Fourteen Consent Orders ClosedNarrow moat

Wells Fargo (WFC) — moat facet

Wells Fargo has had fourteen consent orders lifted since 2019, and two regulatory actions are still open.

The asset cap was the most visible order, but Wells Fargo spent most of a decade under many. By March 2025 the bank said the termination of the Home Lending loss-mitigation order was the "eleventh consent order closed" since 2019, and the "fifth closed consent order since the beginning of 2025", achieved "in just three and a half years"1. By early 2026 its proxy counted "the termination of 14 consent orders"2.

Orders closedSep 2021CFPB 2016sales-practicesorder expiresFeb 2024OCC 2016orderterminatedJan 2025CFPB2022 orderterminatedMar 2025eleventhorder closedJun 2025asset capremovedEarly 2026fourteenthorder closedWells Fargo Forms 10-K FY2023, FY2024; 8-K Mar 2025; Fed; 2026 proxy
Most of the orders closed in about four years.

The dates show the pace. The consumer bureau's 2016 sales-practices order expired on 8 September 20213; the currency comptroller ended its 2016 order on 15 February 20244; the consumer bureau's 2022 order was terminated on 28 January 20255; and the Federal Reserve lifted the asset cap on 3 June 2025, saying Wells Fargo "has met all the conditions required by the 2018 enforcement action"6.

This matters to the moat because orders cost money and management time. They also kept the bank out of products and growth it would otherwise have pursued.

Two actions remain. The bank's 2025 annual report says it is still subject to the February 2018 order on board oversight and risk management and to a September 2024 formal agreement with the currency comptroller on anti-money-laundering practices7.

Two 2011 Federal Reserve orders were also terminated early in 20258. The currency comptroller ended its 2018 compliance risk management order on 13 February 20259, a month before the eleventh closure.

The orders covered more than sales practices. The 2021 order concerned loss mitigation in Home Lending10, and the 2022 consumer bureau order covered auto loans, mortgages and deposit accounts11.

Even the cap's removal left the order behind it. The Federal Reserve lifted the growth restriction in June 2025 while the rest of the 2018 enforcement action stayed in place12, so the bank was free to grow but not yet free of the Fed's oversight of its board and risk management.

The count of closed orders is the milestone to follow, and it should rise. A new consent order of any kind would say the repair was incomplete.

Moat trajectory: Widening

Eleventh order closed March 2025; asset cap lifted June 2025; fourteenth early 2026.

The number that tests this moat
Reported
Consent orders terminated since 2019
14 (early 2026)

The count of regulatory actions lifted; a new consent order would reverse the direction.

Source: Wells Fargo 2026 proxy statement ↗
⚠ Threats to the moat
⚠ THREAT 01
Regulators Promise Escalation
Wells Fargo's record means any new lapse will be punished as a repeat offence.
References
  1. ReportedBy March 2025 the bank said the termination of the Home Lending loss-mitigation order was the "eleventh consent order closed" since 2019, and the "fifth closed consent order since the beginning of 2025", achieved "in just three and a half years".
    Wells Fargo Form 8-K exhibit 99.1 - the OCC terminates the 2021 loss-mitigation consent order, the eleventh closed since 2019. — March 2025 · publ. 17 March 2025 · source ↗
  2. ReportedBy early 2026 its proxy counted "the termination of 14 consent orders".
    Wells Fargo 2026 proxy statement (DEF 14A) - the chief executive's tenure and special award, and the termination of 14 consent orders. — 2026 · publ. 18 March 2026 · source ↗
  3. ReportedThe consumer bureau's 2016 sales-practices order expired on 8 September 2021; the currency comptroller ended its 2016 order on 15 February 2024; the consumer bureau's 2022 order was terminated on 28 January 2025; and the Federal Reserve lifted the asset cap on 3 June 2025, saying Wells Fargo "has met all the conditions required by the 2018 enforcement action".
    Wells Fargo 2023 Annual Report, part of the Form 10-K for fiscal 2023 - restated 2021-2022 results and ROTCE, segment results for 2022 and the termination of the 2016 consent orders. — FY2023 · publ. February 2024 · source ↗
  4. ReportedThe consumer bureau's 2016 sales-practices order expired on 8 September 2021; the currency comptroller ended its 2016 order on 15 February 2024; the consumer bureau's 2022 order was terminated on 28 January 2025; and the Federal Reserve lifted the asset cap on 3 June 2025, saying Wells Fargo "has met all the conditions required by the 2018 enforcement action".
    Wells Fargo 2023 Annual Report, part of the Form 10-K for fiscal 2023 - restated 2021-2022 results and ROTCE, segment results for 2022 and the termination of the 2016 consent orders. — FY2023 · publ. February 2024 · source ↗
  5. ReportedThe consumer bureau's 2016 sales-practices order expired on 8 September 2021; the currency comptroller ended its 2016 order on 15 February 2024; the consumer bureau's 2022 order was terminated on 28 January 2025; and the Federal Reserve lifted the asset cap on 3 June 2025, saying Wells Fargo "has met all the conditions required by the 2018 enforcement action".
    Wells Fargo 2024 Annual Report (financial statements and MD&A), part of the Form 10-K for fiscal 2024 - customer remediation accruals, the CFPB order termination, the 9.80% CET1 requirement and the debit interchange and overdraft rules. — FY2024 · publ. February 2025 · source ↗
  6. ReportedThe consumer bureau's 2016 sales-practices order expired on 8 September 2021; the currency comptroller ended its 2016 order on 15 February 2024; the consumer bureau's 2022 order was terminated on 28 January 2025; and the Federal Reserve lifted the asset cap on 3 June 2025, saying Wells Fargo "has met all the conditions required by the 2018 enforcement action".
    Federal Reserve press release, 3 June 2025 - Wells Fargo no longer subject to the asset growth restriction. — June 2025 · publ. 3 June 2025 · source ↗
  7. ReportedThe bank's 2025 annual report says it is still subject to the February 2018 order on board oversight and risk management and to a September 2024 formal agreement with the currency comptroller on anti-money-laundering practices.
    Wells Fargo 2025 Annual Report to Shareholders (financial statements, MD&A and segment note), part of the Form 10-K for fiscal 2025 - Item 1A risk factors and regulatory matters. — FY2025 · publ. 24 February 2026 · source ↗
  8. ReportedTwo 2011 Federal Reserve orders were also terminated early in 2025.
    Wells Fargo Form 8-K exhibit 99.1 - the OCC terminates the 2021 loss-mitigation consent order, the eleventh closed since 2019. — March 2025 · publ. 17 March 2025 · source ↗
  9. ReportedThe currency comptroller ended its 2018 compliance risk management order on 13 February 2025, a month before the eleventh closure.
    Wells Fargo 2024 Annual Report (financial statements and MD&A), part of the Form 10-K for fiscal 2024 - customer remediation accruals, the CFPB order termination, the 9.80% CET1 requirement and the debit interchange and overdraft rules. — FY2024 · publ. February 2025 · source ↗
  10. ReportedThe 2021 order concerned loss mitigation in Home Lending, and the 2022 consumer bureau order covered auto loans, mortgages and deposit accounts.
    Wells Fargo 2024 Annual Report (financial statements and MD&A), part of the Form 10-K for fiscal 2024 - customer remediation accruals, the CFPB order termination, the 9.80% CET1 requirement and the debit interchange and overdraft rules. — FY2024 · publ. February 2025 · source ↗
  11. ReportedThe 2021 order concerned loss mitigation in Home Lending, and the 2022 consumer bureau order covered auto loans, mortgages and deposit accounts.
    Consumer Financial Protection Bureau press release, 20 December 2022 - more than $2 billion of redress and a $1.7 billion civil penalty. — December 2022 · publ. 20 December 2022 · source ↗
  12. ReportedThe Federal Reserve lifted the growth restriction in June 2025 while the rest of the 2018 enforcement action stayed in place, so the bank was free to grow but not yet free of the Fed's oversight of its board and risk management.
    Federal Reserve press release, 3 June 2025 - Wells Fargo no longer subject to the asset growth restriction. — June 2025 · publ. 3 June 2025 · source ↗
Sources
Generated September 28, 2026