and the intensified concerns over put-back risks in the securitization market have not been helpful to any of the big banks. But as the steward of the giant Countrywide franchise, the backlash has been particularly punishing for B of A, which has been responsible for a third of the country's home loan modifications.

"Cleaning up the distressed Countrywide portfolio colors everything we're doing right now, but it's manageable and we are meeting it head on," said Lawrence Di Rita, a spokesman for B of A. "At the same time, our new home loans business has originated more than $200 billion in high-quality home loans this year, showing the potential of this important product in our customer-centered strategy."

But investors remain worried. When the debate over the need for a national foreclosure moratorium reached a crescendo in mid-October, it started to cost more in the credit derivatives market to protect against a bond default by B of A than by Citi, implying that investors had begun to assign a greater default risk to B of A. The difference has widened since. On Friday, protection against a default on $10 million of B of A debt cost about $183,000 based on the price of a five-year swap, compared with $142,000 for protection on Citi debt.

Of course the idea of an actual default remains remote. But enough clouds have been gathering over the put-back risk in B of A's mortgage business that Damon Silvers, a member of the Congressional Oversight Panel monitoring the Troubled Asset Relief Program, believes the government ought to be examining the situation as a systemic risk.

A group including the Federal Reserve Bank of New York, BlackRock Inc. and Pacific Investment Management Co. already has sent B of A a letter requesting that the company repurchase soured mortgages that had been sliced and diced into $47 billion of bonds. Silvers, who is the policy director at the AFL-CIO, pointed out at the oversight panel's Oct. 27 hearing that if B of A were to receive a few more requests of similar size, the repurchase demands would eclipse the company's total stock market capitalization. When a Treasury Department official testified that there "didn't appear to be evidence of a major systemic risk" from the put-back issue, Silvers shot back, "I hope … if the Treasury comes back to us and is discussing whether or not we need to deploy further public funds to rescue Bank of America, or any such institutions as might be affected by these events, that we get a similar kind of indifference to their fate after it's too late."

In an interview, Silvers said that his comments were not meant to foreshadow another bailout of B of A but rather to get at whether the government feels it has a systemic risk in its midst when it comes to the question of put-backs. Either way, B of A — like all big banks with significant mortgage exposure — has a tough problem to attend to.