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Former Wells Fargo HR director fined $2.25M

Sioux Falls, SD
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Hope Hardison, former chief administrative officer and human resources director of Wells Fargo Bank, N.A. has agreed to the OCC's issuance of a consent order to cease and desist and to pay a civil money penalty of $2.25 million.
The Comptroller found, and Hardison neither admits nor denies, that:
(1) From 2011 to 2018, Respondent was the Bank’s Human Resources Director. She became the Bank’s Chief Administrative Officer in September 2015.
(2) Respondent was the Chair of the Bank’s Incentive Compensation Committee. She was also a member of the Bank’s Operating Committee, Team Member Misconduct Executive Committee, Ethics Committee, and Enterprise Risk Management Committee.
(3) Corporate Investigations reported to Respondent from 2012 through 2014.
(4) From at least 2002, the Community Bank, the largest line of business at the Bank, had a systemic sales practices misconduct problem.
(5) From at least 2013, Respondent should have known about the systemic sales practices misconduct problem in the Community Bank and its root cause.
(6) From 2012 to October 2016, Respondent had oversight responsibilities for the EthicsLine program—a confidential hotline for Bank employees to report improper behavior—which was one of the Bank’s primary controls for detecting sales practices misconduct. Respondent failed to adequately oversee this critical control. With respect to Community Bank employee complaints supplied to Respondent regarding sales practices misconduct and related matters, under the Bank’s decentralized model, Respondent forwarded them to the Human Resources organization of the Community Bank and did not follow up on their disposition.
(7) During her tenure as Human Resources Director and Chair of the Incentive Compensation Committee, Respondent failed to adequately execute her oversight, governance, and escalation responsibilities with respect to the Community Bank’s incentive compensation plans.
(8) Respondent co-authored three annual incentive compensation risk impact memoranda in 2014, 2015, and 2016 that were provided to the Human Resources Committee of the Board of Directors and the OCC. In those memoranda, Respondent reported a “satisfactory” risk management rating for the Community Bank each year and recommended no incentive compensation adjustments for the Head of the Community Bank related to sales practices.

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