Date of Award

2019

Degree Type

Thesis

Degree Name

Master of Laws (LLM)

Department

Law

Abstract

“Wells Fargo fined $1 billion for ‘reckless unsafe or unsound practices.”1 The story behind this headline in the Washington Post on April 20, 2018, set out the problem. Wells Fargo engaged in “unsafe or unsound practices”2 by charging customers for services that Wells Fargo should have absorbed and administering a compulsory insurance scheme that unnecessarily increased borrowers auto loans financial obligation without approval. 3 According to the Office of the Comptroller of the Currency (OCC), “Since at least 2011, the Bank4 (Wells Fargo) has failed to implement and maintain a compliance risk management program commensurate with the Bank’s size, complexity and risk profile.”5 The OCC also found that “a comprehensive plan to address compliance risk management deficiencies, fill critical staffing positions,” 6 enforce “a reliable risk assessment and testing program and report compliance concerns adequately to the board was” 7 not implemented.” 8

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