This is tied to their own Mortgage operations rather than those they bought with Countrywide (disclaimer: I worked at Countrywide for six years).

As the article notes though:

"The bank’s acquisition of mortgage giant Countrywide Financial in 2009 gave it an edge in the housing market and endless legal headaches. Analysts estimate that Bank of America has lost nearly $40 billion on mortgage litigation and repurchases of soured loans linked to Countrywide."

So an $850 million deal resulting in litigation is rather small considering the $40 bil they have already lost due to CW.