WELLS FARGO & COMPANY/MN (WFC) Risk Factors

Recent key developments

Concrete developments — dated events, named agreements and instruments, legal proceedings — that WELLS FARGO & COMPANY/MN surfaced in its latest filing.

• Wells Fargo is subject to a February 2018 consent order with the FRB regarding board governance and oversight, and compliance and operational risk management.February 2018
• Wells Fargo is subject to a September 2024 formal agreement with the OCC regarding anti-money laundering and sanctions risk management practices.September 2024
• The IHC may be restricted from making dividend payments to the Parent under the Support Agreement dated June 28, 2017, as amended and restated on June 26, 2019, if certain liquidity and/or capital metrics fall below defined triggers or if the Parent's board authorizes a bankruptcy filing.June 26, 2019
• Wells Fargo must submit resolution plans to the FRB and FDIC.
• Wells Fargo must submit a recovery plan to the FRB.
• The Bank must submit a recovery plan to the OCC.
• The Parent entered into a Support Agreement, transferring a significant amount of assets to the IHC, with ongoing asset transfers.June 28, 2017
• The Company is subject to Basel III risk-based capital requirements implemented by U.S. federal banking regulators.
• The FRB has issued TLAC rules requiring a U.S. G-SIB like Wells Fargo to hold equity and unsecured long-term debt to improve resolvability and resiliency.
• Federal banking regulators have imposed a liquidity coverage ratio and a net stable funding ratio on Wells Fargo.
• The FRB's capital plan rule governs capital distributions (dividends and share repurchases) for certain BHCs including Wells Fargo.
• The FRB and OCC have stress testing requirements for large BHCs and national banks.
• The OCC has established heightened governance and risk management standards for large national banks like the Bank.
• Previously entered into settlements to resolve inquiries or investigations by various government entities and lawsuits by non-governmental parties arising out of certain retail sales practices.
• Identified issues related to past practices involving certain automobile collateral protection insurance policies.
• Identified issues related to the unused portion of guaranteed automobile protection waiver or insurance agreements.
• Market disruption or loss of confidence could result in loss of customer deposits or inability to access capital markets, similar to the financial crisis in 2008 and early 2009.2008
• Market disruption or loss of confidence could result in loss of customer deposits or inability to access capital markets, similar to the failure of several banks in early 2023.early 2023
• The speed of information dissemination and rapid customer withdrawals could cause faster and greater loss of deposits, particularly uninsured or non-operational deposits, similar to the bank failures in early 2023.early 2023
• COVID-19 pandemic could create additional operational and compliance risks including rapidly changing regulatory requirements and implementing new measures to protect systems.
• The allowance for credit losses at December 31, 2025 was believed appropriate, but may not be sufficient to cover future credit losses.December 31, 2025