Everyone knew that the historic financial reform package would costs banks plenty. But apparently not all of the expected impact was priced into the market. The Durbin Amendment, for example, which limits processing fees on debit card transactions, was hardly a secret. But the market really reacted when Bank of America (NYSE: BAC) said the regulation would cost it $2.3 billion in annual revenue starting this month.

The Durbin amendment might also lead to a $7 billion to $10 billion writedown of its global card services unit's $22 billion in goodwill next quarter, the bank said. In addition, the CARD Act is projected to cut revenues by $1 billion in 2010, and overdraft policy changes are expected to reduce service charge fees by $500 million per quarter, as reported by MarketWatch.

Bank of America executives may be trying to talk analysts down a bit, forcing their estimates even lower, to raise the chances of an upside surprise. This is a good time to undertake such an effort, as the optimism over Bank of America was fairly strong. Analysts had been fairly bullish and Brian Moynihan seemed to be able to do no wrong. So this may be a form of shock therapy. Moynihan certainly has his work cut out for him now.

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