Wells Fargo Advisors: investment adviser

Item 11 questions answered Yes

These questions cover the firm and its advisory affiliates.

• In the past ten years, have you or any advisory affiliate: been charged with any felony?
• In the past ten years, have you or any advisory affiliate: been charged with a misdemeanor listed in Item 11.B.(1)?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have made a false statement or omission?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: entered an order against you or any advisory affiliate in connection with investment-related activity?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?
• Has any self-regulatory organization or commodities exchange ever: found you or any advisory affiliate to have made a false statement or omission?
• Has any self-regulatory organization or commodities exchange ever: found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)?
• Has any self-regulatory organization or commodities exchange ever: disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?
• F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?
• G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C.,
• (1) Has any domestic or foreign court: in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?
• (1) Has any domestic or foreign court: ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?
• (1) Has any domestic or foreign court: ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority?
• (1) Has any domestic or foreign court: Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?

Actions about the firm (19)

1. Dec 20, 2021
   Regulatory Action: FINRA FinalSanctions: Censure; Restitution · Begun Dec 20, 2021 · Resolved Dec 20, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2016049188701

   Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to supervise representatives' 529 plan share-class recommendations. The findings stated that the firm's written supervisory procedures (WSPS) did not reasonably address the share-class suitability factors specific to 529 plan investments. The firm's WSPS for 529 plans did not specifically address the relationship between account beneficiary age, the number of years until funds would be needed to pay qualified education expenses, and 529 plan share-class suitability. Instead, they merely referenced suitability factors generally applicable to all investment products, such as fees and expenses, investment objective and risk tolerance. In addition, the firm's electronic alert system did not include parameters to identify 529 plan share-class recommendations that appeared to be inconsistent with the age of the account beneficiary or the account's stated investment horizon.

2. Dec 13, 2021
   Regulatory Action: FINRA FinalSanctions: Censure; Fine and restitution · Fine: $100,000 · Begun Dec 13, 2021 · Resolved Dec 13, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2016050947801

   Without admitting or denying the findings, the firm consented to the sanctions and to theentry of findings that it failed to establish and maintain a supervisory system that wasreasonably designed to supervise short-term trading of unit investment trusts (UITS). Thefindings stated that the firm did not establish a supervisory system that was reasonablydesigned to identify early uit rollovers. The firm had an automated report that flagged salesof a mutual fund or uit followed within 25 days by a purchase of any of those same products,and in the ordinary course the firm sent switch letters to customers when this report wasgenerated. However, that report did not account for the length of time a uit was held beforeit was sold. As a result, the firm did not have any automated system to identify when uitswere rolled over significantly in advance of their maturity date - even though the firm'swritten supervisory procedures (WSPS) recognized that UITS should generally be held tomaturity. As such, the firm failed to detect that on thousands of occasions, itsrepresentatives recommended potentially unsuitable early series- to-series rollovers. Onthousands of other occasions, the firm failed to detect that its representatives repeatedly recommended other potentially unsuitable early uit rollovers that caused customers to pay unnecessary sales charges. Collectively, these early uit rollovers may have caused customers to pay $375,137.67 in sales charges that they would not have incurred had they held the UITS until their maturity dates. The firm has voluntarily employed corrective measures to revise its procedures, including by revising its WSPS and by implementing improved controls relevant to its uit business, such as establishing automated alerts to assist in identifying when representatives recommend early uit rollovers.

3. Dec 6, 2021
   Regulatory Action: FINRA FinalSanctions: Censure; Civil fine · Fine: $2.2M · Begun Dec 6, 2021 · Resolved Dec 6, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2020066327501

   Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to store records related to its customer identification program (CIP)-an integral part of an anti-money laundering program-in the required non-erasable and non-writable format, known as "write once, read many" (WORM) format. The findings stated that firm personnel discovered that the firm was storing records related to its CIP on a system that was not WORM compliant, and advised an internal working group that addressed books and requirements of the issue. The working group concluded that the issue should be escalated to determine if it needed to be reported to FINRA. The issue, however, was not escalated to the firms' working group that considered FINRA reporting obligations, and the firm did not report it to FINRA or remediate it at that time. The firm continued to store CIP records on the non-WORM compliant platform for more than three years. Approximately 13 million CIP-related records, pertaining to approximately 8.2 million customers, were stored on the non-WORM compliant platform, with approximately 4 million documents having been stored on the firm's non-WORM compliant platform after the issue was discovered. Therefore, the firm violated Exchange Act rule 17A-4(f)(2)(II)(a). In addition, the firm failed to notify FINRA, its designated examining authority, at least 90 days prior to using the non-WORM compliant platform on which it stored the CIP- related records. Therefore, the firm violated Exchange Act rules 17A-4(f)(3)(v) and 17A-4(f)(2)(I).

   The firm entered into an AWC agreement with FINRA on December 6, 2021, fully resolving this matter, which included agreement to the entry of a censure against the firm and a fine payable to FINRA. Fine was received by FINRA on December 23, 2021.

4. Sep 2, 2020
   Regulatory Action: FINRA FinalSanctions: Censure; Restitution, other, civil, and administrative penalty/fines · Fine: $50,000 · Begun Sep 2, 2020 · Resolved Sep 2, 2020 · Acceptance, Waiver & Consent(AWC) · Docket 2016052124001

   Without admitting or denying findings, the firm consented to the sanctions and to the entry of findings that it, together with another member firm, failed to establish and maintain a supervisory system, and failed to enforce written supervisory procedures (WSPS), that were reasonably designed to achieve compliance with FINRA's suitability rule as it pertains to switches from variable annuities to investment company products. As a result the firm is alleged to have violated NASD rule 3010 and FINRA rules 3110 and 2010

   The firm entered into an AWC agreement with FINRA on September 2, 2020, fully resolving this matter, which included agreement to the entry of a censure against the firm, a fine payable to FINRA in the amount of $50,000, and restitution to the customers in the amount of $89,688.31, plus interest on that amount, as set forth in the agreement. Fine received by FINRA September 16, 2020.

5. Mar 11, 2019
   Regulatory Action: SEC FinalSanctions: Disgorgement; Censure, cease and desist · Begun Mar 11, 2019 · Resolved Mar 11, 2019 · Order · Docket 3-19102

   Pursuant to the SEC share class selection disclosure initiative and without admitting or denying the SEC's findings, Wells fargo clearing services LLC ("WCFS") and Wells Fargo Advisors Financial Network, LLC ("respondents"), jointly and severally, consented to the entry of a SEC order alleging that respondents willfully violated section 206(2) of the Investment Advisers Act of 1940 ("Advisers Act") and section 207 of the Advisers Act, in that respondents did not adequately disclose to their clients in either their forms ADV or otherwise their conflicts of interest relating to (a) their receipt of 12B-1 fees and (b) their selection of mutual fund share classes that pay such fees.

   The firm self-reported to the commission the violations in the order pursuant to the division of enforcement's (the "division") share class selection disclosure initiative

6. Jul 6, 2015
   Regulatory Action: FINRA FinalSanctions: Other; N/a · Begun Jul 6, 2015 · Resolved Jul 6, 2015 · Acceptance, Waiver & Consent(AWC) · Docket 2014042689901

   Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it disadvantaged certain retirement plan and charitable organization customers that were eligible to purchase class a shares in certain mutual funds without a front-end sales charge. The findings stated that these customers were instead sold class a shares with a front-end sales charge or class b or c shares with back-end sales charges and higher ongoing fees and expenses. The findings also stated that the firm failed to establish and maintain a supervisory system and procedures reasonably designed to ensure that eligible customers who purchased mutual fund shares received the benefit of applicable sales charge waivers. The firm failed to adopt adequate controls to detect instances in which they did not provide sales charge waivers to customers in connection with their mutual fund purchases.

7. Feb 26, 2013
   Regulatory Action: New York State Department of Financial Services FinalSanctions: Other; Stipulation · Fine: $50,000 · Begun Feb 26, 2013 · Resolved Feb 26, 2013 · Stipulation and Consent · Docket 2012-0184-S

   The New York State Department of Financial Services alleged that during the approximate period of January 2007 through December 2010 Wells Fargo Advisors, LLC, an unlicensed entity, accepted insurance commissions from Wells Fargo Advisors insurance agency LLC, in violation of New York insurance law. The department further alleged that both Wells Fargo Advisors LLC and Wells Fargo Advisors Financial Network LLC provided materially incomplete information in their respective insurance license applications submitted to the state on or about January 27, 2012.

8. May 1, 2012
   Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure restitution · Fine: $2.1M · Begun May 1, 2012 · Resolved May 1, 2012 · Acceptance, Waiver & Consent(AWC) · Docket 2009019113901

   FINRA rule 2010, NASD rules 2110, 2310, 3010 - Wells Fargo Advisors, financial network, LLC failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with NASD and FINRA rules in connection with the sale of non-traditional exchange-traded funds (ETFS) in accounts where the firm provided brokerage services to certain retail customers and the firm failed to provide adequate formal training and guidance to its registered representatives and supervisors regarding non-traditional ETFS. The firm allowed its registered representatives to recommend a non-traditional ETF to customers without performing reasonable diligence to understand the risks and features associated with it. Certain firm registered representatives made unsuitable recommendation of non-traditional ETFS to certain customers with conservative income or conservative growth & income investment objectives and/or risk tolerances.

9. Feb 8, 2012
   Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $90,000 · Begun Feb 8, 2012 · Resolved Feb 8, 2012 · Acceptance, Waiver & Consent(AWC) · Docket 20100229121

   Schedule a, section 1, of the NASD and FINRA by-laws, FINRA rule 2010 NASD rule 2110: until the end of calendar year 2009, the firm reported revenue on its focus reports net of its payout to its financial advisors, rather than as gross revenue, having determined - based partly on the emerging issues task force (EITF) 99-19 - that its net-basis revenue reporting complied with generally accepted accounting principles (GAAP). The firm had followed this accounting protocol since at least 2001, and had alluded to it in its audited financial statements. At the beginning of 2009, a company acquired the firm as part of the company's acquisition of another company, and thereafter proceeded to evaluate the firm's business practices in relation to a separate existing member firm that the acquiring company owned. As a result of that process, the firm changed its practices to reflect and report its revenue on a gross basis. The firm contacted FINRA in November 2009 to advise that the firm's upcoming audited annual financial statement and focus report would reflect a significant change in revenues for calendar year 2009. These year- end 2009 reports reflected approximately $200 million in additional revenues and expenses for the year. For each calendar year from 2001 through 2008, FINRA sent the firm an invoice for the firm's gross income assessment, which FINRA member firms are required to pay pursuant to schedule a, section 1 of FINRA's by-laws. During that period, NASD and FINRA calculated the firm's gross income assessments (GIA) according to the revenue that the firm reported for the previous year in its focus filings. The firm paid these invoices in full. After learning of the firm's history of reporting its revenue on a net basis, FINRA determined that the firm had underpaid its gross income assessments by a total of $595,301.84 between 2001 and 2008. The firm has since paid that amount in full.

10. Oct 4, 2010
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $15,000 · Begun Oct 4, 2010 · Resolved Oct 4, 2010 · Acceptance, Waiver & Consent(AWC) · Docket 2009016286401

    FINRA rule 2010, NASD rules 2110, 3010, 3070 - Wells Fargo Advisors Financial Network, LLC failed to file summary and statistical information for customer complaints by the 15TH day of the month following the calendar quarter in which they were received by the firm. The firm's supervisory system was not reasonably designed to ensure that summary and statistical information of customer complaints was filed in accordance with NASD rule 3070. The firm's supervisory system failed to provide for reasonable follow-up and review to ensure that required customer complaint filings were made.

11. Feb 12, 2009
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $150,500 · Begun Feb 12, 2009 · Resolved Feb 12, 2009 · Acceptance, Waiver & Consent(AWC) · Docket E9A2005013001

    Allegations that the firm (1) made recommendations through its registered representatives to customers to purchase class b and class c mutual fund shares where an equal investment in class a shares would have been more advantageous for certain clients in violation of NASD rule 2310 and (2) failed to establish, maintain and enforce supervisory systems and procedures reasonably designed to provide consideration, on a consistent basis, of the benefits of various mutual fund classes as they applied to individual customers.

12. Feb 20, 2006
    Regulatory Action: State of Florida, Office of Financial Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist and restitution · Fine: $50,000 · Begun Feb 20, 2006 · Resolved Feb 20, 2006 · Stipulation and Consent · Docket 0221-S7/05

    The office of financial regulation alleged that the firm's supervisory system was inadequate with respect to the supervision of recommendations by its associated persons that clients switch from one mutual fund to another in Florida. As noted in the stipulation and consent, since the office's examination, the firm revised it supervisory system and implemented a new computerized supervisory and surveillance system.

13. Sep 17, 2001
    Regulatory Action: NASD (now FINRA) FinalSanctions: Censure; Censure and fine · Fine: $50,000 · Begun Sep 17, 2001 · Resolved Sep 17, 2001 · Acceptance, Waiver & Consent(AWC) · Docket C11010029

    Without admitting or denying the alleged violation. Corporate securities group accepted and consented to the entry of the following by the NASD. During 1997 and 1998, corporate securities group failed to establish an adequate supervisory system of follow-up and review to ensure review of active accounts and failed to devote sufficient resources to its supervisory system to detect and prevent unsuitable activity in customer accounts.

    The acceptance, waiver and consent was made final on 9/17/2001. The firm was censured and fined $50,000.

14. Feb 25, 2000
    Regulatory Action: State of Illinois FinalSanctions: Other · Fine: $3,000 · Begun Jul 29, 1999 · Resolved Feb 25, 2000 · Settled · Docket 9800115

    The State of Illinois initiated an administrative proceding against jwgenesis financial services, inc. alleging failure to supervise registered representative, justyn feldman

15. Apr 6, 1999
    Regulatory Action: NASD (now FINRA) FinalSanctions: Censure; Censure and fine · Fine: $2,500 · Begun Feb 22, 1999 · Resolved Apr 6, 1999 · Acceptance, Waiver & Consent(AWC) · Docket C02990004

    Respondent member executed settlement and release agreements with a public customer containing a confidentialityclause which precluded the customer from cooperating with any securities regulator absent a subpeona or court order and operated to prevent the nasdr from bringing a disciplinary action against one of the firm's former registered representatives because the customer could not cooperate with the nasdr.

    The AWC was accepted on 2/22/1999. The firm was censured and fined $2,500.00

16. Jul 10, 1998
    Regulatory Action: NASD (now FINRA) FinalSanctions: Censure · Fine: $5,000 · Begun Mar 8, 1996 · Resolved Jul 10, 1998 · Settled · Docket C3A96009

    Failure to supervise, inadequate written supervisory procedures

    On August 8, 1997 district 3 entered a decision in which it issued a letter of caution to jwgenesis financial services, inc. the district determined that jwgenesis financial services, inc. reasonably supervised its branch managers but found that the firm did not have the requisite written supervisory procedures in place. On appeal, the national adjudicatory council reverse district 3 decision and found that jwgenesis financial services, inc. did not resonable supervise but did have proper written supervisory procedures

17. Aug 9, 1995
    Regulatory Action: NASD (now FINRA) FinalSanctions: Other · Fine: $1,000 · Begun Dec 14, 1994 · Resolved Aug 9, 1995 · Other · Docket C3A940061

    Failure to supervise, failure to timely file Form U-5

    The claims against the firm for failure to supervise were dismissed in their entirety

18. May 12, 1995
    Regulatory Action: US Securities & Exchange Commission FinalSanctions: Cease and Desist · Fine: $30,000 · Begun Sep 28, 1994 · Resolved May 12, 1995 · Settled · Docket 3-8493

    Failure to reasonable supervise candia mauser, a broker, to prevent her from violating sections 15(a) of the Exchange Act.

19. Feb 5, 1987
    Regulatory Action: NASD (now FINRA) FinalSanctions: Other · Fine: $250 · Begun Feb 5, 1987 · Resolved Feb 5, 1987 · Acceptance, Waiver & Consent(AWC) · Docket MS-483-AWC (A)

    Failure to report its Nasdaq volume in 9 securities on May 28, 1986 and 11 securities on October 31, 1986

Actions about affiliates (112)

1. Jan 17, 2025
   Regulatory Action: SEC FinalAbout an affiliate: Wells Fargo ClearingSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure · Fine: $7.0M · Begun Jan 17, 2025 · Resolved Jan 17, 2025 · Order · Docket FILE NO. 3-22430

   The Securities and Exchange Commission ("SEC") entered into a settlement order with Wells Fargo Clearing services, LLC ("WFCS") and Wells Fargo Advisors Financial Network, LLC ("WFAFN") (collectively, the "firms") to settle an administrative action which alleged that, from 2019 through May 2024, the firms failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Investment Advisers Act of 1940 ("Advisers Act") and the rules thereunder relating to its cash sweep program, specifically, its use of a bank deposit sweep program ("BDSP"). The order found that the firms did not adopt and implement reasonably designed policies and procedures (I) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; and (II) concerning the duties of the firm's advisors in managing client cash in advisory accounts, in willful violation of section 206(4) of the Advisers Act and rule 206(4)-7 thereunder.

   On January 17, 2025, the SEC entered into a settlement order with the firms to settle an administrative action which alleged that, from 2019 through May 2024, the firms failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder relating to its cash sweep program, specifically, its use of a BDSP. The order found that the firms did not adopt and implement reasonably designed policies and procedures (I) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; and (II) concerning the duties of the firm's advisors in managing client cash in advisory accounts, in willful violation of section 206(4) of the Advisers Act and rule 206(4)-7 thereunder. Wfafn, without admitting or denying the findings, consented to a settlement that included a cease and desist order, censure, and civil money penalty of $7 million. The civil monetary penalty was paid in accordance with the terms of the order.

2. Jan 16, 2025
   Regulatory Action: Bloomberg SEF LLC FinalAbout an affiliate: Wells Fargo Bank,Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1,250 · Begun Jan 16, 2025 · Resolved Jan 16, 2025 · Other · Docket N/A

   Bloomberg SEF LLC ("Bloomberg SEF") alleged that Wells Fargo Bank, national association ("the firm") failed to timely notify Bloomberg SEF after an erroneous trade was discovered, in violation of Bloomberg SEF rule 516.

   Bloomberg SEF issued a summary fine in the amount of $1,250 to the firm. The payment was made in accordance with the terms of the notice of fine.

3. Aug 25, 2023
   Regulatory Action: SEC FinalAbout an affiliate: Wells Fargo ClearingSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist censure · Fine: $35.0M · Begun Aug 25, 2023 · Resolved Aug 25, 2023 · Order · Docket FILE NO. 3-21580

   The Securities and Exchange Commission ("SEC") alleged that Wells Fargo Clearing services, LLC, Wells Fargo Advisors Financial Network, LLC, and their predecessor firms (collectively, "Wells fargo" or the "firm") overcharged approximately 10,945 advisory accounts of advisory clients opened through 2014 more than $26.8 million in advisory fees from at least 2002 through December 2022 and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the overbilling in willful violation of sections 206(2) and 206(4) of the Investment Advisers Act of 1940 ("Advisers Act") and rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts.

   On August 25, 2023, the SEC entered into a settlement order with Wells fargo to settle an administrative action which alleged that Wells fargo overcharged approximately 10,945 advisory accounts of advisory clients opened through 2014 more than $26.8 million in advisory fees from at least 2002 through December 2022 and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the overbilling in willful violation of sections 206(2) and 206(4) of the Investment Advisers Act of 1940 ("Advisers Act") and rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts. In 2022 and 2023, the firm corrected the advisory fees to be charged to the accounts and issued payments for the overcharged advisory fees, plus interest, to the affected accountholders. Without admitting or denying the findings, Wells fargo agreed to: (a) cease and desist from committing or causing any violations or any future violations of sections 206(2) and 206(4) of the Advisers Act and rule 206(4)-7 thereunder, (b) be censured, and (c) pay a civil monetary penalty in the amount of $35,000,000. The civil monetary penalty was paid in accordance with the terms of the order.

4. Aug 8, 2023
   Regulatory Action: CFTC FinalAbout an affiliate: Wells Fargo Bank N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, undertaking · Fine: $75.0M · Begun Aug 8, 2023 · Resolved Aug 8, 2023 · Order · Docket DOCKET NO. 23-36

   The Commodity Futures Trading Commission ("CFTC") entered into a settlement order ("order") with Wells fargo securities, LLC ("WFS") and Wells Fargo Bank NA ("WFB" and collectively with WFS, the "respondents") to settle an administrative action concerning (a) WFB's failure to maintain required records in violation of sections 4s(f)(1)(c) and 4s(g)(1) and (3) of the Commodity Exchange Act ("act") and regulations 23.201(a) and 23.202(a)(1) and (b)(1); (b) WFS's failure to keep required records in violation of section 4g of the act and regulation 1.35; (c) respondents' failure to keep records in the required manner in violation of regulation 1.31; (d) WFB's failure to supervise diligently in violation of sections 4s(h)(1)(b) of the act and regulation 23.602(a); and (e) WFS's failure to diligently supervise in violation of regulation 166.3.

   On August 8, 2023, the CFTC entered into an order with the respondents to settle an administrative action concerning (a) WFB's failure to maintain required records in violation of sections 4s(f)(1)(c) and 4s(g)(1) and (3) of the act and regulations 23.201(a) and 23.202(a)(1) and (b)(1); (b) WFS's failure to keep required records in violation of section 4g of the act and regulation 1.35; (c) respondents' failure to keep records in the required manner in violation of regulation 1.31; (d) WFB's failure to supervise diligently in violation of sections 4s(h)(1)(b) of the act and regulation 23.602(a); and (e) WFS's failure to diligently supervise in violation of regulation 166.3. The respondents admitted to the facts in the settlement order, acknowledged their conduct violated the act and regulations and consented to: (a) the entry of the CFTC's findings; (b) have WFB cease and desist from violating sections 4s(f)(1)(c), 4s(g)(1) and (3), and 4s(h)(1)(b) of the act, and regulations 1.31, 23.201(a), 23.202(a)(1) and (b)(1) and 23.602(a) and to have WFS cease and desist from violating section 4g of the act and regulations 1.31, 1.35 and 166.3, (c) pay a civil monetary penalty in the amount of $75,000,000, and (d) comply with certain conditions and undertakings. The civil monetary penalty was paid in accordance with the terms of the order.

5. Aug 8, 2023
   Regulatory Action: SEC FinalAbout an affiliate: Wells Fargo ClearingSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, undertaking · Fine: $125.0M · Begun Aug 8, 2023 · Resolved Aug 8, 2023 · Order · Docket FILE NO. 3-21552

   The Securities and Exchange Commission ("SEC") alleged, in connection with the broker-dealer off-channel communications initiative, that Wells fargo securities, LLC, Wells Fargo Clearing services, LLC, and Wells Fargo Advisors Financial Network, LLC (collectively, "Wells fargo") failed to (1) maintain and preserve off-channel communications related to the business of the broker-dealers operated by Wells fargo, in willful violation of section 17(a) of the Securities Exchange Act of 1934 ("Exchange Act") and rule 17A-4(b)(4) thereunder; and (2) reasonably supervise their employees with a view to preventing or detecting certain of their employees' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act.

   On August 8, 2023, the SEC entered into a settlement order with Wells fargo to settle an administrative action, in connection with the broker-dealer off-channel communications initiative, which alleged that Wells fargo failed to (1) maintain and preserve off-channel communications related to the business of the broker-dealers operated by Wells fargo, in willful violation of section 17(a) of the Securities Exchange Act of 1934 ("Exchange Act") and rule 17A-4(b)(4) thereunder; and (2) reasonably supervise their employees with a view to preventing or detecting certain of their employees' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act. Wells fargo admitted to the facts in the settlement order, acknowledged their conduct violated the federal securities laws and agreed to: (a) cease and desist from committing or causing any violations or any future violations of section 17(a) of the Exchange Act and rule 17A-4 thereunder, (b) be censured, (c) pay a civil monetary penalty in the amount of $125,000,000, and (d) comply with certain undertakings related to retention of electronic communications. The civil monetary penalty was paid in accordance with the terms of the order.

6. Mar 30, 2023
   Regulatory Action: Board of Governors of the Federal Reserve System FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $67.8M · Begun Mar 30, 2023 · Resolved Mar 30, 2023 · Order · Docket 22-011-CMP-HC

   On March 30TH, 2023, the Board of Governors of the Federal Reserve System (the "Board of Governors") issued an order of assessment of civil money penalty issued upon consent pursuant to the federal deposit insurance act, as amended (the "order") imposing a civil money penalty on Wells Fargo & Company ("WFC"), the applicant's parent entity, for unsafe and unsound practices relating to failures in WFC's risk-management and oversight framework for identifying and addressing legal and compliance risks. Specifically, WFC's subsidiary bank, Wells fargo bank, N.A., (the "bank"), provided a trade finance software platform to a non-US bank, which, during the period of December 2011 to December 2015, the non-US bank used to process non-US dollar trade finance instruments outside the US financial system involving parties in jurisdictions subject at the time to sanctions regulations. The order provides that WFC's risk-management and oversight framework failure to identify and address the legal and compliance risks with respect to the bank's provision of the software to a nonus bank constitutes unsafe and unsound practices.

   The Board of Governors assessed a civil money penalty on Wells Fargo & Company for unsafe and unsound practices in respect of failures in its riskmanagement and oversight framework that enabled Wells Fargo & Company's subsidiary bank to provide a trading platform to a non-US bank that allowed that bank to process certain non-US dollar transactions involving parties in jurisdictions subject to OFAC regulations.

7. Dec 20, 2022
   Regulatory Action: Consumer Financial Protection Bureau FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Remediation, process changes · Fine: $1.7B · Begun Dec 20, 2022 · Resolved Dec 20, 2022 · Stipulation and Consent · Docket 2022-CFPB-0011

   The CFPB alleged that certain of the bank's auto loan servicing, mortgage loan servicing, and Consumer deposit account practices were unfair, and that one Consumer deposit account practice was deceptive, as further described in the consent order.

   The order is final and the penalty has been paid.

8. Sep 27, 2021
   Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil Penalty(ies)/Fine(s); Civil asset forfeiture · Fine: $37.3M · Begun Sep 27, 2021 · Resolved Sep 27, 2021 · Settled

   The United States attorney's office for the southern district of New York alleged that from 2010 through 2017, Wells Fargo Bank, N.A. defrauded 771 commercial customers who used the bank's FX services by misrepresenting FX pricing levels and engaging in other improper FX pricing practices in violation of the mail fraud, wire fraud, and bank fraud statutes 18 U.S.C. §§ 1341, 1343, 1344.

   Restitution of $35,337,319.90 was paid to affected consumers.

9. Sep 7, 2021
   Regulatory Action: Office of Comptroller of the Currency (OCC) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $250.0M · Begun Sep 7, 2021 · Resolved Sep 7, 2021 · Other · Docket AA-ENF-2021-29 & AA-ENF-2021-20

   Without admitting liability, the bank consented to consent agreements in which the office of the Comptroller of the Currency (OCC) alleged the bank engaged in (1) unsafe or unsound practices related to loss mitigation activities and inadequate independent risk management and internal audit of the loss mitigation and (2) violations covered under the 2018 consent order, AA-EC-2018-15. Wells Fargo Bank, N.A. agreed to pay a civil money penalty of $250,000,000. To the OCC upon acceptance of the consent agreement and within 150 days provide the OCC examiner-in-charge a written acceptable action plan for remedial actions under the agreement.

   N/a

10. Jun 15, 2020
    Regulatory Action: Office of Attorney General, State of Maryland FinalAbout an affiliate: Wells Faro & CompanySanctions: Restitution · Fine: $20.0M · Begun Jun 15, 2020 · Resolved Jun 15, 2020 · Settled · Docket 2016-0833

    Without admitting or denying liability, Wells fargo & company (WF&co) entered into a consent order in which WF&co was alleged to have violated §11­301(2) of the Maryland Securities Act, related to the creation, pooling, structuring, sponsorship, packaging, marketing, underwriting, sale or issuance of residential mortgage-backed securities ("RMBS") between January 1, 2005 and January 1, 2009. WF&co agreed to pay restitution of $20,000,000 to the state of Maryland within thirty (30) business days.

11. Feb 27, 2020
    Regulatory Action: SEC FinalAbout an affiliate: Wells Fargo Clearing; the full record is on the affiliate's own Form ADVSanctions: Cease and Desist · Fine: $35.0M · Begun Feb 27, 2020 · Resolved Feb 27, 2020 · Order · Docket FILE NO. 3-19714

    The Securities and Exchange Commission (SEC) charged Wells Fargo Clearing services, LLC and Wells Fargo Advisors Financial Network, LLC with willfully violating section 206(4) of the Investment Advisers Act of 1940 (Advisers Act) and rule 206(4)-7 thereunder, failing reasonably to fulfill their supervisory responsibilities within the meaning of section 203(e)(6) of the Advisers Act and failing reasonably to fulfill their supervisory responsibilities within the meaning of section 15(b)(4)(e) of the Securities Exchange Act of 1934 (Exchange Act).

    The commission found that, from April 2012 through September 2019, the firms recommended that many retail investment advisory clients and brokerage customers buy and hold single-inverse exchange-traded funds (ETFS) without having adequate compliance policies and procedures and without providing financial advisors proper training and supervision of single-inverse ETFS. The commission found that, as a result, certain investment adviser representatives and registered representatives made unsuitable recommendations to certain clients. The commission found that the firms willfully violated section 206(4) of the Advisers Act and rule 206(4)-7 thereunder, failed reasonably to fulfill their supervisory responsibilities within the meaning of section 203(e) (6) of the Advisers Act and failed reasonably to fulfill their supervisory responsibilities within the meaning of section 15(b)(4)(e) of the Exchange Act. The firms consented, without admitting or denying the findings contained in the order, to: (a) cease and desist from committing or causing any violations and any future violations of section 206(4) of the Advisers Act and rule 206(4)-7 thereunder, (b) be censured, and (c) jointly and severally pay a civil monetary penalty in the amount of $35,000,000.

12. Feb 21, 2020
    Regulatory Action: SEC FinalAbout an affiliate: Wells Fargo & CompanySanctions: Cease and Desist; Civil and administrative penalty(IES)/fine(s) · Fine: $500.0M · Begun Feb 21, 2020 · Resolved Feb 21, 2020 · Order · Docket NO. 3-19704

    Wells Fargo & Company ("WFC") violated section 10(b) of the Exchange Act of 1934 (the "Exchange Act") and rule 10B-5 thereunder with respect to its historical community bank sales practices and related disclosures.

    WFC consented to the entry of the SEC order and agreed to pay a civil penalty of $500 million and to be enjoined from future violations of section 10(b) of the Exchange Act and rule 10B-5 thereunder. WFC also agreed to engage outside experienced securities counsel to conduct an assessment of the regulation d policies and procedures of WFC and certain of its subsidiaries and to present to the SEC on the implementation of recommendations made by outside counsel.

13. Nov 8, 2019
    Regulatory Action: CFTC FinalAbout an affiliate: Wells Fargo Bank, N. A..Sanctions: Cease and Desist; Civil and administrative penalty(IES), undertakings, and restitution. · Fine: $10.0M · Begun Nov 8, 2019 · Resolved Nov 8, 2019 · Order · Docket CFTC DOCKET NO 20-08

    The CFTC found that Wells fargo bank, N.A. (WFBNA) mispriced a foreign exchange transaction executed on behalf of a counterparty in August 2014, because WFBNA did not have a system in place to accurately track trades used to fill a counterparty's orders and did not implement procedures designed to ensure that accurate information was provided to the counterparty. Accordingly, the CFTC found that the bank violated section 4s(h)(1)(b) and (3)(c) of the Commodity Exchange Act, 7 U.S.C. SEC. 6s(h)(1)(b) and (3)(c) (2012), and regulations 23.4.02(a)(1)(I) and (2) and 23.433, 17 C.F.R. Secs. 23.402(a)(1)(I) and (2) and 23.433 (2019). Without admitting or denying the findings, WFBNA consented to entry of the CFTC's order.

14. Aug 9, 2019
    Regulatory Action: National Futures Association FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.5M · Begun Aug 9, 2019 · Resolved Aug 9, 2019 · Decision · Docket 19-BCC-010

    Without admitting the allegations, Wells Fargo Bank, N.A. ("WFBNA") consented to a settlement in which it was alleged and found to have violated NFA compliance rule 2-49(a) by failing to communicate with a counterparty in a fair and balanced manner as required under Commodity Futures Trading Commission regulation 23-433. WFBNA agreed to pay a civil money penalty of $2,500,000.00 to the National Futures Association within 30 days.

15. Jan 2, 2019
    Regulatory Action: California Department of Insurance FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Other; Administrative proceeding initiated · Fine: $10.3M · Begun Nov 30, 2017 · Resolved Jan 2, 2019 · Settled · Docket LA2016000665-AP

    The California Department of Insurance filed a disciplinary action for alleged improper sales practices between 2008 and 2016 concerning the bank's online insurance referral program for renters and simplified-issue term life insurance. The insurance products were offered by referral through third-party carriers american modern insurance group, assurant, great west financial, and prudential insurance company. The California Department of Insurance alleges that Wells fargo's actions are grounds for suspending or revoking the insurance licenses for Wells Fargo Bank, N.A. and Wells fargo insurance, inc.

16. Dec 28, 2018
    Regulatory Action: State Attorney General - California FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $148.7M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket 18-ST-CV-09856

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

17. Dec 28, 2018
    Regulatory Action: State Attorney General - Alaska FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

18. Dec 28, 2018
    Regulatory Action: State Attorney General - Wisconsin FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $8.6M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

19. Dec 28, 2018
    Regulatory Action: State Attorney General - West Virginia FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.7M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

20. Dec 28, 2018
    Regulatory Action: State Attorney General - Vermont FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.0M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

21. Dec 28, 2018
    Regulatory Action: State Attorney General - Washington FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $16.1M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket 18-2-06490-34

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

22. Dec 28, 2018
    Regulatory Action: State Attorney General - Utah FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $10.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

23. Dec 28, 2018
    Regulatory Action: State Attorney General - Virginia FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $11.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

24. Dec 28, 2018
    Regulatory Action: State Attorney General - Tennessee FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.0M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket 19C69

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

25. Dec 28, 2018
    Regulatory Action: State Attorney General - Texas FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $47.4M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket D-1-GN-18-007683

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

26. Dec 28, 2018
    Regulatory Action: State Attorney General - South Dakota FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.8M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

27. Dec 28, 2018
    Regulatory Action: State Attorney General - South Carolina FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $6.8M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

28. Dec 28, 2018
    Regulatory Action: State Attorney General - Rhode Island FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket PC-2018-9401

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

29. Dec 28, 2018
    Regulatory Action: State Attorney General - Pennsylvania FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $16.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

30. Dec 28, 2018
    Regulatory Action: State Attorney General - Oklahoma FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.6M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

31. Dec 28, 2018
    Regulatory Action: State Attorney General - Ohio FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $3.0M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

32. Dec 28, 2018
    Regulatory Action: State Attorney General - North Dakota FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

33. Dec 28, 2018
    Regulatory Action: State Attorney General - North Carolina FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $15.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

34. Dec 28, 2018
    Regulatory Action: State Attorney General - New York FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $11.9M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

35. Dec 28, 2018
    Regulatory Action: State Attorney General - New Jersey FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $17.0M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

36. Dec 28, 2018
    Regulatory Action: State Attorney General - New Hampshire FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket 217-2018-CV-00811

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

37. Dec 28, 2018
    Regulatory Action: State Attorney General - Alabama FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $7.9M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

38. Dec 28, 2018
    Regulatory Action: State Attorney General - New Mexico FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $6.4M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket D-101-CV-2018-02395

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

39. Dec 28, 2018
    Regulatory Action: State Attorney General - Michigan FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

40. Dec 28, 2018
    Regulatory Action: State Attorney General - Wyoming FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.6M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

41. Dec 28, 2018
    Regulatory Action: State Attorney General - Oregon FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $9.8M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

42. Dec 28, 2018
    Regulatory Action: State Attorney General - Nebraska FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.2M · Begun Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

43. Dec 28, 2018
    Regulatory Action: State Attorney General - Nevada FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $13.4M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

44. Dec 28, 2018
    Regulatory Action: State Attorney General - Montana FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.8M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

45. Dec 28, 2018
    Regulatory Action: State Attorney General - Mississippi FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

46. Dec 28, 2018
    Regulatory Action: State Attorney General - Missouri FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.6M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket 18AC-CC00516

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

47. Dec 28, 2018
    Regulatory Action: State Attorney General - Minnesota FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $9.4M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket 62-CV-18-8322

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

48. Dec 28, 2018
    Regulatory Action: State Attorney General - Maryland FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $7.9M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

49. Dec 28, 2018
    Regulatory Action: State Attorney General - Massachusetts FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $6.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

50. Dec 28, 2018
    Regulatory Action: State Attorney General - Maine FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.1M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

51. Dec 28, 2018
    Regulatory Action: State Attorney General - Louisiana FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.9M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

52. Dec 28, 2018
    Regulatory Action: State Attorney General - Kentucky FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $3.7M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

53. Dec 28, 2018
    Regulatory Action: State Attorney General - Kansas FinalAbout an affiliate: State Attorney General -Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.3M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells fargo & company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

54. Dec 28, 2018
    Regulatory Action: State Attorney General - Iowa FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $6.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

55. Dec 28, 2018
    Regulatory Action: ( g g g y y ) FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

56. Dec 28, 2018
    Regulatory Action: State Attorney General - Illinois FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $10.9M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

57. Dec 28, 2018
    Regulatory Action: State Attorney General - Idaho FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.3M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled · Docket CV01-18-23986

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

58. Dec 28, 2018
    Regulatory Action: State Attorney General - Hawaii FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

59. Dec 28, 2018
    Regulatory Action: State Attorney General - Georgia FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $16.3M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

60. Dec 28, 2018
    Regulatory Action: State Attorney General - Florida FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $28.3M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

61. Dec 28, 2018
    Regulatory Action: State Attorney General - District of Columbia FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.1M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

62. Dec 28, 2018
    Regulatory Action: State Attorney General - Delaware FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.0M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

63. Dec 28, 2018
    Regulatory Action: State Attorney General - Connecticut FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $5.2M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

64. Dec 28, 2018
    Regulatory Action: State Attorney General - Colorado FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $21.5M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

65. Dec 28, 2018
    Regulatory Action: State Attorney General - Arizona FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $37.1M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

66. Dec 28, 2018
    Regulatory Action: State Attorney General - Arkansas FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.3M · Begun Dec 28, 2018 · Resolved Dec 28, 2018 · Settled

    Wells Fargo & Company entered into a settlement with all 50 state attorneys general and the District of Columbia regarding previously disclosed retail sales practices, auto collateral protection insurance and guaranteed asset/auto protection, and mortgage interest rate lock matters. Under the terms of the agreement, Wells fargo agreed to pay a total of $575 million to resolve potential civil claims by state attorneys general.

67. Nov 27, 2018
    Regulatory Action: Office of Attorney General, State of Illinois FinalAbout an affiliate: Wells Fargo & CompanySanctions: Restitution · Fine: $17.2M · Begun Nov 27, 2018 · Resolved Nov 27, 2018 · Settled · Docket N/A

    Without admitting liability, Wells Fargo & Company (WFC) consented to a settlement agreement with the Illinois attorney general's office in which WFC agreed to pay $17.25MM in restitution to designated illiniois state pensions to resolve an investigation of . Wells fargo mortgage - related securitizations issued before January 1, 2009.

68. Oct 18, 2018
    Regulatory Action: Office of Attorney General, State of New York FinalAbout an affiliate: Wells Fargo & CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $65.0M · Begun Oct 18, 2018 · Resolved Oct 18, 2018 · Settled · Docket 18/121

    Without admitting liability, Wells Fargo & Company (WF&co) consented to a settlement agreement in which the Office of Attorney General, State of New York (OAG), alleged WF&co engaged in violations of NY general business law, § 352 et seq., executive law § 63(12), and the common law of the state of NY, related to representations to investors. Wells Fargo & Company agreed to pay a civil money penalty of $65,000,000. To the OAG within ten (10) business days.

    N/a

69. Aug 1, 2018
    Regulatory Action: U.S. Department of Justice FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2.1B · Resolved Aug 1, 2018 · Settled

    Without admitting liability, the bank consented to a civil settlement agreement in which the US DOJ alleged the bank engaged in violations covered under the financial institutions reform, recovery and enforcement act of 1989, 12 U.S.C. § 1833a, related to representations, disclosures or non-disclosures to RMBS investors or third parties that were passed through to RMBS investors. Wells Fargo Bank, N.A. agreed to pay a civil money penalty of $2,090,000,000 to the civil division of the U.S. Department of Justice within fifteen (15) days.

70. Apr 20, 2018
    Regulatory Action: Bureau of Consumer Financial Protection FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: p; Restitution disgorgement cease and desist · Fine: $500.0M · Begun Apr 20, 2018 · Resolved Apr 20, 2018 · Consent · Docket 2018-BCFP-0001

    Without admitting or denying the findings of fact or conclusions of law, the bank consented to the issuance of an order in which the CFPB found that the bank engaged in unfair acts or practices in violation of sections 1031(c) and 1036(a)(1)(b) of the consumer financial protection act of 2010 (CFPA) for certain specified acts and practices related to: (1) the bank's failure to follow the mortgage-interest-rate-lock process it explained to some prospective borrowers; and (2) the bank's force-placed automobile collateral protection insurance (CPI) program. In addition to ordering the bank to stop engaging in the specified acts and practices, the order further requires the bank to: (1) maintain a compliance committee responsible for monitoring and overseeing the bank's compliance with the provisions of the order; (2) submit an acceptable enterprise-wide compliance risk management plan designed to ensure the bank's acts and practices comply with federal consumer financial law and the terms of the order, a staffing assessment for the compliance risk management program, and a plan to enhance the internal audit program with respect to compliance; (3) establish a comprehensive remediation program for remediation activities conducted by the bank and establish remediation plans addressing the CPI and mortgage-interest-rate-lock findings in the order; (4) pay a civil money penalty of $1 billion, for which only $500 million must be paid to the CFPB as the CFPB is treating the payment of the $500 million OCC penalty as partial satisfaction of the penalty; and (5) comply with various reporting and approval requirements.

71. Apr 20, 2018
    Regulatory Action: Office of the Comptroller of the Currency (OCC) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution disgorgement cease and desist · Fine: $500.0M · Begun Apr 20, 2018 · Resolved Apr 20, 2018 · Consent · Docket AA-EC-2018-15 & AA-EC-2018-16

    Without admitting or denying the findings, the bank consented to the issuance of an order in which the OCC found that the bank failed to implement and maintain an enterprise-wide compliance risk management program commensurate with the bank's size, complexity, and risk profile. The OCC found that the deficiencies in the bank's enterprise-wide compliance risk management program, which were identified during the OCC's ongoing supervision of the bank, constituted reckless unsafe or unsound practices resulting in violations of the unfair acts or practices provision of section 5 of the federal trade commission act. The OCC also found that deficiencies in the bank's automobile collateral protection insurance (CPI) program and mortgage interest rate lock extension fee practices constituted unfair acts or practices and were unsafe or unsound. The order requires the bank to: (1) maintain a compliance committee responsible for monitoring and overseeing the bank's compliance with the provisions of the order; (2) develop and execute a compliance risk management plan, a consent order action plan, a staffing assessment for the compliance risk management program, and a plan to enhance the internal audit program with respect to compliance; (3) establish a comprehensive remediation program for remediation activities conducted by the bank and establish remediation plans addressing CPI and mortgage interest rate lock extension fees; (4) pay a civil money penalty of $500,000,000; and (5) comply with various reporting and approval requirements.

72. Feb 2, 2018
    Regulatory Action: Board of Governors of the Federal Reserve System FinalAbout an affiliate: Wells Fargo & CompanySanctions: Cease and Desist; Independent reviews · Begun Feb 2, 2018 · Resolved Feb 2, 2018 · Consent · Docket 18-007-B-HC

    Without admitting or denying the findings, the firm consented to the order to cease and desist and to take affirmative action to take steps to ensure the bank complies with consent orders issued by the OCC and CFPB, within sixty days, submit a written plan to further enhance the effectiveness in carrying out oversight and governance of WFC, improve its oversight of senior management including an effective risk tolerance program and risk identification and escalation framework. Following the adoption fo the plans and improvements, WFC shall conduct by September 30, 2018 and independent review of the Board's improvements, enhancements to the firm's compliance and operational risk management program. WFC must conduct a second independent review into WFC's "business-as-usual practices and operations to assess the efficacy and sustainability of the improvements. Both reviews must be conducted by third party experts with results submitted to the Federal Reserve within 30 days of completion of the reports. WFC is restricted, without prior written appoval, to take any action that would cause the average of WFC's total consolidated assets for the current and preceding quarter to exceed a specified level as described more fully in the order.

73. Oct 16, 2017
    Regulatory Action: FINRA FinalAbout an affiliate: Wells Fargo Clearing; the full record is on the affiliate's own Form ADVSanctions: Other; N/a · Begun Oct 16, 2017 · Resolved Oct 16, 2017 · Acceptance, Waiver & Consent(AWC) · Docket 2014042465601

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that certain firm registered representatives recommended volatility-linked exchange-traded products (volatility etps) to brokerage customers without fully understanding their risks and features. The findings stated that the firm failed to vet or place restrictions on recommendations and purchases of volatility etps, and as a result, these products were made available to retail brokerage customers regardless of risk profile and investment objective. Certain firm representatives mistakenly believed that volatility etps could be used as a long-term hedge on their customers' equity positions in the event of a market downturn. In fact, volatility etps are generally short-term trading products that degrade significantly over time and should not be used as part of a long-term buy-and-hold investment strategy. Accordingly, in those instances, the representatives did not have a reasonable basis to recommend volatility etps as suitable to customers with conservative or moderate risk profiles and investment objectives and the representatives further failed to appropriately recommend the exit of these positions within a timely manner. In some instances, customers incurred significant losses. The findings also stated that the firm failed to establish and maintain a supervisory system, including written policies and procedures, reasonably designed to achieve compliance with NASD rule 2310 in connection with its sale of volatility etps. Although the firm should have been aware of the complexity and unique risks and features associated with volatility etps, the firm failed to implement a reasonable system to supervise its representatives' solicited sales of volatility etps. The findings also included that the firm's supervisory systems also did not include reasonable training for registered representatives and supervisors regarding the features and risks associated with volatility etps. Because the firm failed to establish and provide reasonable guidance, training or tools to educate its registered representatives and supervisors about volatility etps, certain retail brokerage customers were uninformed about the features and risks associated with volatility etps prior to purchasing them.

    In determining to resolve this matter without the imposition of a fine, FINRA took the following into consideration: (I) prior to detection by FINRA, the firm corrected its supervisory deficiencies relating to volatility etps; (II) the firm was previously fined $2.1 million - after the misconduct and its remediation herein - for similar violations relating to non-traditional etps; and, (III) the firm provided substantial assistance to FINRA by, among other things, engaging at its own expense a consulting firm to review, compile, and calculate large amounts of data pertaining to sales of volatility etps for use in determining the appropriate restitution to be provided.

74. Dec 21, 2016
    Regulatory Action: FINRA FinalAbout an affiliate: Wells Fargo ClearingSanctions: Other; N/a · Fine: $1.5M · Begun Dec 21, 2016 · Resolved Dec 21, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2016050274801

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it, with two other firms, failed to maintain approximately one million electronic brokerage records in non-erasable and non-rewritable format, known as worm "write once, read many" format. The findings stated that worm format is intended to prevent the alteration or destruction of broker-dealer records stored electronically. The findings also stated that for approximately 1.5 million accounts, the firm, with the other two firms, failed to preserve customer account form templates containing the terms and conditions related to the opening and maintenance of the accounts. The findings also included that the firm failed to notify FINRA, its designated examining authority, at least 90 days prior to using new storage media to store electronic broker-dealer records. FINRA found that the firm failed to implement an audit system for those records they failed to maintain in worm format. FINRA also found that the firm failed to provide its third-party vendors full access to, and the ability to download information from, its electronic storage systems. In addition, FINRA determined that the firm failed to implement an adequate supervisory system, and failed to enforce written procedures, concerning the firm's ready access to electronic broker-dealer records and its storage of such records in worm format.

75. Dec 5, 2016
    Regulatory Action: FINRA FinalAbout an affiliate: Wells Fargo AdvisorsFine: $1.0M · Begun Dec 5, 2016 · Resolved Dec 5, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2015043740201

    Without admitting or denying the findings, the firm and its affiliate consented to the sanctions and to the entry of findings that they failed to establish, maintain, and enforce reasonable supervisory systems for the use of consolidated reports generated by their registered representatives through a particular application (the application) that the firms made available to their registered representatives. The findings stated that the firm and its affiliate permitted their registered representatives to use up to 10 or more different applications to create consolidated reports, including the application. The application was the most widely used consolidated reporting application at the firms. The findings also stated that when preparing application reports, the firms' representatives were permitted to manually enter information regarding customers' external accounts, assets and liabilities into a centralized assets and liabilities table, which the firms maintained. The application would pull that information from the table to populate the application reports, including those that were then sent to the firms' customers. The firms reviewed a random sampling of only 2 percent of the application reports. The firm and its affiliate did not, and had no system in place to, review the contents of the application reports, including information about customers' holdings away from the firms. The findings also included that the firms' supervisory systems and procedures were inadequate because there was no mechanism allowing their representatives to designate which application reports were actually provided to customers. The firms could not distinguish between draft application reports and reports that were completed and sent to customers, which should have been subjected to the firms' supervisory systems designed to review customer communications.

76. Sep 29, 2016
    Regulatory Action: Office of the Comptroller of the Currency (OCC) FinalAbout an affiliate: Wells Fargo Bank, N. A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Establish a compliance committee, create a comprehensive action plan and develop a written scra compliance program and · Fine: $20.0M · Begun Sep 29, 2016 · Resolved Sep 29, 2016 · Order · Docket AA-EC-2016-68 & AA-EC-2016-69

    Without admitting or denying the findings, Wells fargo bank, N.A. (WFBNA) consents to the finding that between 2007 and 2014, WFBNA failed to accurately disclose some service member's military status in affidavits filed in eviction proceedings and between 2006 and 2011, failed to obtain court orders prior to repossesing services member's automobiles.

    N/a

77. Sep 29, 2016
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, N. A.Sanctions: Civil Penalty(ies)/Fine(s); Establish a compliance committee, create a comprehensive action plan and develop a written scra compliance program. · Fine: $60,000 · Begun Sep 29, 2016 · Resolved Sep 29, 2016 · Consent

    Without admitting or denying the findings, Wells fargo bank, N.A. (WFBNA) consents to the finding that between January 1, 2008 and July 1, 2015, WFBNA violated the servicemember civil releif act (SCRA) by failing to obtain court orders prior to repossessing services member's automobiles.

    $60,000.00 fine paid

78. Sep 27, 2016
    Regulatory Action: CFTC FinalAbout an affiliate: Wells Fargo Bank, N. A.Sanctions: Cease and Desist; Civil monetary fine of $400,000. · Fine: $400,000 · Begun Sep 27, 2016 · Resolved Sep 27, 2016 · Order · Docket CFTC DOCKET NO 16-32

    The CFTC found that between March 1, 2013 and November 13, 2015, every large trader report ("LTR") submitted by Wells fargo bank, N.A. failed to meet the part 20 requirements. LTRS submitted by the bank omitted required data elements and reported certain data in a manner that did not conform to the specifications required by the CFTC. Accordingly, the bank violated section 4s(f)(1)(a) of the Commodity Exchange Act, 7 U.S.C. SEC. 6s(f)(1)(a) (2012), and regulations 20.4 and 20.7, 17 C.F.R. Secs. 20.4 and 20.7 (2015). Without admitting or denying the findings, the bank consented to entry of the CFTC's order.

    N/a

79. Sep 13, 2016
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo & CompanySanctions: Injunction; Mediate current or former California customers who incurred fees or were harmed as a result of the unauthorized · Fine: $50.0M · Begun May 4, 2015 · Resolved Sep 13, 2016 · Judgment Rendered

    The complaint alleges that Wells fargo personnel engaged in various allegedly improper acts and practices designed to meet sales goals and quotas, such as opening accounts without customer authorization, misrepresenting that certain products were available only in packages with other products, misusing customer data in connection with the foregoing, and not disclosing such alleged misuse to customers. The complaint alleges that customers were harmed by, among other things, incurring unauthorized fees.

    Fine of $50,000,000.00 paid

80. Sep 6, 2016
    Regulatory Action: Comptroller of the Currency (OCC) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Cease and Desist; Compliance and risk management plan; pay reimbursement to affected consumers; civil money penalty. · Fine: $35.0M · Begun Sep 6, 2016 · Consent · Docket AA-EC-2016-66 AND AA-EC-2016-67

    Without admitting or denying the findings, Wells Fargo Bank, N.A. ("WFBNA") consented to the entry of an order that its community bank group had unsafe or unsound practices in risk management and oversight of sales practices, and unsafe or unsound sales practices by selling unwanted deposit or credit card accounts, the unauthorized opening of such accounts, the transfer of funds to unauthorized accounts, and unauthorized credit inquiries to open the accounts.

81. Sep 4, 2016
    Regulatory Action: Consumer Financial Protection Bureau (CFPB) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Civil money penalties of $100,000,000.00; compliance and redress plans; independent consultant review, pay redress to affected · Fine: $100.0M · Begun Sep 4, 2016 · Resolved Sep 4, 2016 · Consent · Docket 2016-CFPB-0015

    Without admitting or denying the findings, Wells Fargo Bank, N.A. ("WFBNA") consented to the entry of an order that its community bank group engaged in unfair and abusive practices by opening deposit accounts, transferring funds between accounts, applying for credit cards, issuing debit cards and enrolling customers in on-line banking services without the customers' consent.

82. Aug 20, 2016
    Regulatory Action: Consumer Financial Protection Bureau (CFPB) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Cease and Desist; Compliance plan, remediation to borrowers, pay civil money penalties of $3,600,000 and provide a quarterly/annual tracking · Fine: $3.6M · Begun Aug 20, 2016 · Resolved Aug 20, 2016 · Consent · Docket 2016-CFPB-0013

    Without admitting or denying the findings, Wells Fargo Bank, N.A. ("WFBNA") consented to the entry of an order that under certain scenarios and in certain timeframes its education financial services business (EFS)allocated partial payments, aggregated partial payments, and charged late fees in ways that were alleged to be unlawful.

83. May 24, 2016
    Regulatory Action: Office of the Comptrollerof the Currency ("OCC") FinalAbout an affiliate: Wells Fargo Bank, N. A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $70.0M · Begun Mar 31, 2011 · Resolved May 24, 2016 · Stipulation and Consent · Docket 2016-56 AMENDS 2011-051, 2013-132, 2015-067, AND AA-EC-11-19 TO TERMINATE. 2016-055 (AA-EC-2016-30) ORDER FOR CIVIL PENALTY

    Wells fargo bank, N.A. failed to comply with certain provisions of prior OCC consent orders relating to certain residential mortgage servicing practices from prior consent orders. # 2016-055 (AA-EC-2016-30) orders Wells fargo bank, N.A. pay a $ 70,000,000. Civil money penalty.

84. May 24, 2016
    Regulatory Action: Office of the Comptroller of the Currency FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $70.0M · Begun Mar 31, 2011 · Resolved May 24, 2016 · Stipulation and Consent · Docket 2016-56 AMENDS 2011-051, 2013-132, 2015-067, AND AA-EC-11-19 TO TERMINATE. 2016-055 (AA-EC-2016-30) ORDER FOR CIVIL PENALTY

    Wells Fargo Bank, N.A. failed to comply with certain provisions of prior OCC consent orders relating to certain residential mortgage servicing practices from prior consent orders. # 2016-055 (AA-EC-2016-30) orders Wells Fargo Bank, N.A. pay a $ 70,000,000. Civil money penalty.

85. Apr 8, 2016
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, NASanctions: Money Damages (Private/Civil Complaint); Civil penalties · Fine: $1.2B · Begun Oct 9, 2012 · Resolved Apr 8, 2016 · Settled

    The complaint alleges that Wells Fargo Bank, N.A. engaged in misconduct in connection with its participation in the federal housing administration (FHA) direct endorsement lender program and that, as a result of false certifications, FHA has paid hundreds of millions of dollars in insurance claims on thousands of mortgages that defaulted.

    Monetary fine of 1,200,000,000.00 100% leveled against the affiliate.

86. Feb 2, 2016
    Regulatory Action: Securities Exchange Commission FinalAbout an affiliate: Wells Fargo Bank, N.A.,Sanctions: Cease and Desist; Monetary fine of $440,000.00 · Fine: $440,000 · Begun Feb 2, 2016 · Resolved Feb 2, 2016 · Consent · Docket 3-17096

    The Securities and Exchange Commission (SEC) alleged Wells Fargo Bank, N.A. municipal products group (wfbna MPG) conducted inadequate due diligence in certain offerings and as a result, failed to form a reasonable basis for believing the truthfulness of certain material representations in official statements issued in connection with those offerings. This resulted in wfbna MPG offering and selling municipal securities on the basis of materially misleading disclosure documents. The SEC alleges wfbna MPG violated section 17(a)(2) of the Securities Act of 1933.

    Without admitting or denying the findings or violations of securities laws or rules, Wells Fargo Bank, N.A. municipal products group agrees to the offer of settlement and this order.

87. Dec 18, 2015
    Regulatory Action: U.S.A., Department of the Treasury, Comptroller of the Currency (OCC) FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Cease and Desist · Begun Dec 18, 2015 · Resolved Dec 18, 2015 · Consent · Docket AA-EC-2015-79

    7.the OCC found that Wells Fargo Bank, N.A. ("WFBNA") failed to make acceptable substantial progress toward correcting previously identified BSA/AML problems relating to due diligence practices and customer risk assessment in the wholesale banking group resulting in a violation of 12 usc 1818(s); and critical internal control deficiencies in the wholesale banking group's BSA/AML compliance program resulted in an internal control pillar violation (12 CFR 21.21(d)(1)).

88. Jun 3, 2015
    Regulatory Action: Office of the Comptroller of the Currency FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Cease and Desist; Civil money penalties and customer remediation · Fine: $4.0M · Begun Jun 3, 2015 · Resolved Jun 3, 2015 · Stipulation and Consent · Docket AA-EC-2015-06 AND AA-EC-2015-13

    The OCC alleged Wells Fargo Bank, N.A. engaged in unfair billing and deceptive marketing practices with regard to identity protection and debt cancellation products that resulted in violations of section 5 of the federal trade commission act.

89. Feb 4, 2015
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Other; Compliance plan to ensure compliance with the order and administration of payments to redress affected consumers. · Fine: $21.0M · Begun Jan 22, 2015 · Resolved Feb 4, 2015 · Judgment Rendered

    The complaint alleges from 2009 through 2013, genuine title, LLC provided Wells fargo loan officers marketing services that assisted the loan officers in generating business and increasing the number of loans Wells fargo originated or financed. The complaint alleges that under agreements or understanding between genuine title and the loan officers, the loan officers referred settlement service business to genuine title.

    Restitution of $10,809,807.71 to be provided to affected consumers. Any funds remaining will be deposited in US Treasury as disgorgement.

90. Jan 22, 2015
    Regulatory Action: United States of America Consumer Financial Protection Bureau FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Other; Consent order with conduct provision and order distribution and acknowledgement. · Begun Jan 22, 2015 · Resolved Jan 22, 2015 · Consent · Docket 2015-CFPB-0002

    The complaint alleges from 2009 through 2013, genuine title, LLC provided Wells fargo loan officers marketing services that assisted the loan officers in generating business and increasing the number of loans Wells fargo originated or financed. The complaint alleges that under agreements or understanding between genuine title and the loan officers, the loan officers referred settlement service business to genuine title.

    Wells Fargo Bank, N.A., neither admits or denies any allegations except to establish the bureau's jurisdiction over Wells fargo and the subject matter.

91. Dec 18, 2014
    Regulatory Action: FINRA FinalAbout an affiliate: Wells Fargo Advisors, LLCSanctions: Other; N/a · Fine: $1.5M · Begun Dec 18, 2014 · Resolved Dec 18, 2014 · Acceptance, Waiver & Consent(AWC) · Docket 2012034123501

    FINRA has alleged potential violations of FINRA rules 3310 and 2010 and NASD rule 2110. Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that for several years the firm failed to comply fully with a key aspect of the anti-money laundering ("AML") compliance program requirements for broker-dealers. To satisfy those requirements, every broker-dealer must establish and maintain a customer identification program ("CIP") under which it verifies the identity of each customer opening a new account, and, during the relevant period, the firm's CIP was deficient, in that it did not subject certain new customers to identity verification. The findings stated that during the relevant period, when the firm's transaction- processing system, the beta system, assigned customer identifiers to new securities accounts, it sometimes recycled identifiers previously assigned to accounts that had been closed. When this happened, the CIP system recognized the identifiers and treated the new accounts as if they had already gone through the CIP system. Thus, even though the appurtenant customer information - such as customer name, address, tax-identification number, and date of birth - was different from the previous instance of identity verification, the CIP system did not subject the customers associated with these new accounts to identity verification. For that reason, the firm's CIP system did not verify the identities of new customers with recycled identifiers. This resulted in the firms' failure to conduct customer-identity verification for nearly 220,000 accounts during the relevant period. The findings also stated that of the accounts that were not subjected to identity verification, approximately 120,000 were already closed when the problem came to light. These accounts were never subjected to identity verification. The accounts that were still open when the firm discovered the design flaw were subsequently sent through the CIP process, with the firm eventually prohibiting further activity in 345 accounts for which identity verification could not be completed. In determining the appropriate sanctions, FINRA considered that the firm discovered the CIP-related violations through the firm's compliance risk analysis system (CRAS) test, investigated their causes and scope, performed remediation CIP on the approximately 100,000 affected accounts that remained open, made programming changes to the CIP system and to the firm's beta in an effort to prevent recurrences, and reported the violations to FINRA in accordance with rule 4530(b).

    In determining the appropriate sanctions, FINRA considered that the firm discovered the cip-related violations through the firm's compliance risk analysis system (CRAS) test, investigated their causes and scope, performed remediation cip on the approximately 100,000 affected accounts that remained open, made programming changes to the cip system and to the firm's beta in an effort to prevent recurrences, and reported the violations to FINRA in accordance with rule 4530(b).

92. Oct 29, 2014
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank N.A.Sanctions: Injunction; Restitution · Resolved Oct 29, 2014 · Judgment Rendered

    The only remaining allegation in this litigation is that Wells Fargo Bank violated the provisions of California business & professions code section 17200 et seq. Relating to alleged fraudulent misrepresentations as to the order by which the bank posted items to consumer deposit accounts in the state of California.

    Effective July 15, 2013 the order enjoins the bank permanently "from making or disseminating, or permitting to be made or disseminated, any false or misleading representations relating to the posting order of debit-card purchases, checks, and ach transactions in its customer bank accounts." Restitution of $203,000,000.00 was ordered. Restitution has not been paid pending appeal. Wells fargo paid the judgment (and post-judgment interest) of approximately $205,000,000 in June 2016.

93. Sep 20, 2012
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, NASanctions: Injunction; Monetary damages; pre-judgment interest on monetary damages; and a civil penalty · Fine: $175.0M · Resolved Sep 20, 2012 · Consent

    The complaint alleges that, during and between 2004 and 2009, the referenced control affiliate engaged in a pattern or practice of discrimination on the basis of race and national origin in residential mortgage lending by allowing employees to make decisions about the type of loan product offered and the loan price in a manner disconnected from objective criteria like credit risk, that policies set up financial incentives for employees and mortgage broker's to impose unfavorable terms, and that the policies lacked safeguards to prevent and remedy racial and ethnic disparities.

    The referenced control affiliate agreed to pay at least $125 million to compensate borrowers who were allegedly aggrieved. The referenced control affiliate also agreed to pay $50 million to provide down-payment assistance to low- income borrowers in select metropolitan areas. The control affiliate deposited funds in escrow accounts for the agreed payments by September 24, 2012. Wells fargo will maintain its policies that disconnect compensation from a loan's terms and conditions (implemented after the events in the alleged complaint), provide training and assure compliance, through monitoring and regular reporting to the United States.

94. Mar 12, 2012
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo & CompanySanctions: Money Damages (Private/Civil Complaint); Payment of compensatory damages · Begun Mar 12, 2012 · Resolved Mar 12, 2012 · Consent

    The complaint alleges that the referenced affiliates violated the Oklahoma consumer protection act by failing to take required action and by taking certain prohibited actions in connection with residential mortgage loans.

    Compensatory damages in the amount of $3,769,569.70

95. Mar 12, 2012
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo & CompanySanctions: Money Damages (Private/Civil Complaint); Compliance with servicing standards and payment of monetary amounts · Begun Mar 12, 2012 · Resolved Mar 12, 2012 · Consent

    The complaint alleges that the referenced affiliates: engaged in unfair and deceptive consumer practices with respect to loan servicing, foreclosure proceedings and loan originations; violated the false claims act, the financial institutions reform and recovery act of 1989 and the servicemembers civil relief act; and engaged in bankruptcy misconduct.

    Monetary payments consist of $1,005,233,716 direct payment settlement amount; $1,489,813,925 borrow payment amount; $3,434,000,000 eligible consumer relief, and $903,000,000 eligible refinancing relief.

96. Feb 22, 2012
    Regulatory Action: Office of the Comptroller of the Currency FinalAbout an affiliate: Wells Fargo Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist undertaking · Fine: $83.0M · Begun Feb 22, 2012 · Resolved Feb 22, 2012 · Stipulation and Consent · Docket 2012-042

    Wells Fargo Bank, N.A. engaged in unsafe or unsound banking practices in connection with residential mortgage foreclosures.

97. Feb 9, 2012
    Regulatory Action: Federal Reserve FinalAbout an affiliate: Wells Fargo and CompanySanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist · Fine: $87.0M · Begun Feb 9, 2012 · Resolved Feb 9, 2012 · Consent · Docket 12-010-CMP-HC

    Federal Reserve consent order re: bank's mortgage foreclosure practices.

98. Dec 8, 2011
    Regulatory Action: Office of the Comptroller of the Currency ("OCC") FinalAbout an affiliate: Wells Fargo Bank, N. A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $20.0M · Begun Dec 8, 2011 · Resolved Dec 8, 2011 · Consent · Docket # 2011 - 174; AA - EC - 11-97

    The ooc alleged that, from at least 1997 through at least 2006, wachovia bank, N.A. and first union national bank ("wachovia bank"), predecessors to Wells fargo bank, N.A., engaged in illegal conduct and/or unsafe or unsound banking practices in connection with the marketing and sale of certain derivative financial products to certain municipalities and other non-profit organizations ("counterparties") in certain competitively bid transactions.

    The OCC alleged that wachovia bank won bids for the temporary investment of proceeds from the sale of tax-exempt municipal securities by, among other things, participating in schemes with outside individuals to agree on bids and to artificially set prices in connection with the sale of certain derivative financial products to certain municipalities and non-profit organizations, submitting false or sham courtesy bids, communicating with direct competitors and./or coordinating with third party brokers to fix bid prices, and/or coordinating with direct competitors and/or third party brokers to determine which bidder would win a particular transaction. Wells fargo bank, N.A. resolved this matter by agreeing to the sanctions and restitution outlined above and further undertakings with respect to: its compliance, training and audit programs; assessing and evaluating its competitive bidding activities; and preparing and submitting annual reports concerning the effectiveness of its supervisory control policies and procedures.

99. Dec 8, 2011
    Civil Judicial Action FinalAbout an affiliate: Wells Fargo Bank, N. A.Sanctions: Civil Penalty(ies)/Fine(s); Disgorgement injunction · Fine: $25.0M · Begun Dec 8, 2011 · Resolved Dec 8, 2011 · Consent

    The SEC alleged fraudulent bidding practices, from at least 1997 through at least 2005, by wachovia bank, N.A. ("wachovia bank"), predecessor to Wells fargo bank, N.A., involving the temporary investment of proceeds from the sale of tax-exempt municipal securities in certain investment instruments by state and local governmental entities, affecting the prices of the investment instruments, depriving municipalities of a conclusive presumption that their investment instruments were purchased at fair market value and/or jeopardizing the tax-exempt status of the underlying municipal securities.

    The court permanently restrained and enjoined Wells fargo bank, N.A. from future violations of section 17(a) of the Securities Act of 1933. The court also found Wells fargo bank, N.A. liable for disgorgement of $13,802,984.00, prejudgment interest thereon in the amount of $7,275,607.00, and a civil penalty in the amount of $25,000,000.00. Wells fargo bank, N.A. was ordered to pay the aggregate of the foregoing amounts totaling $46,078,591.00 to the entities and in the amounts directed by the court within 60 days of entry of the final judgment.

100. Jul 20, 2011
     Regulatory Action: The Board of Governors of the Federal Reserve System FinalAbout an affiliate: Wells Fargo and CompanySanctions: Cease and Desist; Civil and administrative penalt(IES) / fine(s) restitution · Fine: $85.0M · Begun Jul 20, 2011 · Resolved Jul 20, 2011 · Settled · Docket 11-094-B-HC1; 11-094-B-HC2; 11-094-I-HC1; 11-094-I-HC2

     The Board of Governors alleged that Wells fargo financial, inc., a subsidiary of Wells fargo & company, engaged in activities constituting unsafe or unsound banking practices, and violations of the federal trade commission act and state law in connection with certain home mortgage lending activities.

     This matter was resolved by settlement and a mutually agreed order dated July 20, 2011 providing for: (I) payment of civil monetary penalty of $85 million; (II) the submission within 90 days of remedial plans for paying restitution to eligible borrowers; and (III) the submission within 90 days of acceptable plans for the prevention of similiar future conduct, overseeing compliance with federal and state law applicable to home mortgage lending activities, and modifying incentive compensation and performance management programs related to home mortgage lending activities.

101. Apr 4, 2011
     Regulatory Action: Federal Reserve FinalAbout an affiliate: Wells Fargo and CompaanySanctions: Cease and Desist · Begun Apr 4, 2011 · Resolved Apr 4, 2011 · Consent · Docket 11-025-B-HC

     Federal Reserve consent order re: bank's mortgage foreclosure practices

     Wells fargo & company (Wells fargo) entered into a consent order with the Federal Reserve pursuant to which Wells fargo agreed, among other things, (I) to ensure the bank's compliance with the OCC consent order; (II) to develop for the Federal Reserve's approval a written plan to enhance its enterprise risk management with respect to oversight of residential mortgage loan servicing; (III) to develop for the Federal Reserve's approval a written plan to enhance its enterprise-wide compliance program with respect to oversight of residential mortgage loan servicing; and (IV) to develop for the Federal Reserve's approval a written plan to enhance the internal audit program with respect to residential mortgage loan servicing.

102. Mar 12, 2010
     Regulatory Action: Department of the Treasury - Financial Crimes Enforcement Network FinalAbout an affiliate: Wachovia Bank N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $110.0M · Begun Mar 12, 2010 · Resolved Mar 12, 2010 · Order · Docket 2010-1

     The financial crimes enforcement network ("FINCEN") of the Department of the Treasury alleged that Wachovia Bank, N.A. ("Wachovia Bank") failed to implement adequate policies, procedures and controls relating to cash transfers for currency exchange houses and foreign correspondent customers, to conduct adequate monitoring of related transactions and customers, to adequately staff the Bank Secrecy Act ("BSA") compliance function, to effectively implement an independent audit function to test for BSA compliance, to file timely suspicious activity reports and to report currency transactions

     FINCEN issued its assessment of civil money penalty concurrently with Wachovia Bank entering into a deferred prosecution agreement ("agreement") with the U.S. attorney's office and the U.S. Department of Justice (collectively, the "United States") on March 16, 2010. Pursuant to the agreement, Wachovia Bank settled civil and criminal forfeiture claims for the amount of $110 million, paid on or before March 21, 2010, and agreed to implement certain remedial measures designed to fully comply with the Bank Secrecy Act and to abide by any FINCEN orders and regulations. Wachovia Bank merged with and into Wells fargo bank, N.A. on March 20, 2010. Wells fargo bank, N.A. agreed to be bound by the terms and conditions of the agreement following the merger. The United States agreed that prosecution of Wachovia Bank be deferred for a period of twelve months and that, if Wells fargo bank, N.A. is in compliance in all material aspects with all of its obligations under the agreement, the United States, within thirty days of the expiration of that period, would seek dismissal with prejudice of the charge.

103. Mar 12, 2010
     Regulatory Action: Department of the Treasury - Comptroller of the Currency FinalAbout an affiliate: Wachovia Bank, N.A.Sanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist; - undertaking · Fine: $50.0M · Begun Mar 12, 2010 · Resolved Mar 12, 2010 · Order · Docket AA-EC.-10-16; AAA-EC.-10-17

     The office of the Comptroller of the Currency ("OCC") alleged that Wachovia Bank, N.A. ("Wachovia Bank") failed to implement adequate policies, procedures and controls relating to cash transfers for currency exchange houses and foreign correspondent customers, to conduct adequate monitoring of related transactions and customers, to file timely suspicious activity reports and to adequately report cash structuring activity from review of internally generated reports

     Wachovia Bank agreed, among other things, to take the necessary steps to address deficiencies and enhance its BSA and AML policies and procedures over foreign correspondent banking activities, to develop an action plan designed to address identified deficiencies and violations of law and to submit the action plan to the deputy comptroller within 90 days of the order, not to implement any material changes to the action plan without prior submission to and approval of the deputy comptroller, to submit a formal report to its board of directors and the deputy comptroller detailing the status of remediation activities within 120 days of the order, and to submit quarterly status reports until the provisions of the order are terminated by the comptroller. Wachovia Bank merged with and into Wells fargo bank, N.A. on March 20, 2010.

104. Sep 4, 2008
     Civil Judicial Action FinalAbout an affiliate: Prudential Financial, Inc.Sanctions: Injunction; N/a · Begun Aug 6, 2008 · Resolved Sep 4, 2008 · Consent

     The SEC filed a complaint which alleged that Prudential Financial, Inc. improperly accounted for certain reinsurance contracts entered into with a single counterparty in the years 1997-2002 relating to the company's property and casualty operations that were sold in 2003. The complaint alleged that this resulted in an overstatment of the company's consolidated results for certain years in reports filed with the SEC,in violation of the financial reporting, books and records and internal control provisions of the Exchange Act.

     Court permanently enjoined Prudential Financial, Inc.; its offices, agents, servants, employees, attorneys and all persons in active concert or participation with them for violating certain provisions of the Securities Exchange Act of 1933.

105. Aug 17, 2006
     Civil Judicial Action FinalAbout an affiliate: Wachovia Bank,N.A. (Non-Sanctions: Disgorgement · Begun Oct 4, 1996 · Resolved Aug 17, 2006 · Settled

     The county sought to recover damages arising from conduct of a former first fidelity bank employee who entered into a kickback scheme with the treasurer of essex county in 1987 to steer business to first fidelity, which served as underwriter for three bond issues done by the county in 1987 and 1989.

     See item 14.

106. Nov 10, 2004
     Civil Judicial Action FinalAbout an affiliate: Wachovia CorporationSanctions: Injunction; Civil penalty of $37,000,000.00 · Fine: $37.0M · Begun Nov 4, 2004 · Resolved Nov 10, 2004 · Settled

     Without admitting or denying the allegations in the complaint, Wachovia Corporation settled a civil action brought by the U.S. Securities and Exchange Commission for violations of the proxy disclosures and other reporting requirements concerning the 2001 merger between first union corporation and old Wachovia Corporation. Under the settlement Wachovia Corporation paid $37 million civil penalty and is enjoined from future violations of certain provisions of the federal securities laws.

     Civil penalty of $37 million paid to the US Treasury on November 15, 2004. Wachovia Corporation was enjoined from directly or indirectly violating section 13(a) and 14(a) of the Exchange Act and rules 12B-20, 13A-13 and 14A-9 thereunder.

107. Feb 1, 2000
     Regulatory Action: NASD (now FINRA) FinalAbout an affiliate: Jwgenesis Financial Group,; the full record is on the affiliate's own Form ADVSanctions: Other · Fine: $2,000 · Begun Apr 15, 1999 · Resolved Feb 1, 2000 · Acceptance, Waiver & Consent(AWC) · Docket E07990136

     Failure to sumitt 77 retail municipal securities trade reports to the MSRB during the period January 1 through April 30, 1999.

108. Aug 19, 1999
     Regulatory Action: Securities/Futures Commission & Stock Exchange of Hong Kong FinalAbout an affiliate: Prudential-Bache (HongSanctions: Censure; Prudential securities ("PSI") was fined HK$30,000 (approx. US $3,900). A PSI registered representative was fined HD$20,000 (approx · Fine: $6,500 · Begun Apr 23, 1999 · Resolved Aug 19, 1999 · Other · Docket DISCIPLINARY PROCEEDING NO. 50/99

     The stock exchange of Hong Kong, disciplinary committee (the"committee"). Disciplinary proceeding case no: 50/99. August 15, 1999. The committee and the Hong Kong securities and futures commission jointly charged prudential-bache securities (Hong Kong) limited ("PPS(HK)"), an affiliate of prudential securities and its dealing director, liu luk por for breach of the rules of the exchange. The substance of the charge was that during a period from December 15, 1997 to July 3, 1998, PBS(HK) had inadequate internal controls and failed to implement an appropriate system for deterring and detecting intra-day short selling by its staff, and that as a result, a former sales representative of PBS(HK), who was subsequently dismissed, had engaged in extensive short selling in his own account. The result was that the securities and futures commission issued a public reprimand to both PBS(HK) and MR. liu luk por and the stock exchange of Hong Kong issued a public censure plus a fine of HK$30,000 (approximately US$3,900) for PBS(HK) and a public censure plus a fine of HK$20,000 (approximately US$2,600) for MR. liu luk por.

109. Jan 15, 1997
     Regulatory Action: Commonwealth of Virginia, State Corporation Commission FinalAbout an affiliate: American SkandiaSanctions: Denial · Begun Jan 15, 1997 · Resolved Jan 15, 1997 · Other · Docket N/A

     The affiliate was denied registration as an investment advisor by the Commonwealth of Virginia state corporation commission, division of securities and retail franchising, on January 15, 1997. This denial was based upon the fact that the statutory deadline for submitting all information that was necessary to complete applicant's application for registration had expired. Therefore, this denial was not based upon any misconduct or unlawful activity by the affiliate.

     Application was never resubmitted.

110. Apr 18, 1995
     Regulatory Action: U S Securities & Exchange Commission FinalAbout an affiliate: Meridian InvestmentSanctions: Cease and Desist · Begun Apr 18, 1995 · Resolved Apr 18, 1995 · Settled · Docket 3-8672

     Meridian Investment company (registered investment advisor) was alleged to have failed to take steps to fully disclose as certain the potential for conflict of interest between the firm and its clients in connection with an investment of client funds made by the firm.

111. Dec 31, 1991
     Regulatory Action: The Securities and Futures Authority FinalAbout an affiliate: Bache Financial DeriativesSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $60,000 · Begun Dec 31, 1991 · Resolved Dec 31, 1991 · Settled · Docket N/A

     The sfa alleged that between May 13, 1991 and October 2, 1991 affiliate and john brackley failed to comply with sfa principles of statements of principle. The affiliate was alleged to have engaged in a course of conduct in relation to property futures transactions traded on the London fox; brackley was alleged to have failed to act with due care, skill and diligence and to avoid in engaging in a course of conduct which did not conform with the high standards of market conduct.

     Without admitting or denying the alleged violations, the affiliate agreed to pay a fine in the amount of $60,000. John brackley was reprimanded. In addition, the sfa stated that there was no intention on the part of the affiliate to violate sfa rules, infringe applicable market standards or create any false impression of the market in property futures.

112. Jul 26, 1991
     Regulatory Action: New York Mercantile Exchange FinalAbout an affiliate: Dryden Nominees (HongSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $15,000 · Begun Jul 26, 1991 · Settled · Docket 91-51

     The NYMEX alleged that affiliate had placed certain customer orders on the floor of the NYMEX which were improperly time- stamped, and had allegedly failed to maintain accurate records. As a result, the complaint alleged that affiliate had violated NYMEX rules 8.50(a) and 6.18(a).

     Affiliate settled this matter by agreeing to a fine of $15,000 and to update its policies and procedures designed to achieve compliance with aforementioned rules at affiliate.

Disclosures filed elsewhere

The firm's Form ADV names these and the kind of action only; the details are on the named firm's own filing.

• 8 regulatory action disclosures about A. G. Edwards & Sons, Inc.
• 7 regulatory action disclosures about Wachovia Securities, LLC
• 4 regulatory action disclosures about the firm
• 4 regulatory action disclosures about Pruco Securities, LLC.
• 3 regulatory action disclosures about First Union Securities, Inc.
• 3 regulatory action disclosures about Captrust Financial
• 3 regulatory action disclosures about Wachovia Securities, Inc.
• 3 regulatory action disclosures about Wachovia Capital Markets,
• 2 criminal disclosures about the firm
• 2 regulatory action disclosures about Metropolitan West
• 2 regulatory action disclosures about Wells Fargo Securities,
• 2 civil judicial action disclosures about Wells Fargo Advisors, LLC
• 1 criminal disclosure about Wachovia Bank, N.A.
• 1 regulatory action disclosure about Thornburg, Dustin, E
• 1 regulatory action disclosure about Wells Fargo Clearing
• 1 regulatory action disclosure about First Clearing, LLC
• 1 regulatory action disclosure about Prudential Investment
• 1 regulatory action disclosure about Pru Global Securities, LLC
• 1 regulatory action disclosure about Evergreen Investment
• 1 regulatory action disclosure about American Skandia
• 1 regulatory action disclosure about Global Alternative
• 1 regulatory action disclosure about Prudential Equity Group,
• 1 regulatory action disclosure about Wells Fargo Advisors, LLC
• 1 regulatory action disclosure about Wells Fargo Investments,
• 1 regulatory action disclosure about Wells Fargo Institutional
• 1 regulatory action disclosure about Yersin, Lincoln Blaine
• 1 regulatory action disclosure about H.D. Vest Investment
• 1 regulatory action disclosure about Wells Fargo Brokerage
• 1 regulatory action disclosure about Merlin Securities, LLC
• 1 regulatory action disclosure about Wells Fargo Funds
• 1 civil judicial action disclosure about Wachovia Capital Markets,
• 1 civil judicial action disclosure about The Prudential Insurance
• 1 civil judicial action disclosure about Wells Fargo Securities,

Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.