April 4 (Reuters) - Proxy adviser Institutional

Shareholder Services has recommended that investors cast

advisory votes against the pay of top Bank of America ( BAC )

executives including CEO Brian Moynihan, citing concerns about

the process used to set the compensation.

Moynihan earned $35 million last year, an increase of

roughly 21%. ISS said in a report on Thursday that the increase

"appears directionally aligned with company performance."

But the process for determining his short-term incentive

includes discretionary determinations and the bank did not

disclose enough details, which "inhibits a fulsome assessment of

pay program rigor and the reasonableness of the specific pay

determinations," ISS said.

Asked for comment about the ISS report, a Bank of America ( BAC )

spokesperson referred to language in its recent proxy statement.

In the document the bank credited Moynihan with growing its net

income 2.3% last year compared to 2023 and growing revenue 3.4%

last year compared to 2023.

Rival proxy advisor Glass Lewis had recommended on March 28

that investors vote in support of Bank of America's ( BAC ) executive

pay.