In his decision, Hsu described Anderson’s behavior as particularly damaging to Wells Fargo’s reputation, citing her failure to challenge the bank’s incentive compensation program, her inability to escalate known risks, and her repeated downplaying of the misconduct. Anderson was also found to have provided misleading information to the OCC in 2015, which led to additional legal violations.
“Between 2013 and 2016, Anderson failed to credibly challenge the bank’s incentive compensation program, failed to escalate known or obvious risks, and repeatedly downplayed the misconduct. She also violated the law by failing to provide accurate information to the OCC back in 2015,” the OCC’s decision reads. While the decision declined to rule on whether Anderson’s actions breached her fiduciary duties to the bank, the penalties imposed reflect her significant role in the scandal.
Meanwhile, both Julian and McLinko were faulted for failing to properly manage audits that could have detected or documented the fraudulent sales practices. The OCC also criticized McLinko for his failure to maintain professional independence from the bank’s retail banking division, which was central to the misconduct. Both former executives were found to have failed to adequately escalate the issue when they became aware of the problematic sales practices.
