Wells Fargo Fraud Case Study Analysis
One of the most—all-time bad corporate ethics failures supernovas in modern banking
history is the Wells Fargo account fraud scandal, and it shows a major institutional failure in one
of America’s oldest banks. In September 2016, federal regulators reported that Wells Fargo
employees made up to 3.5 million accounts and credit cards of their own, without customers'
knowledge or consent, over several years. The scandal bubbled up when regulators determined
that under the pressure to meet unrealistic sales targets hardwired into Wells Fargo’s culture,
employees had opened fake accounts, transferred customers' money without their authorization,
and charged them for unwanted products and services. Wells Fargo’s reputation took a serious hit
from this crisis, and its stock price plummeted, with the helm of its ship taken over by former
CEO John Stumpf and the firing of roughly 5,300 employees. In this way, the case serves as
important lessons on how corporate culture can incentivize and enable unethical behavior and
how ethical leadership, appropriate incentive structures, and effective compliance programs in
companies, in particular in financial institutions, can go a long way in preventing such behaviors.
Additionally, it gives us insight into how crisis communication strategies should be developed
when an organization finds itself with such a reputational crisis as a result of its own systemic
failures.
Situation Analysis
That backdrop was supposed to be the very aggressive cross-selling practices, celebrated
as Wells Fargo's key competitive advantage before the scandal. Millions of unauthorized
accounts were opened by employees between 2011 and 2016 in order to meet impossible sales
quotas, according to investigations, which revealed later that the problem predates back to 2002,
thus a more systemic problem within the organization (Tayan, 2019). Branch employees faced
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extreme pressure from the bank’s ‘Eight is Great’ strategy to sell eight Wells Fargo products per
customer and were afraid of losing their jobs for not meeting ‘unrealistic’ quotas. These targets
were enforced by senior leadership and backed by a toxic, hostile, high-intensity sales culture
that included daily monitoring and threat of termination if they did not meet their numbers
(Carberry et al., 2018). This was reinforced by the organizational culture through compensation
systems that rewarded employees, first of all, according to the number of new accounts opened
and only in second place customer satisfaction and account quality. It mostly showcased how
whistleblowers who tried registering these immoral practices through internal channels were
ignored or their contracts were furthermore terminated, which has left a very bad mark on the
ethics reporting systems and compliance oversight frameworks employed by the bank. Rather
than through their own compliance systems, the scandal became public through external
channels, from where it became evident that Wells Fargo's governance structures and risk
management processes were critical failures that should have been noticed and avoided in the
broad fraud.
Communication Objectives
After the public announcement of fraud, Wells Fargo was under intense pressure to
formulate strategies to communicate with the multiple stakeholders simultaneously. In addition
to customers who were directly victimized by unauthorized accounts and fees, the bank had to
regain the trust of all customers whose confidence in the institution was severely shaken by the
disclosure of the problems. As a result, a critical priority was the ability to communicate
effectively and productively with regulators and government officials, e.g., Consumer Financial
Protection Bureau, Office of the Comptroller of Currency, Department of Justice, as the bank
was under investigation by three of these agencies. Wells Fargo needed to convince investors and