Bank of America Corp. said Friday that it may not guarantee $38.1 billion of Countrywide Financial Corp.’s debt after taking over the mortgage lender.

The announcement from the Charlotte, N.C.-based bank renews concerns that Countrywide’s bondholders face renewed risk of default.

“There is no assurance that any such debt would be redeemed, assumed or guaranteed,” the bank company said in an April 30 regulatory filing, adding that no decision has been reached.

Countrywide bondholders have been hoping that after the merger goes through, Countrywide would assume Bank of America’s AA credit rating. Countrywide has a total of $97.2 billion in debt. The debt includes $11.5 billion is in credit lines and $47.7 billion in advances from the Federal Home Loan Bank Board, according to information compiled by Bloomberg.

Bank of America said the credit lines will be paid when the merger is completed, while the advances will remain outstanding. That leaves the $38 billion, which is about 2.5 percent of B of A’s total liabilities at the end of 2007, according to the filing.

The purchase of Countrywide is scheduled to close in the third quarter. However, concern has circulated that Bank of America may drop its offer price or cancel the deal altogether as U.S. home prices and sales continue to decline and the nation’s credit markets continue to be stingy.

Shares in Countrywide were up 1.2 percent to $6.12 in early trading Friday.