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. (Reporting by Ross Kerber; Editing by Mark Porter)