Wells Fargo
Unauthorized Policies
November 2021
© 2021 Professional Risk Managers’ International Association
Summary
The financial crisis of 2007/2008 began in the United States due to the collapse of the housing market.
Subprime mortgages issued by numerous financial institutions, including Wells Fargo, fueled the housing
market crash, leading to an economic downturn called the Great Recession, and threatening to destroy the
international financial system. 1 Federal government agencies have fined Wells Fargo about $3 billion for their
behavior in the crisis, which also included defrauding the Federal Housing Administration (FHA) to insure
improper mortgages.
In 2016, a Senate committee grilled top Wells Fargo executives about their actions in a scandal involving the
creation of at least 3.5 million bank accounts without their customers knowledge or agreement, leading to
improper fees, deleterious credit reports, and misuse of private information. In early 2018, citing
dissatisfaction with Wells Fargo’s progress in reforming its risk controls and leadership, the Federal Reserve
ordered Wells Fargo to limit its assets to $1.95 trillion. As of September 2021 the bank has been issued
more than $5 billion in fines and penalties by the government.
While Wells Fargo has made numerous steps to redeem its behavior, including management changes,
centralizing their financial system, and rebranding, its involvement in other scandals that continue to be
revealed. Regardless of this, Wells Fargo continues to be highly profitable and ranked as one of the US’s
largest companies.
Main Content
On March 18, 1852, Henry Wells and William G. Fargo founded Wells, Fargo & Company 2 in order to handle
the banking and express business generated by the California Gold Rush. From about 1855 to 1865, Wells
Fargo expanded into the stagecoach business by handling many overland routes in the West in addition to
operating the western part of the Pony Express route. A series of bank mergers in the 20th century grew the
company so that by the early 21st century its thousands of branches made it one of the US’s biggest
banks. 3
As of July 2021, Wells Fargo & Company “has approximately $1.9 trillion in assets, and proudly serves one
in three U.S. households and more than 10% of small businesses in the U.S.” 4 The company took number
37 on Fortune’s 2021 rankings of America’s largest corporations. 5
Wells Fargo has weathered numerous scandals in the 21st century, however, that have tarnished its storied
reputation. Its participation in the 2007/2008 financial crisis, also known as the Great Recession, embroiled
1 Duignan, B. (2019, October 7). Financial crisis of 2007–08. Encyclopedia Britannica.
https://www.britannica.com/event/financial-crisis-of-2007-2008
2 History of Wells Fargo – Wells Fargo. (n.d.). Wells Fargo – Banking, Credit Cards, Loans, Mortgages & More.
https://www.wellsfargo.com/about/corporate/history/
3 Chandler, R. (2020, March 12). Wells Fargo. Encyclopedia Britannica. https://www.britannica.com/topic/Wells-FargoAmerican-corporation
4 Wells Fargo reports second quarter 2021 financial results. (n.d.). Wells Fargo Newsroom.
https://newsroom.wf.com/English/news-releases/news-release-details/2021/Wells-Fargo-Reports-Second-Quarter2021-Financial-Results/default.aspx
5 Fortune 500 Wells Fargo https://fortune.com/company/wells-fargo/fortune500/
© 2021 Professional Risk Managers’ International Association
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it in a “continuing string of settlements and scandals,” 6 that involved an April 2016 penalty of $1.2 billion for
deceiving the Federal Housing Administration (FHA) into insuring mortgages that didn’t qualify for federal
coverage between 2001 and 2008. In August 2018, Wells Fargo was hit with another penalty due to the
sale of poor-quality mortgage-backed securities leading to the 2007/2008 financial crisis, this one totaling
$2.1 billion. The Justice Department blamed Wells Fargo for packaging tens of thousands of loans into
securities that were then defaulted, resulting in the loss of billions of dollars by investors, including financial
institutions insured by the federal government. 7
Apart from its actions in the Great Recession, as early as 2002, Wells Fargo began an aggressive practice of
cross-selling, or having customers engage in multiple bank services in order, ostensibly, to better serve their
financial needs, but ultimately to provide the bank with significantly bigger profits. 8 Wells Fargo CEO John
Stumpf distilled cross-selling in the phrase “eight is great,” or every customer should have eight Wells Fargo
products. 9
Cross-selling required employees to meet sales quotas so high that they were often impossible to achieve,
creating an atmosphere of pressure and fear.10 Branch managers at locations who did not meet the quotas
assigned to them had the shortfall added to the next day’s goals. Branch employees earned incentives if they
met their goals, which for personal bankers reached 15 to 20 percent of their salaries, and up to 3 percent
for bank tellers. Employees who neglected to reach their quotas faced reprimands or dismissal. Such
pressure led to unethical behavior on the part of some employees. (Tayan, 2019)
First, customers were convinced to buy products they did not need. Next, some employees opened accounts
in customers’ names without their knowledge, forged their signatures, and transferred funds between their
accounts to pay overdraft fees. Employees also set up credit cards, loans, and monitoring programs. Often
these actions took place with supervisors’ full knowledge.
The fake accounts scandal erupted in full due to an LA Times investigation in 2013. Wells Fargo eventually
admitted that more than 3.5 million accounts were created without customers’ consent. Lower-income
customers faced the brunt of the harm these actions inflicted, particularly by lowered credit scores, since this
number can result in difficulties in obtaining a job, renting an apartment, obtaining a loan, and buying a car
or home. In addition, at least $11 million in fees were charged to customers due to the fraudulent accounts.
("Wells Fargo fake account scandal," 2018)
6 Shen, L. (2018, August 1). Wells Fargo just got hit with a $2.1 billion penalty for the financial crisis. Fortune.
https://fortune.com/2018/08/01/wells-fargo-financial-crisis-fine-mortgage-backed-security/
7 Glazer, E. (2018, August 1). Wells Fargo reaches $2.09 billion settlement over mortgage-backed securities. WSJ.
https://www.wsj.com/articles/wells-fargo-agrees-to-2-09-billion-settlement-for-crisis-era-mortgage-loans-1533147302
8 Tayan, B. (2019, February 6). The Wells Fargo cross-selling scandal. The Harvard Law School Forum on Corporate
Governance. https://corpgov.law.harvard.edu/2019/02/06/the-wells-fargo-cross-selling-scandal-2/
9 Wells Fargo banking scandal. (2018, July). Markkula Center for Applied Ethics at Santa Clara University.
https://www.scu.edu/ethics/focus-areas/business-ethics/resources/wells-fargo-banking-scandal/
10 Wells Fargo fake account scandal. (2018, July 11). Center for Progressive Reform.
https://progressivereform.org/our-work/consumer-protection/civjustice_wellsfargo/
© 2021 Professional Risk Managers’ International Association
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An independent firm conducted an investigation into all accounts opened from 2011 on. Tens of thousands
of employees were interviewed by then, and 5,300 were fired from 2011 to 2015, due to unethical
business practices. (Tayan, 2019)
In a Senate hearing on September 20, 2016 featuring Wells Fargo CEO John Stumpf, Sen. Elizabeth Warren,
D-Mass., said:
Here's what really gets me about this, Mr. Stumpf. If one of your tellers took
a handful of $20 bills out of the cash drawer, they'd probably be looking at
criminal charges for theft. They could end up in prison. But you squeezed
your employees to the breaking point so they would cheat customers and
you could drive up the value of your stock and put hundreds of millions of
dollars in your own pocket.
And when it all blew up, you kept your job, you kept your multi-million-dollar
bonuses, and you went on television to blame thousands of $12-an-hour
employees who were just trying to meet cross-sell quotas that made you
rich. This is about accountability. You should resign. You should give back
the money that you took while this scam was going on, and you should be
criminally investigated by both the Department of Justice and the Securities
and Exchange Commission. This just isn't right. 11
Senators also criticized the board of directors’ decision not to clawback millions in salary and bonuses paid
to John Stumpf or head of retail sales Carrie Tolstedt. Stumpf resigned without comment on October 12,
2016. 12 Carrie Tolstedt retired in September 2016. 13
On February 21, 2020, Wells Fargo agreed to pay $3 billion in a settlement with the Justice Department and
the Securities and Exchange Commission. An attorney for the Central District of California stated, “This case
illustrates a complete failure of leadership at multiple levels … Wells Fargo traded its hard-earned reputation
for short-term profits, and harmed untold numbers of customers along the way.” 14 The $3 billion settlement
raises the amount owed in penalties and fines to an excess of $5 billion as of September 2021. 15
11 Chappell, B. (2016, September 20). 'You should resign': Watch sen. Elizabeth Warren grill Wells Fargo CEO John
Stumpf. NPR.org. https://www.npr.org/sections/thetwo-way/2016/09/20/494738797/you-should-resign-watch-senelizabeth-warren-grill-wells-fargo-ceo-john-stumpf
Wells Fargo Chairman, CEO John Stumpf Retires; Board of Directors Elects Tim Sloan CEO, Director; Appoints Lead
Director Stephen Sanger Chairman, Director Elizabeth Duke Vice Chair. (2016, October 12). Business Wire.
12
https://www.businesswire.com/news/home/20161012006336/en/
13
Chappell, B. (2016, September 13). Wells Fargo Unit's Leader Departs With $125M After Bank Incurs Record Fine.
NPR.org. https://www.npr.org/sections/thetwo-way/2016/09/13/493791920/wells-fargo-units-leader-departs-with125-million-after-group-incurs-record-fine
14 Merle, R. (2020, February 21). Wells Fargo reaches $3 billion settlement with DOJ, SEC over fake-accounts scandal.
The Washington Post. https://www.washingtonpost.com/business/2020/02/21/wells-fargo-fake-accounts-settlement/
15 Levitt, H. (2021, September 10). Wells Fargo fined $250M over unresolved issues tied to scandals. ThinkAdvisor.
https://www.thinkadvisor.com/2021/09/10/wells-fargo-fined-250m-over-unresolved-issues-tied-to-scandals/
© 2021 Professional Risk Managers’ International Association
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Wells Fargo has taken a number of actions to recover from the scandal. Product sales goals were eliminated,
and branch incentives were changed to emphasize customer service instead of cross-selling. The board of
directors hired an independent organization to investigate how the fake accounts scandal had been able to
happen. Results published in April 2017 identified multiple contributing causes, including performance and
incentive systems, organizational structure, and leadership failures that involved denial of the scale and
nature of the problem. (Tayan, 2019)
Wells Fargo’s practice of creating performance scorecards led directly to a competitive atmosphere,
micromanagement, shaming of employees who did not measure up, and threats of job loss, all of which
created intense pressure to sell unnecessary and unwanted products to customers, and even to open
fraudulent accounts in their names. Employees guilty of creating fake accounts cited pressure by
management as a greater incentive for their actions than the bonuses they received. 16
The environment of fear engendered by such actions also included observations by witnesses that
“inexperienced bankers were frequently promoted purely based on sales performance, thus creating a
detrimental tier of managers who were inexperienced in necessary core skills.” (Premachandra & Filabi,
2018)
Despite the fact that Wells Fargo installed a hotline for whistleblowers to report violations to senior
management (Tayan, 2019), several employees were allegedly fired for bringing the fake accounts problem
to light. Other warnings about improprieties with the establishment of accounts were simply ignored.
(Premachandra & Filabi, 2018)
The bank’s decentralized organizational structure put risk managers under the supervision of the business
unit leaders, leading them to focus sales practice violations on the actions of specific individuals rather than
as a more systemic issue. While the chief operational risk manager was aware of employees gaming the
system through cross-selling, she believed it was a contained, limited problem, and that other issues of sales
practices and compensation were outside of her responsibilities. (Tayan, 2019)
A look at the account sales statistics, which indicated a ten-fold increase in account sales over a four-year
period, followed by a seven-year decline in accounts being used by customers, would have created a red flag
that the integrity of sales practices might be at fault. However, the bank’s risk systems were not designed to
look at the big picture. 17
Leadership failures were attributed to CEO John Stumpf for accepting sales violations as part of doing
business and not significant financially. He attributed the scandal to “a few bad apples” and denied that the
company incentivized unethical behavior. (Premachandra & Filabi, 2018)
16 Premachandra, B., & Filabi, A. (2018, May). Under pressure: Wells Fargo, misconduct, leadership and culture. Ethical
Systems: NYU Stern's Business and Society Program. https://www.ethicalsystems.org/wpcontent/uploads/2013/07/files_WellsFargoCaseStudy_EthSystems_May2018FINAL.pdf
17
Lessons from Wells Fargo. (2017, May 2). Markkula Center for Applied Ethics at Santa Clara University.
https://www.scu.edu/ethics/leadership-ethics-blog/lessons-from-wells-fargo/
© 2021 Professional Risk Managers’ International Association
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Carrie Tolstedt, while credited with boasting the bank’s bottom line, was also criticized for an “insular and
defensive” management style that made it clear she didn’t want to hear any negative news. (Tayan, 2019)
The board of directors was largely exonerated because they were misinformed, partly by Tolstedt, by the
scale of the sales practice problems. (Tayan, 2019)
Following the April 2017 release of the independent investigation report, the board announced a plan to
centralize control functions, and claw back about $75 million in outstanding awards to Stumpf and Tolstedt.
(Tayan, 2019) Additional actions included replacing key leaders, eliminating sales goals, improving incentive
systems, and establishing a new office of Ethics, Oversight, and Integrity. (Premachandra & Filabi, 2018)
The bank has also issued apologies to the customers affected. 18
In early 2018, the Federal Reserve ordered Wells Fargo, in an unusual step, to cap its assets below $1.95
trillion, until its risk controls and governance improved. The cap keeps Wells Fargo from growing as rapidly as
competing banks, and hampers its ability to make new loans. 19
In a move to salvage its reputation and rebuild trust with the public, Wells Fargo rebranded twice, once in
May 2018 with the tagline “Established 1852. Re-established 2018” and once in January 2019—less than
a year later—with a marketing campaign called “This is Wells Fargo.” The latest rebranding included an
updated logo and stagecoach icon. 20
However, since the rebranding efforts, other misdeeds by Wells Fargo have also surfaced. They include
putting borrowers up-to-date on their home loans in mortgage forbearance without their consent, illegal
repossession of servicemembers’ vehicles, mistaken foreclosure on hundreds of homes, unwarranted fees
added on customer accounts, 21 overcharging foreign exchange customers for seven plus years, a lawsuit
over defrauding customers after numerous scandals, and others. 22
Numerous studies have identified the root cause of Wells Fargo’s woes as a corporate culture whose stated
values did not align with practices. The fake-accounts scandal highlighted, “an organization whose culture
prized short-term rewards at the expense of customers, leaders who didn’t respond quickly enough, and
Thank you. (2017). Wells Fargo Bank, N.A.
https://www08.wellsfargomedia.com/assets/pdf/commitment/TimSloan_Letter.pdf
19 Hussain, N. Z., & Scuffham, M. (2021, July 14). Wells Fargo wary on prospect of asset restriction easing. Reuters.
https://www.reuters.com/business/finance/wells-fargo-beats-profit-estimates-reserve-release-boost-2021-07-14/
20 Roberts, D. (2019, January 24). After scandals, Wells Fargo unveils new slogan, refined logo. See what it looks like.
The Charlotte Observer. https://www.charlotteobserver.com/news/business/banking/article225026785.html
18
21 Warren, Schatz to Wells Fargo: New Reports Show Mistreatment of Customers During Pandemic-Induced Financial
Crisis, Highlighting Broken Culture at the Bank. (2020, July 30). U.S. Senator Elizabeth Warren of Massachusetts.
https://www.warren.senate.gov/newsroom/press-releases/warren-schatz-to-wells-fargo-new-reports-showmistreatment-of-customers-during-pandemic-induced-financial-crisis-highlighting-broken-culture-at-the-bank
22 Manhattan U.S. attorney announces $72.6 million settlement of fraud lawsuit against Wells Fargo bank for
overcharging foreign exchange customers over seven years. (2021, September 28). U.S. Department of Justice.
https://www.justice.gov/usao-sdny/pr/manhattan-us-attorney-announces-726-million-settlement-fraud-lawsuit-againstwells
© 2021 Professional Risk Managers’ International Association
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whose initial crisis management approach didn’t recognize the systemic cause of the scandal.”
(Premachandra & Filabi, 2018)
Wells Fargo’s ethical culture, as with other organizations, serves as the foundation for behavior and decisionmaking by management and employees. Beginning with the board of directors and CEO, and flowing down
to upper management, ethical conduct provides a template for actions by middle managers that were then
transferred down to lower-level employees. (Premachandra & Filabi, 2018)
This complex and multi-layered process can simply be left alone by upper management when the larger
organization turns substantial profits, as Wells Fargo continues to do.
© 2021 Professional Risk Managers’ International Association
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Lessons Learned
1.
2.
3.
4.
5.
6.
Embody the company’s culture and values. Focus on customer service and lawful practices should
be emphasized by upper management and the board of directors and supported down the chain of
command.
Intense pressure to make sales will lead to unethical behavior by some employees. Recognize that
unreasonable goals and fear of job loss will lead some employees to look for the easiest way to
secure their positions, even if it is wrong.
Profit in the bottom line should not excuse ignoring ethical violations. The fake accounts scandal was
portrayed as an isolated incident when in fact it was large scale and involved emotional abuse of
employees and suppression of whistleblowers.
A decentralized business approach obscures systemic problems. Risk management focused on
“transactional” or individual abuses by employees rather than larger problems that drove this
behavior.
Do not ignore bad news. Shielding upper management from negative news can result in missing the
signs of a bigger corporate culture problem and delay meaningful action to solve problems.
Rebranding does not indicate lasting change. Rebranding the advertising of an organization is an
ineffective means of changing corporate culture, even if it does assure the general public of good
intentions. Scrutiny by government officials, guardians of the public wellbeing, can result in hefty
fines and limiting business practices. The continued scandals that Wells Fargo has participated in
indicate deep-seated problems.
Timeline of events
March 18, 1852 .......... Henry Wells and William G. Fargo found Wells, Fargo & Company.
2002 .............................. Wells Fargo initiates aggressive cross-selling mandates. Practice continues until 2016.
2007/2008 .................. Wells Fargo participates in mortgage-backed securities default scandal and FHA fraud.
2013 .............................. LA Times investigation reveals scope of fake accounts scandal.
September 20, 2016 .. Senate committee including Elizabeth Warren grills CEO John Stumpf on fake
accounts practices.
Early 2018 .................... Federal Reserve orders Wells Fargo to limit its assets until business practices improve.
May 2018 ..................... Wells Fargo rebrands with the tagline “Established 1852. Re-established 2018”.
August 2018................. Fines and penalties for Wells Fargo’s participation in 2007/2008 financial crisis
exceed $3 billion.
January 2019 ................ Wells Fargo rebrands with a marketing campaign called “This is Wells Fargo”.
September 2021 ......... Fines and penalties issued by the government for fake accounts reaches $5 billion.
© 2021 Professional Risk Managers’ International Association
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References
Chandler, R. (2020, March 12). Wells Fargo. Encyclopedia Britannica. https://www.britannica.com/topic/Wells-FargoAmerican-corporation
Chappell, B. (2016, September 13). Wells Fargo Unit's Leader Departs With $125M After Bank Incurs Record Fine. NPR.org.
https://www.npr.org/sections/thetwo-way/2016/09/13/493791920/wells-fargo-units-leader-departs-with-125million-after-group-incurs-record-fine
Chappell, B. (2016, September 20). 'You should resign': Watch sen. Elizabeth Warren grill Wells Fargo CEO John Stumpf.
NPR.org. https://www.npr.org/sections/thetwo-way/2016/09/20/494738797/you-should-resign-watch-senelizabeth-warren-grill-wells-fargo-ceo-john-stumpf
Czarnecki, S. (2016, November 28). Timeline of a crisis: Wells Fargo. PR Week.
https://www.prweek.com/article/1417005/timeline-crisis-wells-fargo
Duignan, B. (2019, October 7). Financial crisis of 2007–08. Encyclopedia Britannica.
https://www.britannica.com/event/financial-crisis-of-2007-2008
Glazer, E. (2018, August 1). Wells Fargo reaches $2.09 billion settlement over mortgage-backed securities. WSJ.
https://www.wsj.com/articles/wells-fargo-agrees-to-2-09-billion-settlement-for-crisis-era-mortgage-loans1533147302
History of Wells Fargo – Wells Fargo. (n.d.). Wells Fargo – Banking, Credit Cards, Loans, Mortgages & More.
https://www.wellsfargo.com/about/corporate/history/
Hussain, N. Z., & Scuffham, M. (2021, July 14). Wells Fargo wary on prospect of asset restriction easing. Reuters.
https://www.reuters.com/business/finance/wells-fargo-beats-profit-estimates-reserve-release-boost-2021-07-14/
Levitt, H. (2021, September 10). Wells Fargo fined $250M over unresolved issues tied to scandals. ThinkAdvisor.
https://www.thinkadvisor.com/2021/09/10/wells-fargo-fined-250m-over-unresolved-issues-tied-to-scandals/
Lessons from Wells Fargo. (2017, May 2). Markkula Center for Applied Ethics at Santa Clara University.
https://www.scu.edu/ethics/leadership-ethics-blog/lessons-from-wells-fargo/
Manhattan U.S. attorney announces $72.6 million settlement of fraud lawsuit against Wells Fargo bank for overcharging
foreign exchange customers over seven years. (2021, September 28). U.S. Department of Justice.
https://www.justice.gov/usao-sdny/pr/manhattan-us-attorney-announces-726-million-settlement-fraud-lawsuitagainst-wells
McGee, S. (2016, October 7). Wells Fargo banking scandal a financial crisis we can finally understand. The Guardian.
https://www.theguardian.com/business/us-money-blog/2016/oct/07/wells-fargo-banking-scandal-financial-crisis
Merle, R. (2020, February 21). Wells Fargo reaches $3 billion settlement with DOJ, SEC over fake-accounts scandal. The
Washington Post. https://www.washingtonpost.com/business/2020/02/21/wells-fargo-fake-accounts-settlement/
© 2021 Professional Risk Managers’ International Association
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Premachandra, B., & Filabi, A. (2018, May). Under pressure: Wells Fargo, misconduct, leadership and culture. Ethical
Systems: NYU Stern's Business and Society Program. https://www.ethicalsystems.org/wpcontent/uploads/2013/07/files_WellsFargoCaseStudy_EthSystems_May2018FINAL.pdf
Roberts, D. (2019, January 24). After scandals, Wells Fargo unveils new slogan, refined logo. See what it looks like. The
Charlotte Observer. https://www.charlotteobserver.com/news/business/banking/article225026785.html
Shen, L. (2018, August 1). Wells Fargo just got hit with a $2.1 billion penalty for the financial crisis. Fortune.
https://fortune.com/2018/08/01/wells-fargo-financial-crisis-fine-mortgage-backed-security/
Tayan, B. (2019, February 6). The Wells Fargo cross-selling scandal. The Harvard Law School Forum on Corporate
Governance. https://corpgov.law.harvard.edu/2019/02/06/the-wells-fargo-cross-selling-scandal-2/
Thank you. (2017). Wells Fargo Bank, N.A.
https://www08.wellsfargomedia.com/assets/pdf/commitment/TimSloan_Letter.pdf
Warren, Schatz to Wells Fargo: New Reports Show Mistreatment of Customers During Pandemic-Induced Financial Crisis,
Highlighting Broken Culture at the Bank. (2020, July 30). U.S. Senator Elizabeth Warren of Massachusetts.
https://www.warren.senate.gov/newsroom/press-releases/warren-schatz-to-wells-fargo-new-reports-showmistreatment-of-customers-during-pandemic-induced-financial-crisis-highlighting-broken-culture-at-the-bank
Wells Fargo agrees to pay $2.09 billion penalty for allegedly misrepresenting quality of loans used in residential mortgagebacked securities. (2018, August 1). U.S. Department of Justice. https://www.justice.gov/opa/pr/wells-fargoagrees-pay-209-billion-penalty-allegedly-misrepresenting-quality-loans-used
Wells Fargo banking scandal. (2018, July). Markkula Center for Applied Ethics at Santa Clara University.
https://www.scu.edu/ethics/focus-areas/business-ethics/resources/wells-fargo-banking-scandal/
Wells Fargo Chairman, CEO John Stumpf Retires; Board of Directors Elects Tim Sloan CEO, Director; Appoints Lead Director
Stephen Sanger Chairman, Director Elizabeth Duke Vice Chair. (2016, October 12). Business Wire.
https://www.businesswire.com/news/home/20161012006336/en/
Wells Fargo fake account scandal. (2018, July 11). Center for Progressive Reform. https://progressivereform.org/ourwork/consumer-protection/civjustice_wellsfargo/
Wells Fargo reports second quarter 2021 financial results. (n.d.). Wells Fargo Newsroom.
https://newsroom.wf.com/English/news-releases/news-release-details/2021/Wells-Fargo-Reports-Second-Quarter2021-Financial-Results/default.aspx
© 2021 Professional Risk Managers’ International Association
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