Background: Wells Fargo has been in the press a great deal over the past few years for a variety of unscrupulous business practices and compensation programs that encouraged and rewarded such behavior. While it is unknown whether the incentive plans were specifically designed to drive such bad behavior, it is clear that controls did not exist to protect against unforeseen consequences or to support ethical leadership that might have curtailed it once it began. Some have gone so far as to suggest that the culture is/was inherently corrupt and that the incentives were intentionally designed to work within that framework.

Assignment: You have been hired as an outside Compensation Consultant to provide fresh eyes to Wells Fargo. Your role is to examine what happened (based on the readings and any other sources you wish to include), consider how such rampant fraud was allowed to occur and to make a recommendation for a new incentive program that will drive ethically responsible customer service. (Note that, as part of their sanctions announced in February 2018, the Fed has precluded Wells Fargo from getting any bigger than its current $2 trillion in assets until they are satisfied that they have cleaned up their act.)

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