Every behavior begins with a belief. Every system begins with an assumption about the way the world works. The interesting question isn’t how the Wells Fargo scandal happened, or even why it happened. The more interesting question is: What did management have to believe for those behaviors to make sense?
The Behaviors
Between 2011 and 2015, employees at Wells Fargo opened millions of deposit and credit card accounts that customers had not authorized in order to meet aggressive sales goals. Wells Fargo acknowledged that at least 2 million accounts may have been unauthorized, and later reviews increased that estimate to approximately 3.5 million. Regulators concluded that compensation incentives and sales targets contributed to the misconduct.
The Consequences of Reality
On September 8, 2016, the CFPB, OCC, and the Los Angeles City Attorney announced a combined $185 million settlement against Wells Fargo. More than 5,000 employees were terminated over the sales-practices scandal, and CEO John Stumpf resigned shortly afterward amid intense public and congressional scrutiny. In 2018, the Federal Reserve imposed an unprecedented asset cap on Wells Fargo until governance and risk management deficiencies were corrected. That restriction remained in place until 2025, illustrating how long cultural failures can affect an organization.
Customs and Rituals
None of us were in the room, so we should resist inventing conversations that may not have occurred. What we do know is that sales goals and incentive compensation established the rules of the game. Employees rarely invent the scorecard. They simply learn how to win the game management designs. When promotions, recognition, and compensation reinforce one behavior, that behavior is repeated.
Over time, those repeated behaviors become customs and rituals. Those rituals eventually reinforce the original management belief, that success is measured by the scorecard. Whether that belief is intentional or accidental, culture quietly shapes itself around what management consistently rewards.
