On September 8, 2016, the Consumer Financial Protection Bureau (CFPB or “Bureau”), the Office of the Comptroller of the Currency (OCC), and the City and County of Los Angeles entered into a Consent Order with Wells Fargo (the “Bank”), with civil money penalties totaling $185 million. The CFPB’s portion of those penalties is $100 million, which is the largest fine the Bureau has imposed since opening its doors in July 2011. The alleged conduct in question involved bank employees opening new deposit and credit accounts, issuing debit cards, and initiating online banking services without the knowledge of customers.

ALLEGED CONDUCT -

According to the CFPB, the Bank set sales goals and implemented sales incentives, including an incentivecompensation program, in an effort to improve cross-selling of banking products and services to existing customers. Allegedly, between May 2011 and July 2015, thousands of bank employees engaged in improper conduct to meet the Bank’s sales goals and take advantage of the sales incentive program, reportedly resulting in the termination of over 5,000 employees. The conduct allegedly included...