OCC Imposes Civil Money Penalties Against Three Former Executives of Wells Fargo
January 15, 2025 / Source: OCC
WASHINGTON—The Office of the Comptroller of the Currency (OCC) today announced enforcement actions against three former senior executives of Wells Fargo Bank, N.A., Sioux Falls, South Dakota (bank). These actions were taken in response to the former executives’ unsafe or unsound banking practices related to the bank’s systemic and widespread sales practices misconduct.
The enforcement actions are described in two written decisions issued by Acting Comptroller of the Currency Michael J. Hsu, covering Claudia Russ Anderson and jointly covering David Julian and Paul McLinko, as follows:
| Name | Former Position | Relief Ordered |
|---|---|---|
| Claudia Russ Anderson | Community Bank Group Risk Officer | Prohibition Order and $10,000,000 Civil Money Penalty (CMP) |
| David Julian | Chief Auditor | Personal Cease & Desist Order and $7,000,000 CMP |
| Paul McLinko | Executive Audit Director | Personal Cease & Desist Order and $1,500,000 CMP |
The decision covering Ms. Anderson found that from 2013 to 2016, she failed to credibly challenge the bank’s incentive compensation program, failed to institute effective controls to manage risks posed by sales practices misconduct, failed to escalate known or obvious risks, and repeatedly and consistently downplayed the sales practices misconduct. The decision also noted that Ms. Anderson committed violations of law by failing to provide information or providing false, incomplete, or misleading information to the OCC during its 2015 examinations.
A separate decision concluded that during the same period, Mr. Julian and Mr. McLinko failed to plan and manage audit activity that would detect and document sales practices misconduct and failed to adequately escalate the sales practices misconduct. Mr. McLinko also failed to maintain professional independence from the Community Bank, the Bank’s largest business line that housed the retail branches.
The decisions issued today explained that under pressure to meet unreasonable sales goals, thousands of employees at the bank engaged in widespread sales practices misconduct.
Today’s written decisions and orders stem from the Notice of Charges the OCC filed in January 2020, which began the administrative litigation. An Administrative Law Judge issued three recommended decisions in December 2022 following a 38-day administrative hearing. These are the remaining outstanding enforcement actions among those that the OCC pursued against 11 individuals related to the bank’s systemic and widespread sales practices misconduct. The OCC previously reached resolution with eight other former Wells Fargo senior bank executives, resulting in their payment of civil money penalties totaling $43,175,000.
Related Links
- Comptroller Decision for Ms. Anderson (PDF)
- Comptroller Decision for Mr. Julian and Mr. McLinko (PDF)
- Notice of Charges (PDF)
- Recent Selected Litigated Enforcement Actions