How Many Consent Orders Is Wells Fargo Under

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It's fantastic that you're looking into the regulatory landscape surrounding Wells Fargo! It's a complex and ever-evolving situation, and understanding it requires a deep dive. Let's embark on this journey together.

Navigating the Waters: Understanding Wells Fargo's Consent Orders

Have you ever felt like a company just keeps getting into trouble? For many, Wells Fargo fits that bill. The bank has faced a barrage of regulatory scrutiny and public criticism for a series of scandals, most notably the "fake accounts" debacle that came to light in 2016. As a result, various regulatory bodies have imposed what are known as "consent orders" on the bank. These are agreements between a regulator and a financial institution that require the institution to take specific actions to address deficiencies and improve compliance. Think of them as a roadmap to reform, laid out by the authorities.

The number of active consent orders against Wells Fargo has been a significant point of interest for investors, analysts, and the public alike, as they directly impact the bank's operations, growth, and profitability. While Wells Fargo has been diligently working to resolve these issues, it's been a lengthy and arduous process.

Let's break down the current situation and the journey the bank has undertaken.


Step 1: Understanding the "Why" Behind the Orders

Before we get to the "how many," it's crucial to grasp why these consent orders were put in place. Wells Fargo's troubles stemmed from a culture that prioritized aggressive sales targets over ethical conduct and customer well-being. This led to a range of abuses, including:

  • The "Fake Accounts" Scandal: Employees opened millions of unauthorized customer accounts to meet sales quotas, often without customer knowledge or consent. This was the primary catalyst for much of the subsequent regulatory action.
  • Auto Loan Issues: Improperly charging customers for auto insurance they didn't need, or failing to ensure borrowers had existing insurance. This resulted in customers being wrongly defaulted on loans and having their vehicles repossessed.
  • Mortgage Lending Malpractices: Issues related to fees, interest charges, and denying loan modifications to qualified borrowers, sometimes leading to wrongful foreclosures.
  • Other Consumer Abuses: Various issues across consumer deposit accounts and other product lines, including improper fees and mishandling of customer funds.
  • Risk Management and Governance Deficiencies: Regulators found systemic weaknesses in Wells Fargo's internal controls, compliance programs, and overall risk management framework that allowed these widespread abuses to occur.

These issues eroded public trust and led to substantial financial penalties and operational restrictions. The consent orders are designed to force Wells Fargo to address these fundamental problems and prevent future misconduct.


Step 2: The Evolving Number of Consent Orders – A Recent Snapshot

This is where the information becomes dynamic, as Wells Fargo has been making significant progress in getting these orders lifted. As of early June 2025, Wells Fargo has made substantial headway in resolving its outstanding consent orders.

Here's a breakdown of the recent developments:

  • A Major Breakthrough: The Federal Reserve's Asset Cap Lifted!
    • One of the most significant and punitive restrictions on Wells Fargo was the $1.95 trillion asset cap imposed by the Federal Reserve in 2018. This effectively prevented the bank from growing its balance sheet.
    • As of June 3, 2025, the Federal Reserve has officially lifted this asset cap. This is a monumental achievement for Wells Fargo, signaling that the Fed believes the bank has made sufficient progress in improving its governance and risk management. While the asset cap is lifted, some provisions of the underlying consent order from 2018 remain.
  • Other Recent Terminations:
    • Wells Fargo has successfully terminated a number of other consent orders in 2025. For example, the Consumer Financial Protection Bureau (CFPB) terminated its 2018 consent order related to compliance risk management in April 2025.
    • The Office of the Comptroller of the Currency (OCC) also lifted its consent order for the same issue in February 2025.
    • The bank has cleared several other orders from the OCC and Fed related to various issues, including mortgage lending practices and risk compliance management.

The exact, real-time number of currently active consent orders is constantly changing as the bank satisfies the requirements of each agreement. However, recent reports indicate that Wells Fargo is now operating under a significantly reduced number of major disciplinary actions.

Sub-heading: The Current State of Play

While the precise count can fluctuate, as of the latest information available in early June 2025, Wells Fargo has been actively working to clear its regulatory obligations. With the lifting of the asset cap and the termination of several other orders, the bank is believed to be down to a handful of remaining significant consent orders. Some reports indicate this number is as low as two or three remaining major issues, though specifics may vary based on the reporting agency and the definition of "major."

Sub-heading: What Does "Remaining" Mean?

The remaining consent orders typically involve ongoing improvements in areas such as:

  • Anti-Money Laundering (AML) programs: Ensuring robust systems are in place to prevent illicit financial activities.
  • Data security and consumer information protection: Adhering to acts like the Gramm-Leach-Bliley Act to safeguard customer data.
  • Overall enterprise-wide risk management frameworks: Continuously strengthening the bank's ability to identify, assess, and mitigate risks across all operations.

It's important to note that even after a consent order is "lifted," the bank's compliance efforts are subject to ongoing scrutiny from regulators. The lifting of an order signifies that the bank has met the specific requirements outlined in that particular agreement, but it does not mean regulatory oversight disappears.


Step 3: The Path to Resolution – A Step-by-Step Guide for the Bank (and What It Means for You)

While this guide is for the bank, understanding their process helps you understand the bigger picture and how it impacts you as a customer or interested party.

Sub-heading: Internal Transformation

  1. Acknowledge and Investigate: The first and most crucial step for Wells Fargo (and any institution facing such issues) was to fully acknowledge the problems and conduct thorough internal investigations to understand the root causes of the misconduct. This involved auditing past practices, identifying systemic failures, and determining individual accountability.
  2. Leadership Change and Culture Shift: New leadership, like CEO Charlie Scharf, was brought in with a clear mandate to transform the bank's culture. This involved emphasizing ethical conduct, putting customers first, and moving away from aggressive sales incentives that fueled the scandals. This is a long-term endeavor.
  3. Allocate Resources: Wells Fargo poured billions of dollars and immense human capital into enhancing its compliance, risk management, and operational controls. This meant hiring new experts, upgrading technology, and retraining employees.

Sub-heading: Engaging with Regulators

  1. Develop Remediation Plans: For each consent order, Wells Fargo had to develop detailed, actionable plans outlining how it would address the specific deficiencies identified by the regulators (e.g., the Federal Reserve, OCC, CFPB). These plans often included specific milestones and deadlines.
  2. Implement and Monitor: The bank then had to implement these plans rigorously. This wasn't a superficial effort; it required deep structural changes across various departments and business lines. Regular internal monitoring and reporting were essential to track progress.
  3. Independent Reviews and Audits: Many consent orders require independent third-party reviews and audits to verify the effectiveness of the bank's remediation efforts. This external validation provides an objective assessment of progress.
  4. Regular Reporting to Regulators: Wells Fargo has been providing frequent and comprehensive reports to the relevant regulatory agencies, detailing its progress against the requirements of each consent order. This transparent communication is crucial for building trust.
  5. Demonstrate Sustainability: It's not enough to just fix a problem once. The bank must demonstrate that the improvements are sustainable and embedded into its long-term operations. This means showing a consistent track record of compliance.

Sub-heading: The Final Hurdle – Order Termination

  1. Regulator Review and Verification: Once Wells Fargo believes it has met all the conditions of a specific consent order, it submits a request for termination. The regulators then conduct their own thorough review and verification to confirm that all requirements have been met satisfactorily. This can involve on-site inspections, data analysis, and interviews.
  2. Formal Termination: If the regulators are satisfied, they issue a formal announcement terminating the consent order. This is a public declaration of the bank's progress and a key milestone in its journey back to full health.

Step 4: The Impact of Consent Orders (and Their Removal)

Consent orders are not just administrative formalities; they have tangible impacts:

  • Financial Penalties: They often come with hefty fines, which have cost Wells Fargo billions of dollars.
  • Operational Restrictions: The asset cap was a prime example of an operational restriction, limiting the bank's ability to grow loans and deposits. Other restrictions might limit certain business activities or require specific approvals for new products.
  • Increased Costs: The extensive remediation efforts, including hiring compliance staff, consultants, and investing in new technology, have significantly increased the bank's operating costs.
  • Reputational Damage: The scandals and ongoing consent orders have severely damaged Wells Fargo's reputation, making it harder to attract and retain customers and talent.
  • Investor Sentiment: The uncertainty surrounding the lifting of these orders has often weighed on Wells Fargo's stock performance. The recent lifting of the asset cap, however, has led to positive investor sentiment, as it unlocks the bank's growth potential.

Step 5: What This Means for You

As a consumer or an investor, understanding Wells Fargo's regulatory journey is important:

  • For Consumers: The lifting of consent orders suggests that Wells Fargo has implemented stronger consumer protections and better oversight. This should theoretically lead to a more reliable and trustworthy banking experience. However, vigilance is always key when dealing with any financial institution.
  • For Investors: The termination of major consent orders, particularly the asset cap, signifies a significant de-risking for Wells Fargo. It opens the door for increased revenue growth, better efficiency, and potentially higher shareholder returns. It suggests that the bank is on a more stable footing.

10 Related FAQ Questions

Here are 10 related FAQ questions, starting with 'How to', along with their quick answers:

  1. How to find out if a bank is under a consent order?

    • Quick Answer: Regulatory agencies like the Federal Reserve, Office of the Comptroller of the Currency (OCC), and Consumer Financial Protection Bureau (CFPB) typically publish consent orders on their official websites. You can search their enforcement action databases.
  2. How to understand what a consent order means for me as a customer?

    • Quick Answer: While specifics vary, it generally means the bank has been found deficient in certain areas and is working to improve. It should lead to better practices and protections for customers in the long run.
  3. How to know when a consent order has been lifted?

    • Quick Answer: Regulatory agencies will issue public announcements or press releases when a consent order is terminated. Banks also often announce the termination through their newsrooms.
  4. How to report a potential banking violation to regulators?

    • Quick Answer: You can typically file a complaint directly with the relevant regulatory agency (e.g., CFPB, OCC, or your state's banking regulator) through their official websites.
  5. How to identify the key regulatory bodies overseeing large banks like Wells Fargo?

    • Quick Answer: The primary federal regulators include the Federal Reserve (for bank holding companies and systemic risk), the Office of the Comptroller of the Currency (OCC) for national banks, and the Consumer Financial Protection Bureau (CFPB) for consumer protection issues.
  6. How to assess a bank's financial health and compliance beyond consent orders?

    • Quick Answer: Look at their financial reports (e.g., quarterly earnings), read reputable financial news, and review reports from credit rating agencies and independent analysts.
  7. How to determine if a consent order impacts a bank's lending practices?

    • Quick Answer: Some consent orders directly address lending practices (e.g., mortgage or auto loan issues). An asset cap, while not directly about lending practices, can indirectly limit a bank's ability to make new loans.
  8. How to understand the historical context of Wells Fargo's regulatory issues?

    • Quick Answer: Research the "fake accounts scandal" of 2016 and subsequent investigations, as this event triggered a significant wave of regulatory actions and public scrutiny.
  9. How to evaluate a bank's commitment to compliance and ethical conduct?

    • Quick Answer: Observe leadership statements, investment in compliance infrastructure, employee training programs, and the speed and thoroughness with which they address regulatory findings.
  10. How to differentiate between various types of regulatory enforcement actions?

    • Quick Answer: Beyond consent orders, actions can include cease and desist orders (requiring an immediate halt to certain activities), civil money penalties (fines), and formal agreements, each with varying levels of severity and impact.
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