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Wells Fargo & Company

wfc · NYSE Financial Services
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Ticker wfc
Exchange NYSE
Sector Financial Services
Industry Banks - Diversified
Employees 10,000+
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FY2018 Annual Report · Wells Fargo & Company
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Cove r :   We l l s   Fa rg o   c u s to m e r   E r i k   G r u b e r   o u t s i d e   h i s   n e w   h o m e   i n   P h i l a d e l p h i a .   Le a r n   m o re   o n   p a g e   3 4 .  

Contents
 

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L E T T E R   F R O M   C H A I R   O F   T H E   B O A R D  

L E T T E R   F R O M   C H I E F   E X E C U T I V E   O F F I C E R   A N D   P R E S I D E N T  

S T O R I E S :   O U R   P R O G R E S S   O N   T H E   R O A D   A H E A D  

O P E R A T I N G   C O M M I T T E E   A N D   O T H E R   C O R P O R A T E   O F F I C E R S  

B O A R D   O F   D I R E C T O R S  

2 0 1 8   C O R P O R A T E   R E S P O N S I B I L I T Y   H I G H L I G H T S  

2 0 1 8   F I N A N C I A L   R E P O R T  

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S T O C K   P E R F O R M A N C E  

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Dear  Fellow S hare holder s 
 

We are steadfast in 
our commitment to 
building and protecting 
the long-term value 
of the company. 

Looking back on my first year as chair of the 

individually and the decentralized nature of 

Wells Fargo Board of Directors, I am encouraged 

certain control functions. I believe this review 

by the progress the company and our board 

was necessary to help us serve our customers 

have made as we build a better Wells Fargo for 

better. In the past two years, we have centralized 

the future. 

many aspects of our organizational structure, 

strengthened risk management, and improved 

Before I talk about the board, I’d like to recognize 

governance practices and oversight. Going 

the tireless efforts of our management team. 

forward, we believe maintaining a holistic view 

Tim Sloan became CEO just over two years ago, 

of the company and focusing on operational 

and since then, with the full support of the board, 

excellence will result in continued positive change. 

he has been driving transformational change 

at the company. 

Organizationally, Tim has pulled together a 

strong management team that blends Wells Fargo 

As CEO, Tim’s first priority was to initiate an 

veterans with experienced talent from elsewhere. 

extensive review to identify, understand, and 

Three of his direct reports are from outside 

resolve the problems of the past; to provide 

the company, and two more — the company’s 

appropriate remediation to customers who 

new head of Technology and chief auditor — will 

were harmed; and to be transparent about our 

join Wells Fargo in April. Most of his other direct 

progress. We discovered a variety of issues, and 

reports are in new or expanded roles. Together, 

even though the specific causes may have been 

the leadership team is executing plans to 

different, some common themes emerged, such 

streamline the company’s operating structure, 

as the company’s history of running businesses 

better define roles and responsibilities, fill key 

E L I Z A B E T H   A .   D U K E   |  C h a i r,   B o a r d   o f   D i r e c t o r s ,   W e l l s   F a r g o   &   C o m p a n y  

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4 

positions, enhance the way we serve customers, 

regulatory expectations remains a top priority, 

strengthen risk and compliance measures, and 

as is continuing to serve our customers and help 

instill our Vision, Values & Goals uniformly 

them succeed financially. 

into the culture of Wells Fargo. In addition, the 

management team has redesigned the strategy, 

O U R   B O A R D   O F   D I R E C T O R S  

leadership, and incentive structure of the retail 

The board operates very differently today than 

bank and the Wells Fargo Auto business to align 

it did a year ago. Following our independent 

with a more forward-looking consumer approach. 

board investigation into retail sales practices 

One important early indicator of the success 

and our 2017 board self-evaluation, we 

of these efforts is that “Customer Loyalty” and 

identified several areas in which we could 

“Overall Satisfaction with Most Recent Visit” 

enhance board oversight. As a result, we added 

Community Bank branch survey scores reached 

more directors with expertise in financial 

24-month highs in December 2018. At the same 

services; adjusted committee structures, 

time, voluntary team member attrition in 2018 

charters, and membership; enhanced agenda 

improved to its lowest level in six years. 

planning; and worked with management to 

better focus materials provided to the board. 

Early in 2018, we agreed to a consent order with  Mary Jo White, a senior partner at the law firm 

the Board of Governors of the Federal Reserve 

of Debevoise & Plimpton LLP and former chair 

System and consent orders with the Office of the 

of the Securities and Exchange Commission, 

Comptroller of the Currency and the Consumer 

was engaged by the board to facilitate its 2017 

Financial Protection Bureau. To make sure we are 

self-evaluation and work with the board on 

meeting our commitments under the consent 

its 2018 self-evaluation to help assess our 

orders, the board and senior management are 

progress. Regular self-assessment provides us 

engaged in regular dialogue with our regulators. 

a mechanism for continuous improvement. 

Clear communication is necessary so that the 
comprehensive changes we are making across  With 13 directors, our board is smaller than in 
the recent past. More than half of the current 

the company will sufficiently strengthen our 

governance and oversight, as well as operational 

directors joined the board in 2017 or later. 

and compliance risk management. Although we 

These new directors came ready to work and 

are devoting a significant amount of resources 

began to contribute immediately. The new 

to these efforts, we also have been delivering on 

directors have brought important experience in 

our ongoing cost-reduction initiatives. Expense 

several areas, including financial services, other 

savings from simplifying and centralizing 

highly regulated industries, and consumer brand 

operations help fund our investments in areas 

management. With board turnover, we have 

such as risk management and technology. 

also refreshed our board committee leadership. 

Since September 2017, six of seven standing 

We continue to have constructive dialogue 

board committees have new committee chairs. 

with the Federal Reserve on an ongoing basis 

Today, the average tenure of our independent 

to clarify expectations, receive feedback, and 

directors is less than four years. Even as the 

assess progress under the consent order, and 

board and its committees have experienced much 

we are now planning to operate under the 

change, we remain focused on responding to 

asset cap through the end of 2019. Making 

stakeholders, enhancing oversight, and creating 

the changes necessary to ensure we meet 

long-term value for shareholders. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
  
  
  
 
  
  
 
 
  
  
  
   
  
  
   
   
  
  
 
 
  
  
  
   
 
  
 
 
  
 
 
 
 
 
  
  
 
 
 
 
 
 
 
 
In January 2019, Wayne Hewett joined our 

satisfying regulatory expectations. We 

board. Throughout his career as a CEO and 

are specifically focused on satisfying the 

senior executive, Wayne has had a record of 

requirements of the company’s outstanding 

success managing strategic priorities in complex 

consent orders. But more broadly, we are 

business environments. His background as an 

enhancing our risk and reporting systems 

industrial engineer and experience with data-

to meet the heightened regulatory 

driven process improvement methodologies 

expectations for systemically important 

will be especially valuable as we focus on 

financial institutions and our own goal of 

operational excellence. 

industry leadership in risk management. 

We are engaging in frequent and open 

Karen Peetz will retire from the board at our 

communication with our regulators about 

Annual Meeting of Shareholders in April 

our progress. 

2019. Karen has been effective at framing risk 

management imperatives and insisting on 

Enhancing risk management. 

individual accountability, especially in her role 

Wells Fargo has been and remains an 

as chair of the Risk Committee. Since Karen 

industry leader in credit, market, and 

joined the Risk Committee, we have brought 

liquidity risk management. Over the years, 

on to our board and Risk Committee additional 

the company has demonstrated an ability 

expertise in risk management of financial 

to manage through difficult economic 

institutions. By announcing her retirement 

conditions, including the 2008 financial 

decision early, Karen has again demonstrated 

crisis, but management of compliance and 

her commitment to responsible governance 

operational risks needed improvement. 

by ensuring a smooth transition of Risk 

We have new leadership in the chief risk 

Committee chair to Maria Morris, who will 

officer, chief compliance officer, head of 

continue the work Karen started. 

Regulatory Relations, and chief operational 

O V E R S I G H T  

risk officer roles. They have developed and 

are busy implementing plans to continue 

Our board oversight in 2018 focused heavily 

building our operational and compliance 

on identifying, understanding, and resolving 

risk management systems to a level that 

issues within the company, including 

matches our business, structure, and 

concerns identified by our regulators. 

strategies. These plans include enhancing 

We are also looking to the future. In his letter 

management-level governance committee 

to shareholders, Tim details management 

structures, oversight, monitoring and 

strategies to achieve our six company goals 

controls, and escalation processes and 

of becoming the financial services leader in 

procedures. Our objective is to build an 

customer service and advice, team member 

industry-leading risk management program. 

engagement, innovation, risk management, 

corporate citizenship, and shareholder value. 

Operational excellence. Many of our past 

Going forward, board oversight of those 

operational risk problems stemmed from 

goals will emphasize the following: 

weaknesses in underlying operations. 

Meeting regulatory expectations. 

to inventory and map all our business 

We recognize the importance of fully 

processes. While identifying risk areas 

In 2018, management launched a project 

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6 

will improve our control testing and 

S TA K E H O L D E R   I N T E R A C T I O N  

monitoring functions, reducing the number 

For the past several years, our independent 

and complexity of our business processes 

directors have participated in a shareholder 

also offers the potential for improving 

engagement program to help us better 

the efficiency and effectiveness of core 

understand our shareholders’ views on key 

operations. We expect this work to 

corporate governance and other topics. 

improve the customer and team member 

The candid feedback of our shareholders 

experience, reduce operating costs, and 

helps us define priorities, assess progress, 

enhance risk management. 

and enhance our corporate governance 

practices. In 2018, I met with shareholders 

Oversight of culture and human capital 

representing more than 35 percent of our 

management. We continue to assess 

company’s common stock to discuss our 

and shape the company’s culture, with 

governance approach. 

an emphasis on such areas as ethics, 

training and development, and diversity 

Our board is also focused on corporate 

and inclusion. One of the guiding values 

citizenship, which is overseen by the board’s 

of Wells Fargo is “people as a competitive 

Corporate Responsibility Committee. 

advantage.” We expect to devote a 

The committee reviews environmental and 

substantial amount of board attention to 

social governance practices and policies. 

talent management strategies, including 

Following our 2018 Annual Meeting of 

plans to attract, retain, reward, develop, 

Shareholders, Corporate Responsibility 

and care for the very best people available. 

Committee members met with members 

We recognize the importance of rewarding 

of our external Stakeholder Advisory Council  

outstanding performance and holding 

to seek feedback and insights on current 

team members accountable. 

and emerging issues important to them. 

Tim and I continued to meet with the council 

Technology. New generations of customers 

during the year to discuss such varied topics 

and team members expect technology to 

as mortgage lending, services for unbanked or 

work seamlessly and intuitively. Thoughtful 

underbanked consumers, our efforts to help 

use of emerging technologies can enable 

customers avoid and reduce overdraft fees, 

quantum leaps in innovation and efficiency. 

environmental commitments, human rights, 

At the same time, cyber risk is at an all-time 

and reputational risk issues. 

high. We want to make sure all our systems 

operate on up-to-date platforms, are able to 

One of our most significant responses to 

process and protect massive amounts of data, 

shareholder feedback was the publication of 

and contribute to our vision of operational 

a Business Standards Report on our website 

excellence and leadership in innovation. 

in early 2019. The report was the culmination 

of engagement with a group of stakeholders 

We have already made progress in each 

led by the Interfaith Center on Corporate 

of these areas, and we will continue to focus 

Responsibility, which requested the report. 

on them in 2019. 

The report discusses our business practices and 

the many fundamental changes we have made — 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
  
 
  
 
 
 
 
  
 
  
  
  
  
 
 
 
 
 
 
  
  
 
 
 
  
  
  
 
 
 
 
 
  
 
  
 
 
 
 
  
 
and continue to make — as we transform our 

We do not take our strengths for granted. 

company. The report also details what we have 

We intend to continue to strengthen risk 

learned and what we have changed as we work 

management, streamline and simplify 

to improve the company and rebuild trust. 

operations, and innovate responsibly so we 

I encourage you to read it. 

can build on our strengths. The goal of all 

“ The entire board remains 

excited and optimistic about 
Wells Fargo.” 

these efforts is to become even more customer-

focused, innovative, and better positioned for 

the future — creating long-term value for 

our shareholders. 

I N   A P P R E C I AT I O N  

On behalf of the directors of your company, 

L O N G -T E R M   S H A R E H O L D E R   VA L U E  

thank you for choosing to invest in Wells Fargo 

Over the past few years, management and the 

and for your continued faith in the future of our 

board have devoted a substantial amount of time 

company. Even though much work remains, we 

and attention to the problems we have found 

believe we are on the right path and are making 

in our company. Finding, fixing, and atoning for 

real progress. We are confident we have a CEO 

those problems is necessary to build our future 

and management team with the vision and 

on a strong foundation and is required to meet the 

strategy to achieve our goals — and to fix the 

expectations of our regulators and regain the 

problems of the past while building a strong 

trust of our customers, team members, and the 

foundation for the future. The changes the 

public. Through it all, we have also delivered solid 

company is making are showing positive signs, 

7 

financial performance. The company earned 

and we are confident in our success. 

$22.4 billion in 2018, or $4.28 per diluted 

common share, the highest earnings per share 

I encourage you to carefully review this 

in the company’s history. Our ability to sustain 

report, our 2019 proxy statement, and the 

solid financial performance in the face of our 

other materials the company makes available 

recent challenges is a testament to the fi  nancial 

to shareholders to better understand the 

durability provided by our core franchise and 

opportunities and challenges ahead and 

diversified business model. 

Wells Fargo’s work to execute its strategy. 

Our capital levels are well in excess of regulatory 

building and protecting the long-term value 

We are steadfast in our commitment to 

minimums. As part of the company’s goal of 

of the company. 

delivering long-term shareholder value, we’re 

committed to returning capital to shareholders 

The entire board remains excited and 

when appropriate. During 2018 we returned a 

optimistic about Wells Fargo. 

record $25.8 billion in capital to shareholders 

through common stock dividends and net share 

repurchases, representing a 78 percent increase 

from 2017. In January 2019, we increased the 

quarterly common stock dividend from 43 cents 

to 45 cents per share. 

E L I Z A B E T H   A .   D U K E  

Chair, Board of Directors
 
Wells Fargo & Company
 
February 15, 2019 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
8 

To  Ou r  Owne rs
  

I am as optimistic as 
ever about the future 
of Wells Fargo. 

We have a clear vision and deeply held values. 

and our team members. We continued to make 

Our company continues to produce strong 

progress in our efforts to address past issues 

financial results, we have robust goals in place, 

and rebuild trust with stakeholders. While we 

and I believe we have the best team members 

have more work to do, we have learned from our 

in the business to execute on our goals for our 

mistakes and are making fundamental changes 

70 million customers. 

as we transform Wells Fargo for the future. 

9 

We are building on a truly remarkable history. 

T H E   D U R A B I L I T Y   O F   T H E   F R A N C H I S E  

Wells Fargo has prospered for 166 years, an 

I believe Wells Fargo is prepared for the future — 

incredibly durable franchise. Our symbol, the 

for evolving customer preferences, for emerging 

stagecoach, was not only transformative in its 

technologies, for new risks, and more — and I am 

time, it also signifies forward momentum. Today  

confident that our underlying strengths provide 

we are maintaining that momentum in many 

a very strong foundation for success. These 

ways, including a new brand strategy inspired by 

strengths include our diversified business model, 

human ingenuity and featuring a more modern 

which has enabled us to perform well through 

version of the stagecoach. 

a variety of interest rate and economic cycles. 

In 2018, we further strengthened the foundation 

We also have industry-leading distribution, both 

for our road ahead through new products and 

physical and digital. We are a longtime leader in 

services, improvements in the customer 

providing innovation for our customers, and our 

experience, greater operational efficiency, and 

pace of innovation has increased. 

deepened commitments to our communities 

T I MOT H Y   J.   S LOA N    |  C h i e f   E x e c u t i v e   O f f i c e r   a n d   P r e s i d e n t ,   W e l l s   F a r g o   &   C o m p a n y  

   
  
 
 
  
  
 
 
 
 
 
 
 
 
  
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
  
  
 
We have a large customer base, serving one in 

W E   A R E   T R A N S F O R M I N G  

three U.S. households, and our valuable low-cost 

F O R   T H E   F U T U R E  

deposit franchise includes $1.3 trillion in deposits. 

The future of the financial services industry 

We offer a broad product set at scale, including 

encompasses many different aspects, and  

being among the largest lenders in the U.S., and 

I am confident that Wells Fargo is taking 

our outstanding team is committed to serving 

a comprehensive view. 

our customers. 

This year, we have made significant progress on 

Our strong credit discipline has enabled us to 

strengthening our risk management, especially 

perform well through numerous credit cycles, 

operational and compliance risk. This is a top 

and we currently have historically low charge-

priority for the company and for me. To further 

offs. We have delivered consistent shareholder 

our risk management capabilities, we’ve made a 

returns and built a strong capital position, 

tremendous investment in people, technology, 

and we remain committed to returning more 

infrastructure, and cybersecurity. 

capital to shareholders. 

In January 2019, we released a Business 

we put our vision and values, the bedrock of our 

Standards Report detailing the actions we have 

company, into practice. And that’s how we will 

taken to address past issues and outlining our 

achieve our goals. Culture also means that we 

business practices and areas of focus as we 

work as a team to hold each other accountable. 

We also continue to focus on our culture. It’s how 

10 

move forward. The report addresses how we 

In order for Wells Fargo to fulfill its vision of helping 

are improving our culture, making things 

our customers succeed financially, every team 

right for customers who were harmed, and 

member needs to be living our values every day. 

strengthening our risk management and 

controls. Titled “Learning from the past, 

We made several leadership changes in 2018. 

transforming for the future,” it represents 

For example, we welcomed a new chief risk 

our commitment to transparency as well as 

officer, Mandy Norton, who brings nearly three 

an important step in engaging and rebuilding 

decades of financial industry experience to the 

trust with all of our stakeholders. 

role. Mandy has immediately made her mark 

as an experienced and insightful leader who 

Every day I meet with people who have a stake 

has driven our risk management work forward 

in our success — including customers, team 

throughout the company. 

members, community leaders, investors, 

and government leaders. These conversations 

We announced that Saul Van Beurden, who has 

are the best part of my day! The feedback I hear 

25 years of financial services experience, will fill 

is one way to affirm that we’ve made a lot of 

the new head of Technology role at our company, 

progress in transforming Wells Fargo. We have 

reflecting the importance of centralizing and 

work ahead, and we are staying focused on 

elevating that work. And Julie Scammahorn will 

our six company goals: becoming the financial 

join Wells Fargo as chief auditor. Julie brings 

services leader in customer service and advice, 

significant experience and a proven track record 

team member engagement, innovation, risk 

to this role, having led large audit functions for 

management, corporate citizenship, and 

global financial services institutions. Saul and 

shareholder value. 

Julie will join our Operating Committee. I also 

  
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
  
 
 
 
 
   
  
 
 
 
  
  
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
  
 
 
  
  
 
 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
elevated our head of Human Resources, David 

greater consistency and manage risk. A key 

Galloreese, who joined the company in 2018, to 

component of the centralization process was 

the Operating Committee, reporting to me, and 

the consolidation of 57 regional business 

consolidated our Corporate Philanthropy and 

centers into four regional hubs, which we 

Community Relations work with the Stakeholder 

completed in 2018. This transformation 

Relations function led by Jim Rowe, who also 

was designed to enable us to better serve 

reports to me. 

“ We are making changes to 

better serve our customers, as 

we continue to put them at the 

center of everything we do.” 

our customers and improve our efficiency 

by simplifying change delivery, reducing 

operational risk, leveraging enterprise 

infrastructure and standards, improving 

consistency, increasing career development 

opportunities for team members, and 

creating economies of skill and scale by 

co-locating similar functions. 

Wealth Management’s Fiduciary Management 

I am pleased that 2018 was another great year 

Services team instituted a series of enhance­

of innovation for our customers and clients. 

ments to its client service model in 2018, 

We prioritize innovation not in terms of what 

including moving to a single point of contact 

we can do, but based on what our customers 

from a team-based model for serving affluent 

tell us they want and need. That means the 

fiduciary and trust clients, having newly 

continued expansion of services such as 

assigned relationship managers proactively 

Pay With Wells Fargo5, now in pilot; our online 

reach out to each client, and implementing 

mortgage application; and Control Tower™. 

an automated workflow tool to provide front 

office partners with visibility into servicing 

We are also focused on operational excellence, 

requests. One result is that overall client 

which we are driving through every corner of 

loyalty and satisfaction increased more than 

our business. This effort includes reducing the 

10 percentage points. 

number of processes we have for any given 

task and assessing the efficiency of those 

We’re in the process of transforming our 

processes. We are considering where there are 

Wholesale Banking division to reduce 

risks in our operations and how we can mitigate 

duplicative processes and platforms and 

them. We are evaluating the number of platforms 

break down the silos that exist across 

and technology tools we use in our work and 

our businesses so we can provide a more 

how we can combine and reduce them. And, 

consistent and efficient customer and team 

finally, we are ensuring that we have the proper 

member experience. That should allow us 

oversight and the proper testing for each of our 

to do a better job of serving the customer’s 

processes. Some examples: 

existing and emerging needs. Since I spent 

many years of my career in the Wholesale 

Wells Fargo Auto, which serves more than 

Banking business, I know firsthand what 

3 million auto loan customers and more 

an incredible difference these operational 

than 11,000 auto dealers, centralized 

improvements can make for our team 

back-office business functions to create 

members and our customers. 

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We have brought together more than 200 

as growth in net interest income was more than 

team members from 14 teams to create an 

offset by a decline in noninterest income. 

Estate Care Center of Excellence, focused on 

simplifying the estate settlement process 

Credit quality remained strong with our net 

for survivors when a loved one passes 

charge-off rate near historic lows. Our capital 

away. When rollout is complete to all of our 

levels also remained strong, and we returned a 

branches, survivors will no longer have to 

record $25.8 billion to shareholders in 2018, 

contact multiple lines of business to deal 

up 78 percent from 2017, including reducing 

with finances. A dedicated team member 

our common shares outstanding by 6 percent 

will support them throughout the process, 

in 2018. 

reducing required paperwork and providing 

access to new digital self-service capabilities 

With respect to the Federal Reserve consent 

to simplify settling an estate. In the wake of 

order from February 2018, we continue to have 

the tragic wildfires in Northern California, the 

constructive dialogue with the Federal Reserve 

Estate Care Center of Excellence developed 

on an ongoing basis to clarify expectations, 

special procedures to assist family members 

receive feedback, and assess progress. In order to 

who lack traditional documentation. 

have enough time to incorporate this feedback 

into our plans in a thoughtful manner, adopt 

Finally, we’ve made good progress in making 

and implement the final plans as accepted by 

things right for our customers. We created a 

the Federal Reserve, and complete the required 

12 

Customer Remediation Center of Excellence 

third-party reviews, we are planning to operate 

to establish a consistent approach to managing 

under the consent order’s asset cap through the 

and executing remediation efforts across 

end of 2019. Making the changes necessary to 

Wells Fargo. This includes strengthening internal 

ensure we meet regulatory expectations remains 

governance and reporting processes to achieve 

a top priority, as is continuing to serve our 

greater accountability. It also includes investing 

customers and help them succeed financially. 

in specialized teams dedicated to remediation 

We believe that we can achieve both of these 

efforts and providing them the resources they 

priorities while we operate under the asset cap. 

need to provide outstanding service to customers. 

O U R   C O M PA N Y   G O A L S  

All of these elements are examples of the 

More than a year ago, I introduced six company 

significant milestones we accomplished in 2018. 

goals, so everyone at Wells Fargo would be clear 

F I N A N C I A L   R E P O R T  

on the most important things we need to do to 

continue to move forward. Our goals are rooted 

Our financial results in 2018 were solid. 

in our vision — to satisfy our customers’ financial 

Wells Fargo generated $22.4 billion in net 

needs and help them succeed financially — and 

income in 2018, or $4.28 per diluted common 

our company values of doing what’s right for 

share, the highest earnings per common share 

customers, people as a competitive advantage, 

in the company’s history. We achieved our 

ethics, diversity and inclusion, and leadership. 

2018 expense target. Expenses declined, 

driven by lower operating losses as well as the 

I am delighted that in 2018 we made very strong 

progress we’ve made to reduce expenses while 

progress toward our goals. 

reinvesting in the business. Revenue declined 

 
 
 
 
 
 
 
 
  
 
   
 
 
 
 
  
 
 
   
  
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
T H E   V I S I O N ,   V A L U E S   &   G O A L S  
O F   W E L L S   F A R G O  

Our Vision 

Our  Goals 

We want to satisfy our customers’ financial 
needs and help them succeed financially. 

We want to become the financial services 
leader in these areas: 

Our Va lues 

What’s right for customers 

People as a competitive advantage 

Ethics 

Diversity and inclusion 

Leadership 

Customer service 
and advice 

Team member
 
engagement
 

Innovation 

Risk management 

Corporate 
citizenship  

Shareholder
 
value
 

C U S T O M E R   S E R V I C E   A N D   A D V I C E  

might want an auto, mortgage, or small business 

We are making changes to better serve our 

loan; a retirement savings account; or the services 

customers, as we continue to put them at the 

of our wealth management team. Having one 

center of everything we do. As a company, 

Consumer Strategy means we are with our 

we have always emphasized working together 

customers at every step of their financial lives. 

as a team to provide the best service for all 

our customers — because no matter the role, 

We are continuing to improve the customer 

our work affects them. 

and team member experience within Consumer 

Banking with speed, convenience, and new 

How we serve our customers’ needs is evolving. 

digital offerings. Our branch survey scores for 

Our Consumer Strategy is a holistic approach 

“Customer Loyalty” and “Overall Satisfaction 

designed to meet our customers’ financial needs 

with Most Recent Visit” reached a 24-month 

by anticipating and serving every stage of their 

high in December 2018. 

financial journey — and it extends across all of 

our consumer businesses. 

The Customer Relationship View, a new customer 

relationship platform we developed, gives our 

When customers start their financial journey, 

team members a more holistic view of each 

they may rely on balance alerts so they can 

customer and saves customers from rehashing 

monitor their checking account status more 

interactions they’ve already had. For example, 

closely. (We sent an average of 37 million 

one of our bankers in Lubbock, Texas, phoned a 

monthly zero-balance and customer-specific 

longtime customer to thank him for his business, 

balance alerts to our customers last year!) 

and in the course of their conversation, the banker 

Or Overdraft Rewind®, which helped more 

reminded him that he had more than 64,000 

than 2.3 million customers avoid overdraft 

unused credit card points. 

charges in 2018. Eventually, customers 

13 

 
 
 
   
  
  
 
 
 
 
 
 
 
 
  
 
 
 
 
  
  
 
  
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
  
  
   
   
   
   
   
   
14 

The customer was then advised that he could 

customers every day and demonstrate great 

redeem the points through our Go Far® Rewards 

optimism about our future. Our voluntary team 

program. The customer redeemed the points 

member attrition improved to its lowest level 

for cash, which he used to buy plane tickets 

in six years in 2018. Team members are truly 

for family members so they could visit him 

our greatest asset. 

and his wife. 

They are also the source of some of our best ideas! 

Changes like these help our team members 

In 2018, we continued to gather their ideas and 

become better connected with their customers 

feedback through multiple channels, including 

and maintain their focus on our customers’ 

surveys, focus groups, our internal team member 

needs. Between May and December 2018, our 

portal, and town hall meetings. Our team members 

bankers reached out to 3.3 million customers 

will tell you that I am the biggest cheerleader for 

to thank them for their business, respond to 

our surveys, because I believe so strongly in the 

their questions, and make appointments for 

importance of their feedback. In fact, I think they 

in-person consultations. 

get tired of me reminding them to take advantage 

of every opportunity to have their voices heard. 

We are also transforming our Wealth and 

Investment Management businesses to make 

Our team members are the face of Wells Fargo, 

them more client-centric. The changes we 

and they drive our company culture. In 2018, 

are making are designed to make WIM faster, 

we introduced a set of clear and common 

simpler, and better for clients, with a focus on 

behavioral expectations for all team members. 

the research, thought leadership, and advice 

These expectations describe how team members 

that WIM clients value. An example is Envision 

should conduct themselves at work, and this 

Scenario, introduced in 2018, which allows 

allows us to more consistently align individual 

clients to see how changing their investment 

actions with our Vision, Values & Goals. We help 

decisions can impact their investment goals. 

ensure accountability and measure performance 

And as I stated earlier, putting the customer at 

leadership objective that all team members 

the center of everything we do also means that we 

had as part of their 2018 performance plans. 

make things right for them. So we have worked to 

A common “One Wells Fargo” culture helps 

implement a consistent, companywide customer 

ensure that we are focused on the right things 

against these expectations through a single 

complaints strategy, using data and analytics so 

to drive our success. 

we can assist our customers with their concerns 

more proactively and, when necessary, direct them 

“ Team members are truly 

to a team member with expertise to understand 

their concerns and resolve them. 

our greatest asset.” 

T E A M   M E M B E R   E N G A G E M E N T  

I am privileged to meet regularly with our 

Diversity and inclusion, one of our five primary 

customers and community leaders, and I hear 

values, is essential to our success. In order 

their appreciation and praise for our team 

to satisfy our customers’ financial needs and 

members. I am proud of Wells Fargo’s 259,000 

help them succeed financially, our team needs to 

hardworking team members, who take care of 

reflect the diversity of our customers in the U.S., 

 
 
 
 
 
 
  
 
 
 
 
  
 
  
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
  
  
 
 
 
 
  
  
 
 
 
 
 
 
 
 
  
  
 
  
 
   
 
 
 
 
 
which is growing more diverse every day, and 

said above, we seek out team member feedback 

around the world. I also strongly believe that when 

regularly so we can measure the effectiveness of 

you get people with different experiences in a 

what we offer, and we use team member ideas 

room or working on a team together, you get better 

and opinions to drive our engagement efforts. 

ideas and better problem solving. I’m proud that 

our efforts have been recognized externally by the 

Most important, through their feedback, our team 

Bloomberg Gender Equality Index, DiversityInc, 

members remind me how important the work 

the Human Rights Campaign, and the National 

we do is, because they tell me how much they 

Organization on Disability. 

care about our customers. 

An example of our focus on diversity and 

I N N O VAT I O N  

inclusion in action is our commitment to military 

At Wells Fargo, we are innovating because our 

service members and veterans. At any one time, 

customers are asking for it. They expect us to keep 

Wells Fargo has more than 250 team members 

up with other technological advances they see in 

on active duty. We support those team members 

their daily lives. Convenience used to mean a bank 

through financial and other benefits. We value 

branch on every corner, but now there are a variety 

the leadership and skills of military veterans, 

of channels our customers can use to engage 

and we have a number of recruiting programs 

with us: a branch, their phones, online banking, 

in place to help us identify and hire veterans. 

and more. As customer engagement continues 

to grow, we are using customer feedback to drive 

Our team members are our competitive advantage, 

new products and services. 

and we continue to invest in them in many ways.  

15 

In 2018, we increased the minimum base pay 

An example is the new Wells Fargo Propel® 

in the U.S. to $15 an hour, which benefited 

American Express® Card (page 36). Propel offers 

approximately 36,000 team members. We also 

one of the most compelling rewards programs 

reviewed pay for team members whose salaries 

for no-annual-fee cards, and we’re delighted 

were at or slightly above the new minimum wage 

with its success so far. It came to life because 

and increased the base pay for approximately 

our customers and our team members told us 

50,000 team members. Our team members receive 

what they wanted. 

competitive salaries, training and development 

offerings, and leadership opportunities. And we 

Our innovation program is focused on five areas that 

spend approximately $13,000 annually per 

can help us deliver additional value to our customers. 

U.S. team member to provide affordable health 

care options, work-life balance programs, 401(k) 

First, we are creating digital account opening 

matching contributions, a discretionary profit-

sharing plan, and family leave. In 2018, 

approximately 250,000 team members 

experiences for many of our products so 

the experience is simple and fast and helps 

customers get the most out of their new 

worldwide were awarded restricted share rights 

accounts. An example is our online mortgage 

equivalent to 50 shares of Wells Fargo stock to 

application (page 34). Usage of our online 

eligible full-time employees, and the equivalent 

mortgage application saw a steady increase 

of 30 shares to eligible part-time employees, with 

throughout 2018, with online applications 

a two-year vesting period. This ties their success 

representing 30 percent of our total retail 

to what’s important to our shareholders. As I 

applications in December. 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
  
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
“ I am confident that our 

strong innovation program 
will allow us to continue 
to provide lasting value 
to customers.” 

Since we centralized our innovation work in 2016, 

we have increased the pace of innovation and 

new product development. I am confident that 

our strong innovation program will allow us to 

continue to provide lasting value to customers and 

maintain and strengthen our market leadership. 

R I S K   M A N A G E M E N T  

Second, we are enhancing our payments 

Risk management continues to be a priority 

capabilities so customers can easily make 

for the company, and, to that end, in 2018 we 

payments as well as gain more visibility 

continued to invest in technology, infrastructure, 

into and control over their accounts. For 

cybersecurity, and people. We have adopted and 

instance, Zelle5 allows customers to make 

are implementing our enhanced risk management 

real-time payments to friends and family, 

framework. We have added a number of new 

and later this year we plan to complete the 

leaders to the risk management team, through both 

rollout of Pay With Wells Fargo SM, which 

internal and external hires, including more than 

displays customers’ most commonly used 

3,200 risk management team members hired from 

payment features on our mobile app home 

outside the company over the past three years. We 

screen, making it quick and easy to send a 

now have more clarity of roles and responsibilities 

payment, pay a bill, or make a transfer. 

across the entire company, providing breadth to 

our risk management discipline. 

16 

Third, we are building personalized experiences 

for every customer. For example, Greenhouse®, 

We have historically been strong in many areas 

our mobile banking app with cash management 

of risk management, including credit risk, 

expertise for new-to-banking customers, 

market risk, and liquidity risk. We know we 

offers personalized guidance to help customers 

have work to do in compliance and operational 

save for monthly expenses and manage their 

risk, and under Chief Compliance Officer Mike 

money responsibly, and we expect its rollout 

Roemer’s leadership, most of the Compliance 

in 2019. 

team is now part of one organization and, after 

centralization, numbers nearly 4,000 team 

Fourth, we are building capabilities to allow 

members. Mike is focused on transforming 

us to seamlessly serve customers through 

our compliance function into a competitive 

multiple channels. We are bringing digital 

advantage for the company and integrating 

experiences to our branches to speed 

and implementing best practices across the 

authentication and account opening, and 

company. Our Operational Risk team, under 

we offer banking and payment services on 

the leadership of Chief Operational Risk Officer 

non-Wells Fargo platforms. 

Mark Weintraub, oversees the management of 

operational risk exposures and the effectiveness 

Finally, we are building capabilities and 

of our operational risk management practices. 

technologies that enable innovation, such as 

This includes educating and empowering team 

artificial intelligence, identity management, 

members to identify and assess risks and help 

distributed ledger, and application 

ensure we have the right controls in place to 

programming interfaces. 

mitigate those risks. 

 
 
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
   
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
  
 
 
 
  
 
 
 
 
Through our enhanced risk management 

This problem-solving mindset was showcased in 

framework, we have a greater ability to understand 

our October announcement of the Where We Live5 

and manage our risks in a comprehensive and 

program in Washington, D.C., which combines the 

holistic manner. As a result, we can better drive 

power of philanthropy and our market-leading 

and support effective decisions about risk 

lending businesses with our deep community 

management at all levels of the company. 

partnerships. We made a five-year commitment 

We continue to work very hard and through 

of $1.6 billion to help revitalize disadvantaged 

multiple avenues to strengthen risk management. 

neighborhoods in the district. Through our 

We aren’t finished and continue to make progress, 

collaboration with the National Community 

building on the changes we have made. 

Reinvestment Coalition and nearly 20 other local 

Hand in hand with the enhancements we have 

affordable housing, small business growth, and 

made to our risk management framework is 

job skills for underserved residents in Ward 7 and 

our continued emphasis on our “raise your 

Ward 8 through corporate philanthropy and our 

hand” culture, in which every team member is 

mortgage and small business lending businesses. 

community organizations, we plan to increase 

encouraged to speak up if they need help or see 

something that doesn’t look right. We’ve coupled 

We continue to make progress in our efforts to 

that effort with enhanced escalation channels and 

address the negative consequences of climate 

processes to help ensure that any questions raised 

change and other environmental challenges 

by team members are investigated thoroughly 

affecting our planet. In addition to reducing our 

and confidentially. Every team member has 

company’s environmental footprint, in April 

personal accountability for managing risk. 

2018 we announced our commitment to provide  

$200 billion in financing to sustainable businesses 

C O R P O R AT E   C I T I Z E N S H I P  

and projects by 2030, with more than 50 percent 

I believe our commitment to corporate citizenship 

focused on clean technology and renewable energy 

sets us apart. Our goal is clear: We want to help 

transactions to help accelerate the transition 

people and communities succeed financially in 

to a low-carbon economy. This commitment 

all of the places where we live and do business. 

demonstrates how our products and services, 

We take a comprehensive approach to increasing  

operations and culture, and philanthropy can be 

access to economic opportunities and strengthening 

harnessed toward a single goal. As an example, 

local neighborhoods, working with a range of 

Wells Fargo committed capital in construction 

public and private sector stakeholders to understand 

debt, as well as the tax-equity funding of $35 million, 

the most urgent problems and the solutions that 

for Origis Energy’s new solar generation facility in 

can have the most impact. 

“Our goal is clear: We want to 
help people and communities 
succeed financially in all of 
the places where we live 
and do business.” 

Orange County, Florida. This facility will include 

more than half a million solar panels, producing 

and transmitting enough renewable electricity to 

reduce greenhouse gas emissions by more than 

57,000 tons per year. 

One of my personal highlights this year was 

announcing and then surpassing our $400 million 

philanthropy target for 2018. Wells Fargo donated 

$444 million in 2018 to nearly 11,000 nonprofits 

17 

 
 
 
 
  
 
 
 
 
 
 
 
  
 
 
 
  
  
  
  
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
   
18 

to help communities and people in need. It is 

Wells Fargo has a solid base from which to 

exciting to think of the positive change we can 

achieve this goal, including strong levels of 

make in our communities and in people’s lives 

capital and liquidity. And historically, we have 

through the Wells Fargo Foundation, which is 

generated steady financial performance over 

investing an average of more than $1 million 

time and through different economic cycles. 

a day toward important causes and into the 

We also remained disciplined regarding credit. 

communities we serve. Beginning in 2019, 

Our net charge-off ratio in 2018 was near 

we are targeting 2 percent of our after-tax 

historic lows, and our nonperforming assets 

profits for corporate philanthropy. We were 

declined 16 percent from a year ago. 

recognized in 2018 as the No. 2 most generous 

cash donor in the U.S., and the top financial 

We returned $25.8 billion to our shareholders 

institution in overall giving, by The Chronicle 

through common stock dividends and net share 

of Philanthropy (based on 2017 data). 

repurchases in 2018, up 78 percent from 2017. 

We reduced our common shares outstanding by 

We all have causes that are especially near and 

6 percent in 2018, the sixth year in a row we have 

dear to our hearts, and the WE Care Fund is close 

reduced our common share count. In July 2018, we 

to mine. The WE Care Fund, now in its 17th year, 

increased our quarterly common stock dividend 

provides financial grants to help team members 

to 43 cents per share, and in January 2019, we 

recover from natural disasters, accidents, and 

increased our quarterly common stock dividend 

other life-changing events. Team member 

to 45 cents per share. 

donations to the WE Care Fund are augmented 

by funding from the Wells Fargo Foundation. 

Our efficiency initiatives contribute to our ability 

One team member found support and assistance 

to provide long-term shareholder value. They are 

when her husband was diagnosed with an 

focused on three areas: further centralization 

aggressive form of amyotrophic lateral sclerosis, 

and optimization to create a simpler and 

or ALS. With the help of a WE Care Fund grant, 

more collaborative Wells Fargo, realigning 

they were able to build a wheelchair ramp at 

our businesses to more efficiently serve 

their home, giving them one less expense 

customers, and enhancing our governance and 

to worry about. The WE Care Fund is just one 

enforcement of controls and policies to drive 

of many ways our team members contribute 

down costs. We met our expense target in 

their financial resources and volunteer hours to 

2018, and we remain committed to meeting 

make our communities and our teams better. 

our expense targets for 2019 and 2020. 

I am deeply moved by the care that our team 

members demonstrate for each other every day. 

As planned, we completed 300 branch 

S H A R E H O L D E R   VA L U E  

consolidations in 2018 and sold 52 branches 

in the fourth quarter. Following these changes, 

Our first five company goals all contribute to our 

our physical distribution remains unparalleled 

final goal, which is to deliver long-term shareholder 

in the industry; we have branches in more 

value through our diversified business model, a 

states and in twice the number of markets as 

solid risk discipline, efficient execution, a strong 

our peers. We believe we have an opportunity 

balance sheet, and a world-class team dedicated to 

to further reduce redundancies without 

meeting the financial needs of our customers. 

meaningfully affecting our distribution, while 

having room to grow in many of our businesses. 

 
 
 
 
 
 
 
 
 
  
 
 
  
  
 
 
 
 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
  
 
  
 
  
  
 
 
 
 
O U R   P E R F O R M A N C E

$ in millions, except per share amounts	 

20 18 

20 17 

%  CH ANGE  

FOR THE YEAR 

Wells Fargo net income 

Wells Fargo net income applicable to common stock 

Diluted earnings per common share 

Profitability ratios: 

Wells Fargo net income to average assets (ROA) 

Wells Fargo net income applicable to common stock to average 

Wells Fargo common stockholders’ equity (ROE) 
Return on average tangible common equity (ROTCE)1 

Efficiency ratio2 

Total revenue 
Pre-tax pre-provision profit3 

Dividends declared per common share 

Average common shares outstanding 

Diluted average common shares outstanding 

Average loans 

Average assets 

Average total deposits 
Average consumer and small business banking deposits4 

Net interest margin 

AT YEAR-END 

Debt securities5 

Loans 

Allowance for loan losses 

Goodwill 
Equity securities5 

Assets 

Deposits 

Common stockholders’ equity 

Wells Fargo stockholders’ equity 

Total equity 
Tangible common equity1 

Capital ratios6: 

Total equity to assets 
Risk-based capital7: 

Common Equity Tier 1
 

Tier 1 capital
 

Total capital
 

Tier 1 leverage 

Common shares outstanding 
Book value per common share8 
Tangible book value per common share1, 8 

Team members (active, full-time equivalent) 

$	 

$	 

$ 

$ 

$ 

22,393 
20,689 
4.28 

22,183 
20,554 
4.10 

1.19 % 

1.15 

11.53 
13.73 
65.0 

86,408 
30,282 

1.640 
4,799.7 
4,838.4 

11.35 
13.55 
66.2 

88,389 
29,905 

1.540 
4,964.6 
5,017.3 

945,197 
1,888,892 
1,275,857 
747,183 

956,129 
1,933,005 
1,304,622 
758,271 

2.91 % 

2.87 

484,689 
953,110 
9,775 
26,418 
55,148 
1,895,883 
1,286,170 
174,359 
196,166 
197,066 
145,980 

473,366 
956,770 
11,004 
26,587 
62,497 
1,951,757 
1,335,991 
183,134 
206,936 
208,079 
153,730 

10.39 % 

10.66 

11.74 
13.46 
16.60 
9.07 
4,581.3 
38.06 
31.86 
258,700 

12.28 
14.14 
17.46 
9.35 
4,891.6 
37.44 
31.43 
262,700 

1
 
1
 
4
 

3 

2
 
1
 
(2) 

(2)
 
1
 

6 
(3) 
(4) 

(1) 
(2) 
(2) 
(1) 

1 

2 
-
(11) 
(1) 
(12) 
(3) 
(4) 
(5) 
(5) 
(5) 
(5) 

(3) 

(4) 
(5) 
(5) 
(3) 
(6)
 
2
 
1 
(2) 

1	  Tangible common equity is a non-GAAP financial measure and represents total equity less preferred equity, noncontrolling interests, and goodwill and certain identifiable intangible assets (including goodwill and 

intangible assets associated with certain of our nonmarketable equity securities, but excluding mortgage servicing rights), net of applicable deferred taxes. The methodology of determining tangible common equity 
may differ among companies. Management believes that return on average tangible common equity and tangible book value per common share, which utilize tangible common equity, are useful financial measures 
because they enable investors and others to assess the Company’s use of equity. For additional information, including a corresponding reconciliation to GAAP financial measures, see the “Financial Review – Capital 
Management – Tangible Common Equity” section in this Report. 

2  The efficiency ratio is noninterest expense divided by total revenue (net interest income and noninterest income). 

3	  Pre-tax pre-provision profit (PTPP) is total revenue less noninterest expense. Management believes that PTPP is a useful financial measure because it enables investors and others to assess the Company’s ability to 

generate capital to cover credit losses through a credit cycle. 

4  Consumer and small business banking deposits are total deposits excluding mortgage escrow and wholesale deposits. 

5	  Financial information for 2017 has been revised to reflect the impact of our adoption in first quarter 2018 of Accounting Standards Update (ASU) 2016-01 – Financial Instruments – Overall (Subtopic 825-10): 

Recognition and Measurement of Financial Assets and Financial Liabilities, which amends the presentation and accounting for certain financial instruments, including equity securities. See Note 1 (Summary 
of Significant Accounting Policies) to Financial Statements in this Report for more information. 

6  See the "Financial Review – Capital Management" section and Note 28 (Regulatory and Agency Capital Requirements) to Financial Statements in this Report for additional information. 

7  The risk-based capital ratios were calculated under the lower of Standardized or Advanced Approach determined pursuant to Basel III. Beginning January 1, 2018, the requirements for calculating common equity 
tier 1 and tier 1 capital, along with risk-weighted assets, became fully phased-in; however, the requirements for calculating tier 2 and total capital are still in accordance with Transition Requirements. See the 
“Financial Review – Capital Management” section and Note 28 (Regulatory and Agency Capital Requirements) to Financial Statements in this Report for additional information.  

8  Book value per common share is common stockholders' equity divided by common shares outstanding. Tangible book value per common share is tangible common equity divided by common shares outstanding. 

19 

 
 
 
  
 
 
 
 
 
 
 
As an example, we streamlined the retail 

I am also thankful for our customers, who are at 

mortgage sales operation, eliminating layers 

the center of everything we do. And I am especially 

and reengineering the mortgage fulfillment 

grateful for our 259,000 talented team members, 

process. We will continue to look for ways to 

who work hard every day to ensure we realize our  

improve efficiency as we focus on creating 

vision of satisfying our customers’ financial needs. 

long-term shareholder value. 

I am honored to lead them. 

I N   C L O S I N G  

The future always brings both opportunities 

I am confident that Wells Fargo is well-positioned 

and challenges, and I feel optimistic about what 

for the future. In 2019, we will continue working 

lies ahead for Wells Fargo. I thank you, our 

to build the most customer-focused, efficient, and 

shareholders, for your support of Wells Fargo 

innovative Wells Fargo ever — characterized by 

during 2018 and as we travel our road ahead. 

a strong financial foundation, a leading presence 

in the markets we serve, focused growth within a 

strong risk management framework, operational 

excellence, and highly engaged team members. 

As we look ahead, we won’t lose sight of our roots 

and our company’s history. We are building on 

an exceptionally strong foundation to transform 

Wells Fargo into a better bank for the future. 

T I M O T H Y   J .   S L O A N  

Chief Executive Officer and President 
Wells Fargo & Company 
February 15, 2019 

20 

Coupled with the strong optimism I feel for the 

future of our company is a deep sense of gratitude. 

I am thankful for the leadership, guidance, and 

support of Betsy Duke, our board chair, and our 

other highly qualified, hard-working, and dedicated 

board members. I would like to especially 

recognize Karen Peetz, who is retiring from the 

board this year, for her contributions, and welcome 

Wayne Hewett, who joined the board this year 

and brings deep experience in business operations 

and processes. 

   
  
 
  
 
 
  
 
 
 
 
 
 
 
 
  
 
  
 
 
  
 
 
 
 
 
 
 
As Wells Fargo makes 
progress on the road 
ahead, CEO Tim Sloan 
has established six 
goals to guide us. 

The stories that follow illustrate just a few 
of the many ways we are working to become 
the financial services leader in: 

21 

Customer service and advice 

Team member engagement 

Innovation 

Risk management 

Corporate citizenship 

Shareholder value 

Le a r n   m o re   a b o u t   eve r yo n e   fe a t u re d   i n   t h i s   ye a r ’s   A n n u a l   Re p o r t   a t  w e l l s fa rg o.c o m /s to r i e s  

   
   
 
 
 
 
   
Strengthening financial health through 

focused conversation 

WHEN DARLENE AHMED NEED ED GUIDANCE ON HER FI NANCIAL JOURNEY,
 

SHE FOUND IT IN WELLS FARGO’S FINAN CI AL HEALTH  CONV ERS ATI ON S  PRO GRAM.
  

Talking about money isn’t always easy, but it can be a tremendous help. 

Darlene Ahmed of Fruitland Park, Florida, found that out last year when a series of focused 

conversations helped her transition from renting an apartment to owning her first home. 

It was the kind of talk that takes place daily in all parts of Wells Fargo — in person, over mobile 

devices, and on the phone. 

Ahmed, 57, a certified nursing assistant at an assisted-living facility, had rented for years while raising 

a child — financially secure but unsure if she was ready for homeownership. When she became an 

empty nester, she figured the time might be right. She called Wells Fargo Home Lending and soon 

learned she couldn’t be pre-approved for a mortgage. The culprit? A low credit score. 

22 

“I was shocked when I heard what my credit score was,” Ahmed said. She was put in touch with 

Financial Health Banker Dustin Griffin in Sioux Falls, South Dakota. Griffin started by asking 

questions, and soon the two had hit upon a hard fact: What Ahmed always thought was good — 

no credit cards, no loans, no lines of credit — actually meant a thin credit history and low credit score. 

So over a series of short conversations, Griffin recommended that Ahmed start slowly building her 

credit history — applying for a couple of credit cards, paying off all purchases on time, and never 

using more than 30 percent of the available balances. 

Months later, when she tried for pre-approval again, “I got approved and a week later found
 

my house on my birthday,” said Ahmed. “Dustin was right there for me every step of the way,
 

giving me peace of mind, confidence, and guidance.”
 

Griffin said, “Once she figured out what she wanted, there was no stopping her! I just helped lay
 

out a clear path for her to get there.”
 

Since 2015, Griffin and his Wells Fargo teammates have helped nearly 50,000 customers learn to 

save more and strengthen their credit through Financial Health Conversations, a program for 

customers who request additional help to save more, improve credit, or save for a home. Wells Fargo 

operates the program from contact centers in Sioux Falls; Charlotte, North Carolina; Richmond, 

Virginia; and Phoenix — as well as El Monte, California, and San Antonio, which also serve 

Spanish-speaking customers. The team conducts more than 400 conversations weekly. 

Griffin concluded, “It’s important to me not just to give out information but to form a real bond  


and connection with customers like Darlene. I couldn’t be happier for her.”
 

Righ t:  Da rlene Ahmed at her home in Fru itl and Park , Fl orida. 

   
                         
   
 
  
 
 
 
 
 
 
 
  
 
 
  
 
  
  
  
 
  
 
 
 
 
 
23
 

      A plan to provide 

working capital 

24 

B USINESS OWNER RAY HUFNAGEL  G OT FIN AN CI AL PLAN N ING HELP — AND THE 

FINANCING HE NEEDED TO G ROW — FROM  HI S WELLS FA RG O BA NKER. 

Now that a decade has passed, businessman 

So Hufnagel connected with Wells Fargo 

Ray Hufnagel can see that the low point for 

Commercial Banker Jay Hong of Pasadena, 

his company also was a catalyst for its success 

California, who recognized an opportunity 

today. But it didn’t feel like it at the time. 

for growth in the then-regional company that 

Plastic Express, a logistics services company 

resin — the BB-sized core ingredient for all 

specialized in loading and shipping plastic 

based in City of Industry, California, was like 

plastic products. 

many businesses that struggled at the beginning 

of the Great Recession. Despite a 30-year track 

Together, Hufnagel and Hong devised a plan 

record, it didn’t turn a profit in 2008, and the 

to meet Plastic Express’ short-term needs 

company was rebuffed when it turned to its bank 

while also looking strategically at the years 

for advice. “Everything was great with our old 

ahead. Hong said, “To meet the demand for 

bank until our checking account went to zero,” 

the unique service Plastic Express provides, 

said Hufnagel, president and CEO. “They really 

and to be prepared to earn new business, 

weren’t interested in looking at our financials or 

they needed access to capital — often ahead 

helping us plan. I just didn’t feel supported.” 

of revenue coming in. So Wells Fargo did the 

research and worked with their team.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
  
  
 
  
  
  
 
 
  
 
       
25 

“Now we provide the working capital the 

to deliver for our customers — as well as 

company needs to finance things like new 

quadrupling gross revenue — since we started 

and replacement equipment — like tractors, 

our relationship with Wells Fargo,” Hufnagel said. 

trailers, and packaging lines — which are key 

drivers for the company’s continued growth.” 

A bonus, according to Hufnagel, who was a Navy 

pilot with 15 years of active duty service: “I love 

A decade later, Plastic Express has executed 

the fact that Wells Fargo hires veterans.” 

on its strategic plan of expanding geographically. 

The company now covers the U.S. coast to coast, 

Hong, an Army combat veteran, concluded, 

with 16 warehouses, 19 trucking terminals, 

“The military taught me the value of teamwork, 

42 bulk rail terminals, and 9,000 railcar spots. 

risk assessment, and planning — all of which 

It also now employs 375 people. “We’ve grown 

have benefited my work as Plastic Express’ 

both our national footprint and our ability 

relationship manager at Wells Fargo.” 

Above:  Ray  Hufn agel, right, with Wells Fargo’s Jay H on g in  City  of  Industry, California. 

  
  
  
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
26 

The voice of a  veteran
 

C H A N T Y   C L AY   S U C C E S S F U L LY   N AV I G AT E D   T H E   T R A N S I T I O N   F R O M 
  

M I L I TA R Y   S E R V I C E   T O   W E L L S   F A R G O ,   A N D   N O W   S H E   U S E S   T H AT 
  

E X P E R I E N C E   A N D   H E R   P H . D .   T O   G U I D E   O T H E R S . 
  

If experience is a great teacher, then Chanty Clay of St. Louis is a master. 

She served 10 years in the U.S. Air Force, where she worked in inventory management, training, and
 

human relations, and earned a college degree. After honorable discharge, she applied the leadership
 

skills she had learned to Wells Fargo and then earned a Ph.D. Today she leads a team of Human
 

Resources consultants at Wells Fargo and mentors eight veterans — both inside and outside
 

the company — who are making the transition to life after the military.
 

“What the Air Force prepared me for was to use my competencies, regardless of the industry,” Clay 

said. “In the military, you contribute to the team in so many different ways. For any veteran making 

the transition to civilian life, the most important thing to realize is that you have specific skills from 

27 

your military job and also interpersonal and leadership skills that are applicable to other areas.” 

For example, in Air Force inventory management, one of Clay’s early roles involved answering 

questions from service members about their supplies and reports. “I saw the value of true customer 

service — building trust, maintaining relationships, and delivering outstanding service. Those are 

values I’ve continued to hold onto throughout my career,” she said. 

Clay made the decision to enlist in the military while she was a 20-year-old college student trying to 

figure out what to do with the rest of her life. In considering her options, Clay said, “I appreciated the 

structure of the military, and I appreciated the camaraderie, but most important, I appreciated the 

opportunity to have diverse experiences and learn new things.” 

Making connections is part of what drives Clay’s work in supporting veterans today. She helped 

create the local St. Louis chapter of the internal Veterans’ Team Member Network at Wells Fargo. 

Clay said she is proud “to provide a safe space where veterans can share with me what they’re 

experiencing. Together, we can confront challenges and celebrate successes.” 

Jerry Quinn, Military Affairs Program manager for Wells Fargo, said, “Chanty’s personal story 

of transition, utilizing her skills and abilities, is an experience many veterans have. And her 

dedication is further testimony of the value veterans bring to Wells Fargo and our communities.” 

Lef t:  Wells  Fa rgo’s Chanty Clay with Alexander Propst, a veteran sh e mentors, in St. Louis. 

 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
Teaming up to promote economic
 
empowerment
 

W I T H   B AC K I N G   F R O M   W E L L S   FA R G O,   Y VO N N E   G R E E N   S T R I V E S   TO   E M P OW E R 
  

T H O S E   W H O   L I V E   A N D   W O R K   O U T S I D E   T H E   T R A D I T I O N A L   F I N A N C I A L   S Y S T E M . 
  

“Financial success” has many definitions. 

Connecticut, Ohio, Florida, and Texas —
 

For Yvonne Green, it starts with saving money 

to five additional markets.
 

rather than living paycheck to paycheck and 

depending on pawnshops and payday lenders. 

The program aims to address the needs of 

those who are unbanked (people who do 

Green considers herself lucky to have parents  

not have a checking or savings account) and 

who, despite limited resources, insisted she 

underbanked (people who have a checking or 

open a checking account when she got her first 

savings account but also use services outside 

job at 16. Now, as a fellow with the independent 

of traditional financial institutions). The 

initiative Bank On Houston, she works as 

Federal Deposit Insurance Corporation 

a financial health advocate for those in her 

estimates that 63 million U.S. adults meet 

hometown who live outside the traditional 

these definitions because they don’t have 

28 

financial system. 

enough money to meet a minimum balance 

requirement, distrust financial institutions, 

“I’m reminded daily of what it means to save as 

or have identification or credit problems — 

much of your money as you can, while at the 

making them susceptible to expensive, 

same time avoiding taking on debt that you 

alternative financial services. 

cannot manage,” said Green. “That legacy lives  

on through my work at Bank On Houston, and  

“The Bank On program is all about 

for that I am truly grateful.” 

communicating the benefits of accounts 

and saving,” said Lisa Price of Wells Fargo 

Bank On works with coalitions around the 

Community Relations in Phoenix. “It 

U.S. to build financial capacity in communities. 

doesn’t promote one financial institution 

In 2017, Wells Fargo invested $1 million to 

over another.” 

launch the Bank On Fellows program with 

the Cities for Financial Empowerment Fund, 

Fellows like Green work with consumers, 

which aims to improve the financial stability 

community organizations, local governments, 

of low  and moderate-income households. 

-

and various financial institutions to connect 

The CFE Fund and Wells Fargo share a 

those in need with safe financial products. 

commitment to economic empowerment 

and strengthening financial self-sufficiency 

“I believe that sharing my story can help 

in underserved communities. In 2018, 

communities understand the importance 

Wells Fargo announced an additional $1 million 

of financial empowerment,” Green said. 

grant to expand the Bank On Fellowship — 

“By using safe and affordable products, families 

which currently operates in Alabama, 

can begin to build better financial practices, 

accumulate wealth, and leave a lasting legacy.” 

Rig ht:  Yvonne Green, lef t, with Wells Fargo s Lis a Pric e in H ous ton. 

’

  
 
  
 
 
 
 
 
 
  
  
 
  
 
  
  
 
  
  
  
 
  
  
  
 
 
 
  
  
   
  
 
 
  
 
  
   
  
  
  
  
 
  
 
  
  
 
   
 
29 

30 

Engineering a  better tomorrow
 

SCHOLARSHIP SUPPORT FROM WELLS FARGO HELPED  BI OENGINEER LILY SOOKLAL
 

EARN HER COLLEGE DEGREE, AND NOW SHE IS PAYING IT FORWARD.
 

Lily Sooklal, 24, was never really sure what she wanted to be when she grew up. Then a relative’s 

medical diagnosis brought things into focus, and today she is a bioengineer designing and 

developing medical devices that aim to diagnose disease. 

“I was inspired to study bioengineering by my aunt’s multiple sclerosis,” said Sooklal, an 

Indo-Trinidadian American whose parents emigrated from Trinidad to the U.S. “The chance 

I had to work in a lab researching that same disease during my first year of college was amazing, 

and I discovered I wanted to do work that gives back to patients like my aunt in other countries.” 

She added, “In my family, education has a lot of value, and the desire to earn a college degree is 

something my parents instilled in me early on.” Her family has a long history of farming in Trinidad, 

and her father was not able to go to high school. Sooklal’s family lived below the poverty line, and 

she became aware that she would need to pay her own way through school. 

Sooklal found help from APIA Scholars, which promotes the success of Asian and Pacific Islander 

American students through scholarships, college planning, leadership training, and financial education, 

and provides professional development tools and resources. Wells Fargo has worked with APIA 

Scholars since 2006, providing more than $7.6 million to fund more than 1,700 college scholarships. 

Many of the 252 APIA/Wells Fargo scholars pursuing their education in the 2018–19 academic year 

have similar backgrounds as Sooklal: Eighty-five percent are first-generation college students, and  

67 percent were living at or below the poverty line. 

Jimmie Paschall, head of Enterprise Diversity & Inclusion at Wells Fargo, said, “We aim to make a 

positive contribution to communities through philanthropy, advancing diversity and inclusion, and 

creating economic opportunity. Through APIA Scholars, Wells Fargo is supporting both diversity 

and higher education in a direct and meaningful way: by providing talented, underserved APIA 

students the financial means to achieve their dreams.” 

Sooklal’s scholarship helped her with college tuition and housing costs. She also benefited from an 

APIA initiative that provides tips, advice, and information to help college students be successful in their 

first year. Now she works to pay it forward: At her company, she serves as co-president of a women’s 

network and supports an internal Asian resource group. Sooklal also runs networking and resume 

workshops every year at the University of Maryland. 

She concluded, “I believe it’s important to support — both at the high school and college levels — 

women in technical fields, and organizations like APIA Scholars are part of that. APIA Scholars 

has given people in the Asian community hope and light. It means a lot.” 

Rig ht:  Lily Sooklal at the University of Maryland, Co lleg e Park . 

 
 
 
  
  
 
 
 
 
 
 
 
 
  
  
 
 
 
  
  
  
31
 

32 

Helping clients protect their
             f inancial resources 

W E L L S   FA R G O   A DV I S O R S   T E A M   M E M B E R S   W O R K   TO   H E L P   S E N I O R S  

BY   M A N AG I N G   R I S K   A N D   P U T T I N G   S A F E G UA R D S   I N   P L AC E .  

In reviewing the activity in a client’s brokerage account, a Wells Fargo Advisors financial advisor 

wondered: Why would an 80-year-old be taking out so much cash, and so often? 

The advisor alerted the Elder Client Initiatives team, which investigated and soon found the 

answer: One of her sons was making the withdrawals for himself. The team moved quickly and 

advised the client to add a different relative as a “trusted contact” on the client’s account — 

which stopped the abuse. 

This is one of many successes the team has logged since it was created in 2014, among the first of  


its kind in the brokerage industry. “Everything we do is designed to help clients manage risk and
 

avoid financial harm,” said Ron Long, head of Elder Client Initiatives at Wells Fargo Advisors.
 

Long’s team investigates more than 200 cases a month, typically referred by financial advisors who 

spot red flags that indicate their customers may be at risk of abuse. The team also conducts research 

on related issues and works with protective services and senior advocacy groups across the U.S. 

“We know that families are not always having the conversations they should be having about 

protecting savings and investments,” Long said. “That allows scammers to come onto the scene 

and take advantage.” 

The Elder Client Initiatives team also worked with lawmakers in Alabama on legislation to help 

protect seniors from financial crimes. Joe Borg, director of the Alabama Securities Commission, 

worked with Long to come up with proposed provisions, such as requiring the reporting of certain 

transactions and authorizing financial advisors to speak with the clients’ trusted contacts about 

suspected problems. 

“If a hospital has to report when someone falls out of bed, why shouldn’t we as an industry have 

to report attempts to wipe out someone’s bank or retirement account?” said Borg. “The Alabama 

legislature shared our concerns, and the law passed.” 

Every year, Wells Fargo trains team members who interact with customers on how to prevent, 

identify, and report suspected elder financial abuse. 

Long concluded, “Putting safeguards in place — and engaging in transparent, open dialogue —
 

is critical if we want to protect the dollars older Americans have worked so hard to accumulate.  


We are proud to be part of that.”
 

Investment and insurance products: NOT FDIC-Insured/NO Bank Guarantee/MAY Lose Value
 

Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC, Member SIPC, a registered broker-dealer and 
non-bank affiliate of Wells Fargo & Company. CAR–0119–00596 

Lef t:  Wells  Fa rgo  Advisors’ Ron Long, right, with Joe Bo rg in Montgomery, Alabama. 

33 

 
 
 
 
  
  
 
 
  
 
 
 
 
 
 
 
  
  
   
 
 
Reaching homebuyers in

 their digital domain 

34 

WELLS FARGO  S NEW ONLINE MORTG AG E AP PL ICATION GI VES  CUSTOMERS 

’

LIKE ERIK GRUBER THE SPEED AN D  CONVEN IEN CE  THEY’VE COME TO EXPECT. 

Erik Gruber spends most of his life on the 

in December 2018, 30 percent of all retail 

internet, whether he’s creating videos for work 

mortgage applications were done through 

or ordering pizza for dinner. So when he started 

the online mortgage application. 

to consider becoming a homeowner, it was only 
natural to research the subject online, fi  nd houses  Michael DeVito, head of Wells Fargo 
Home Lending, said, “We see a broad 

online — and get pre-approved for a mortgage 

using an online application from Wells Fargo. 

range of customers readily embracing 

the online mortgage application. We are 

“Whenever I have the option, online 

attracting customers of all ages as they 

usually works best for me,” said Gruber, 

increasingly use their smartphones and 

29, a Wells Fargo customer in suburban 

mobile devices for daily activities. Digital 

Philadelphia. “It’s just more convenient.” 

tools like the online mortgage application 

He is far from alone. Wells Fargo has attracted 

convenience for customers.” 

hundreds of thousands of customers to the 

online mortgage application since the tool 

It is especially convenient for tech-savvy 

launched in first quarter 2018. In fact, 

millennial professionals who, like Gruber, 

help Wells Fargo deliver simplicity and 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
35 

are part of the gig economy — self-employed 

After submitting his application online, 

contractors who work for multiple employers, 

Gruber received a decision from the company 

have many income sources, and who have 

in a matter of hours. Then, once he found 

lots of paperwork to manage. 

a house, he sent documents to Wells Fargo 

through yourLoanTracker SM, an online tool 

“Millennials want their information fast,” 

that allows direct uploading. He closed on his 

said Derek Tesinsky, a Wells Fargo home 

new home in spring 2018. 

mortgage consultant in Des Moines, Iowa, 

who worked with Gruber on his loan. 

He concluded, “I do all my other banking with 

“They want an interface that tells them 

Wells Fargo, so it made sense to use Wells Fargo 

what they need and what needs to be done. 

for my mortgage. And the online mortgage 

They don’t want to spend their time talking 

application worked great! It all boiled down 

on the phone to submit an application.” 

to convenience.” 

Above:  Erik  Gr uber at work near P hiladelphia. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Propel® Card strategy:  Listen, 

learn, design, deploy 

B Y   C O N S U LT I N G   C U S T O M E R S   AT   E V E R Y   T U R N ,   T H I S  T E A M 
  

D E V E L O P E D   A N   O F F E R I N G   W I T H   A   S T R O N G   VA L U E   P R O P O S I T I O N 
  

F O R   C U S T O M E R S   A N D   W E L L S   FA R G O . 
  

When Wells Fargo’s new Propel® Card received 

by the Go Far® Rewards program, the Propel 

a top industry rating in late 2018, a digital 

Card also gives customers a range of options 

celebration broke out among the hundreds of 

for redeeming their rewards points, including 

team members across the U.S. who had worked 

for cash at Wells Fargo ATMs, online 

hard to help make sure it provides just what 

purchases, gift cards for charitable donations, 

it was intended to — and also fits with the 

gifts to friends, and sharing them with other 

company’s strategy to develop services and 

cardholders they know. 

products for a range of different customers. 

Creating products like the Propel Card to serve 

“Based on what active-lifestyle consumers 

existing customers and attract new ones — 

36 

-
told us, we developed a simple, easy  to 

-

while maintaining its risk discipline — is one of 

understand card that rewards them for the 

the key ways Wells Fargo creates value for its 

things they are already doing every day,” said 

shareholders. Anderson and the Propel Card 

Beverly Anderson, head of Wells Fargo Cards 

team undertook market research, conducted 

and Retail Services. “Things like dining out 

focus group studies, and interviewed 

with friends, commuting to work, planning 

customers for more than a year as they tested 

a summer vacation, or downloading a favorite 

and developed the concept, model, and 

TV series to binge-watch. 

implementation strategy. Anderson said the 

team combined the scientific method with 

-
“We also wanted to deliver a compelling, digital 

common sense and intuitive insights into 

first experience that lets people apply for the 

people and their spending behavior. 

card wherever they happened to be shopping 

digitally. In an article published on Nov. 12, 2018, 

Heather Philp, head of the Propel Card team, 

Business Insider named the Propel Card ‘the 

said her team’s biggest challenge — and highest 

best no-fee card to open in 2018,’ and that 

priority — was to identify the best value 

recognition underscored our achievement.” 

proposition for customers. “They wanted a 

The enhanced rewards card — Wells Fargo’s 

than having to make their lives work around 

latest card with partner American Express — 

the card,” she said. “We believe the Propel 

was introduced in summer 2018. Supported 

Card does just that.” 

card that would work for their lives, rather 

Rig ht:  Wells Fargo s Beverly Anderson with her team in W ilmington, Delaware. 

’

 
 
 
 
 
 
 
  
 
 
 
  
  
 
 
 
 
 
 
 
  
  
  
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
  
   
   
  
 
 
 
37 

OPE RAT ING COM MI TTEE AND  
OT H E R   C O R P O R AT E   O F F I C E R S  

38 

Wells Fargo Operating Committee† (left to right): 
Mary T. Mack, Jonathan G. Weiss, Avid Modjtabai, David C. Galloreese, Timothy J. Sloan, John R. Shrewsberry,
 
Amanda G. Norton, C. Allen Parker, and Perry G. Pelos
 

†On January 9, 2019, Wells Fargo announced that Saul Van Beurden will join the company in April as head of Technology 
and become a member of the Operating Committee. On February 6, 2019, Wells Fargo announced that Julie Scammahorn 
will join the company in April as chief auditor and become a member of the Operating Committee. 

T I M OT H Y   J .   S L O A N  
C EO   a n d   P re s i d e n t* 

R I C H A R D   D .   L E V Y  
Con tro ller* 

P E R R Y   G .   P E L O S  
Head  of W h olesale  Bank ing* 

A N T H O N Y   R .   A U G L I E R A  
Cor porate  Se cret ar y 

M A R Y   T.   M A C K  
H ea d o f Consumer  Bank ing* 

J A M E S   H .   R OW E  
Head  of  Stak eh older  Relati on s 

N E A L   A .   B L I N D E  
Tre as urer  

AV I D   M O D J TA B A I  
H ea d of  Payments, Vir tual  
S ol uti ons a nd  In nova tion* 

J O H N   R .   S H R E W S B E R R Y  
Ch ief Fi nanc ial  Offi c er* 

J O H N   M .   C A M P B E L L  
Head of Investor Rel ati ons  

D AV I D   M O S K OW I T Z  
H ea d of  Govern ment Relatio ns 
an d  P ubli c  Pol ic y 

J O N AT H A N   G .   W E I S S  
Head  of Wea lth  an d 
Investment  Management* 

J O N   R .   C A M P B E L L  
Head of Cor po rate   Ph il an thropy  
and Commun i ty Rel atio ns 

A M A N D A   G .   N O R T O N  
Chi ef  Ri sk  Offi c er* 

M A R Y   S .   W E N Z E L  
Head  of  Sustai nabili ty 
and  Corp orate  Resp on si bili ty 

D AV I D   C .   G A L L O R E E S E  
Head of Hu man  Re sourc e s* 

C .   A L L E N   PA R K E R  
Ge ner al  Co unsel* 

* “Executive officers” according to Securities and Exchange Commission rules.  

|  As of February 15, 2019 

   
   
    
  
  
 
 
  
   
 
   
 
   
 
   
   
 
BOA RD  OF DIR ECTORS
 

J O H N   D.   B A K E R   I I   1, 3 

K A R E N   B .   P E E T Z   6, 7  

Executive Chairman and CEO 
FRP Holdings, Inc. 
(Real estate) 

C E L E S T E   A .   C L A R K   2, 3, 5 

Principal, Abraham Clark Consulting, LLC, 
and Retired Senior Vice President, Global 
Public Policy and External Relations and 
Chief Sustainability Officer 
Kellogg Company 
(Food manufacturing) 

Retired President 
The Bank of New York 
Mellon Corporation 
(Banking and financial services) 

J U A N   A .   P U J A D A S   2, 3, 4, 7  

Retired Principal 
PricewaterhouseCoopers LLP, 
and Former Vice Chairman, 
Global Advisory Services 
PwC International 
(Professional services) 

T H E O D O R E   F.   C R AV E R ,   J R .   1, 4  

J A M E S   H .   Q U I G L E Y   1, 3, 7 

Retired Chairman, President and CEO 
Edison International 
(Energy) 

CEO Emeritus and Retired Partner 
Deloitte 
(Audit, tax, financial advisory) 

E L I Z A B E T H   A .   D U K E   3, 4, 5,  7 

R O N A L D   L .   S A R G E N T   1, 5, 6 

Retired Chairman and CEO 
Staples, Inc. 
(Office supply retailer) 

39 

T I M OT H Y   J .   S L O A N  

CEO and President 
Wells Fargo & Company 

S U Z A N N E   M .   VA U T R I N OT   2, 3, 7 

President
 
Kilovolt Consulting, Inc.
 
(Cyber and technology consulting) 
Major General and Commander 
United States Air Force (retired) 

Chair 
Wells Fargo & Company 
Former member of the Federal 
Reserve Board of Governors 
(U.S. regulatory agency) 

WAY N E   M .   H E W E T T   6, 7 

Senior Advisor 
Permira (Private equity), 
and Chairman 
DiversiTech Corporation 
(HVAC-R manufacturing) 

D O N A L D   M .   J A M E S   4, 5, 6 

Retired Chairman 
Vulcan Materials Company 
(Construction materials) 

M A R I A   R .   M O R R I S   6, 7 

Retired Executive Vice President 
and Head of Global Employee 
Benefits business 
MetLife, Inc. 
(Health and life insurance) 

Standing Committees 
1. Audit and Examination   2. Corporate Responsibilty   3. Credit   4. Finance  5. Governance and Nominating   6. Human Resources   7. Risk  

|  As of February 15, 2019 

   
   
   
   
   
   
   
   
 
  
  
  
 
 
 
  
 
 
 
 
 
 
  
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
 
 
 
O U R   C O M M U N I T Y   I M P A C T  
2 0 1 8   C o r p o r a t e   R e s p o n s i b i l i t y   H i g h l i g h t s  

Wells Fargo is committed to making a positive impact by helping people and communities 
succeed financially — and creating solutions for a stronger, more sustainable future in which 
everyone can grow and prosper. Read more at wellsfargo.com/about/corporate-responsibility. 
Here is a snapshot of our community impact in 2018. 

S T R E N G T H E N I N G  
C O M M U N I T I E S  

E M P O W E R I N G   D I V E R S E  
S M A L L   B U S I N E S S E S  

Contributed $444 million and volunteered 
2+ million hours, improving lives and 
supporting economic growth in the U.S. and 

around the world. 

Awarded $94.8 million in grants and capital 
to grow diverse small businesses since 2015, 

supporting economic equity and employment 
opportunities for 36,000 people. 

40 

A C C E L E R AT I N G   T O   A  
L O W - C A R B O N   E C O N O M Y  

E X P A N D I N G   A C C E S S  
T O   C L E A N   E N E R G Y  

Met 100% of our global electricity needs with 
renewable energy. Committed to providing 
$200 billion in financing to sustainable 
businesses and projects by 2030. 

Provided 2,000 low-income and tribal 
households with solar power to decrease 
energy bills, and trained 3,500 people 
for careers in clean energy. 

A D VA N C I N G  
A F F O R D A B L E   H O U S I N G  

I M P R O V I N G   F I N A N C I A L  
H E A LT H   A N D   C A P A B I L I T Y  

Financed 31,800 affordable rental units. Created 
3,900+ homeowners through NeighbhorhoodLIFT® 
program, offering homebuyer education, down 

Reached 1.7 million people to provide 
financial education through Wells Fargo’s Hands 

on Banking® program, including new content for 

payment assistance, and grants to revitalize 

veterans and people with disabilities. 

neighborhoods. 

Data for January 1 , 2018 – December 31 , 2018, unless otherwise noted. 

  
   
  
 
 
 
   
 
 
 
 
   
   
 
 
 
 
  
   
 
   
   
 
 
 
 
 
   
 
 
 
 
   
   
W E L L S   FA R G O   &   C O M P A N Y   2 0 1 8   F I N A N C I A L   R E P O R T 
  

Financial Review 

Overview 

Earnings Performance 

Balance Sheet Analysis 

Off-Balance Sheet Arrangements 

Risk Management 

Capital Management 

Regulatory Matters 

162 

170 

187 

188 

190 

5 

6 

7 

8 

9 

Available-for-Sale and Held-to-Maturity Debt Securities 

Loans and Allowance for Credit Losses 

Premises, Equipment, Lease Commitments and Other 

Assets 

Equity Securities 

Securitizations and Variable Interest Entities 

201 

10 

Mortgage Banking Activities 

203 

11 

Intangible Assets 

Critical Accounting Policies 

205 

12 

Deposits 

Current Accounting Developments 

206 

13 

Short-Term Borrowings 

Forward-Looking Statements 

207 

14 

Long-Term Debt 

Risk Factors 

209 

15 

Commitments 

Guarantees, Pledged Assets and Collateral, and Other 

214 

16 

Legal Actions 

Controls and Procedures 

219 

17 

Derivatives 

Disclosure Controls and Procedures 

229 

18 

Fair Values of Assets and Liabilities 

Internal Control Over Financial Reporting 

249 

19 

Preferred Stock 

Management’s Report on Internal Control over 

Financial Reporting 

Report of Independent Registered Public 

Accounting Firm 

252 

20 

Common Stock and Stock Plans 

256 

21 

Revenue from Contracts with Customers 

260 

22 

Employee Benefits and Other Expenses 

Financial Statements 

267 

23 

Income Taxes 

Consolidated Statement of Income 

Consolidated Statement of Comprehensive 

Income 

270 

24 

Earnings and Dividends Per Common Share 

271 

25 

Other Comprehensive Income 

Consolidated Balance Sheet 

273 

26 

Operating Segments 

Consolidated Statement of Changes in 

Equity 

275 

27 

Parent-Only Financial Statements 

Consolidated Statement of Cash Flows 

278 

28 

Regulatory and Agency Capital Requirements 

Notes to Financial Statements 

1 

2 

3 

4 

Summary of Significant Accounting Policies 

Business Combinations 

Cash, Loan and Dividend Restrictions 

Trading Activities 

279 

280 

282 

Report of Independent Registered 

Public Accounting Firm 

Quarterly Financial Data 

Glossary of Acronyms 

42 

48 

67 

69 

71 

102 

110 

113 

117 

119 

120 

137 

137 

137 

138 

139 

140 

141 

142 

146 

147 

159 

160 

161 

41

Wells Fargo & Company 

41 

This Annual Report, including the Financial Review and the Financial Statements and related Notes, contains forward-looking 
statements, which may include forecasts of our financial results and condition, expectations for our operations and business, and our 
assumptions for those forecasts and expectations. Do not unduly rely on forward-looking statements. Actual results may differ 
materially from our forward-looking statements due to several factors. Factors that could cause our actual results to differ materially 
from our forward-looking statements are described in this Report, including in the “Forward-Looking Statements” and “Risk Factors” 
sections, and in the “Regulation and Supervision” section of our Annual Report on Form 10-K for the year ended December 31, 2018 
(2018 Form 10-K). 

When we refer to “Wells Fargo,” “the Company,” “we,” “our,” or “us” in this Report, we mean Wells Fargo & Company and 
Subsidiaries (consolidated). When we refer to the “Parent,” we mean Wells Fargo & Company. See the Glossary of Acronyms for 
terms used throughout this Report. 

Financial Review1 

Overview 

Wells Fargo & Company is a diversified, community-based 
financial services company with $1.90 trillion in assets. Founded 
in 1852 and headquartered in San Francisco, we provide 
banking, investment and mortgage products and services, as well 
as consumer and commercial finance, through 7,800 locations, 
more than 13,000 ATMs, digital (online, mobile and social), and 
contact centers (phone, email and correspondence), and we have 
offices in 37 countries and territories to support customers who 
conduct business in the global economy. With approximately 
259,000 active, full-time equivalent team members, we serve 
one in three households in the United States and ranked No. 26 
on Fortune’s 2018 rankings of America’s largest corporations. 
We ranked fourth in assets and third in the market value of our 
common stock among all U.S. banks at December 31, 2018. 
We use our Vision, Values & Goals to guide us toward 
growth and success. Our vision is to satisfy our customers’ 
financial needs and help them succeed financially. We aspire to 
create deep and enduring relationships with our customers by 
providing them with an exceptional experience and by 
understanding their needs and delivering the most relevant 
products, services, advice, and guidance. 

We have five primary values, which are based on our vision 

and guide the actions we take. First, we place customers at the 
center of everything we do. We want to exceed customer 
expectations and build relationships that last a lifetime. Second, 
we value and support our people as a competitive advantage and 
strive to attract, develop, motivate, and retain the best team 
members. Third, we strive for the highest ethical standards of 
integrity, transparency, and principled performance. Fourth, we 
value and promote diversity and inclusion in all aspects of 
business and at all levels. Fifth, we look to each of our team 
members to be a leader in establishing, sharing, and 
communicating our vision for our customers, communities, team 
members, and shareholders. In addition to our five primary 
values, one of our key day-to-day priorities is to make risk 
management a competitive advantage by working hard to ensure 
that appropriate controls are in place to reduce risks to our 
customers, maintain and increase our competitive market 
position, and protect Wells Fargo’s long-term safety, soundness, 
and reputation. 
____________________________________________ 
Financial information for periods prior to 2018 has been revised to 
1 
reflect presentation changes made in connection with our adoption 
in first quarter 2018 of Accounting Standards Update (ASU) 
2016-01 Financial Instruments – Overall (Subtopic 825-10): 
Recognition and Measurement of Financial Assets and Financial 
Liabilities. See Note 1 (Summary of Significant Accounting Policies) 
to Financial Statements in this Report for more information. 

In keeping with our primary values and risk management 
priorities, we have six long-term goals for the Company, which 
entail becoming the financial services leader in the following 
areas: 
•	  Customer service and advice – provide exceptional service 
and guidance to our customers to help them succeed 
financially. 

•	  Team member engagement – be a company where people 

•	 

feel included, valued, and supported; everyone is respected; 
and we work as a team. 
Innovation – create lasting value for our customers and 
increased efficiency for our operations through innovative 
thinking, industry-leading technology, and a willingness to 
test and learn. 

•	  Risk management – set the global standard in 

managing all forms of risk. 

•	  Corporate citizenship – make a positive contribution to 

communities through philanthropy, advancing diversity and 
inclusion, creating economic opportunity, and promoting 
environmental sustainability. 
Shareholder value – deliver long-term value for 
shareholders. 

•	 

Federal Reserve Board Consent Order Regarding 
Governance Oversight and Compliance and 
Operational Risk Management 
On February 2, 2018, the Company entered into a consent order 
with the Board of Governors of the Federal Reserve System 
(FRB). As required by the consent order, the Board submitted to 
the FRB a plan to further enhance the Board’s governance and 
oversight of the Company, and the Company submitted to the 
FRB a plan to further improve the Company’s compliance and 
operational risk management program. The consent order 
requires the Company, following the FRB’s acceptance and 
approval of the plans and the Company’s adoption and 
implementation of the plans, to complete third-party reviews of 
the enhancements and improvements provided for in the plans. 
Until these third-party reviews are complete and the plans are 
approved and implemented to the satisfaction of the FRB, the 
Company’s total consolidated assets will be limited to the level as 
of December 31, 2017. Compliance with this asset cap will be 
measured on a two-quarter daily average basis to allow for 
management of temporary fluctuations. The Company continues 
to have constructive dialogue with the FRB on an ongoing basis 
to clarify expectations, receive feedback, and assess progress 
under the consent order. In order to have enough time to 
incorporate this feedback into the Company’s plans in a 

42 

Wells Fargo & Company 

42

 
 
thoughtful manner, adopt and implement the final plans as 
accepted by the FRB, and complete the required third-party 
reviews, the Company is planning to operate under the asset cap 
through the end of 2019. As of the end of fourth quarter 2018, 
our total consolidated assets, as calculated pursuant to the 
requirements of the consent order, were below our level of total 
assets as of December 31, 2017. Additionally, after removal of the 
asset cap, a second third-party review must also be conducted to 
assess the efficacy and sustainability of the enhancements and 
improvements. 

Consent Orders with the Consumer Financial 
Protection Bureau and Office of the Comptroller 
of the Currency Regarding Compliance Risk 
Management Program, Automobile Collateral 
Protection Insurance Policies, and Mortgage 
Interest Rate Lock Extensions 
On April 20, 2018, the Company entered into consent orders 
with the Consumer Financial Protection Bureau (CFPB) and the 
Office of the Comptroller of the Currency (OCC) to pay an 
aggregate of $1 billion in civil money penalties to resolve matters 
regarding the Company’s compliance risk management program 
and past practices involving certain automobile collateral 
protection insurance policies and certain mortgage interest rate 
lock extensions. As required by the consent orders, the Company 
submitted to the CFPB and OCC an enterprise-wide compliance 
risk management plan and a plan to enhance the Company’s 
internal audit program with respect to federal consumer 
financial law and the terms of the consent orders. In addition, as 
required by the consent orders, the Company submitted for non-
objection plans to remediate customers affected by the 
automobile collateral protection insurance and mortgage 
interest rate lock matters, as well as a plan for the management 
of remediation activities conducted by the Company. 

Retail Sales Practices Matters 
As we have previously reported, in September 2016 we 
announced settlements with the CFPB, the OCC, and the Office 
of the Los Angeles City Attorney, and entered into consent 
orders with the CFPB and the OCC, in connection with 
allegations that some of our retail customers received products 
and services they did not request. As a result, it remains our top 
priority to rebuild trust through a comprehensive action plan 
that includes making things right for our customers, team 
members, and other stakeholders, and building a better 
Company for the future. 

Our priority of rebuilding trust has included numerous 
actions focused on identifying potential financial harm and 
customer remediation. The Board and management are 
conducting company-wide reviews of sales practices issues. 
These reviews are ongoing. In August 2017, a third-party 
consulting firm completed an expanded data-driven review of 
retail banking accounts opened from January 2009 to 
September 2016 to identify financial harm stemming from 
potentially unauthorized accounts. We have completed financial 
remediation for the customers identified through the expanded 
account analysis. Additionally, customer outreach under the 
$142 million class action lawsuit settlement concerning 
improper retail sales practices (Jabbari v. Wells Fargo Bank, 
N.A.), into which the Company entered to provide further 
remediation to customers, concluded in June 2018 and the 
period for customers to submit claims closed on July 7, 2018. 
The settlement administrator will pay claims following the 

calculation of compensatory damages and favorable resolution of 
pending appeals in the case. 

For additional information regarding sales practices 
matters, including related legal matters, see the “Risk Factors” 
section and Note 16 (Legal Actions) to Financial Statements in 
this Report. 

Additional Efforts to Rebuild Trust 
Our priority of rebuilding trust has also included an effort to 
identify other areas or instances where customers may have 
experienced financial harm. We are working with our regulatory 
agencies in this effort, and we have accrued for the reasonably 
estimable remediation costs related to these matters, which 
amounts may change based on additional facts and information, 
as well as ongoing reviews and communications with our 
regulators. As part of this effort, we are focused on the following 
key areas: 
•	  Automobile Lending Business  The Company is 

reviewing practices concerning the origination, servicing, 
and/or collection of consumer automobile loans, 
including matters related to certain insurance products, 
and is providing remediation to the extent it identifies 
affected customers. For example: 

In July 2017, the Company announced it would 
remediate customers who may have been financially 
harmed due to issues related to automobile collateral 
protection insurance (CPI) policies purchased 
through a third-party vendor on their behalf (based 
on an understanding that the borrowers did not have 
physical damage insurance coverage on their 
automobiles as required during the term of their 
automobile loans). The practice of placing CPI had 
been previously discontinued by the Company. The 
Company is in the process of providing remediation 
to affected customers and/or letters to affected 
customers through which they may claim or 
otherwise receive remediation compensation for 
policies placed between October 15, 2005, and 
September 30, 2016. 
The Company has identified certain issues related to 
the unused portion of guaranteed automobile 
protection waiver or insurance agreements between 
the customer and dealer and, by assignment, the 
lender, which will result in remediation to customers 
in certain states. The Company is in the process of 
providing remediation to affected customers. 
•	  Mortgage Interest Rate Lock Extensions  In October 
2017, the Company announced plans to reach out to all 
home lending customers who paid fees for mortgage rate 
lock extensions requested from September 16, 2013, 
through February 28, 2017, and to provide refunds, with 
interest, to customers who believe they should not have paid 
those fees. The plan to issue refunds follows an internal 
review that determined a rate lock extension policy 
implemented in September 2013 was, at times, not 
consistently applied, resulting in some borrowers being 
charged fees in cases where the Company was primarily 
responsible for the delays that made the extensions 
necessary. Effective March 1, 2017, the Company changed 
how it manages the mortgage rate lock extension process by 
establishing a centralized review team that reviews all rate 
lock extension requests for consistent application of the 
policy. Although the Company believes a substantial 
number of the rate lock extension fees during the period in 
question were appropriately charged under its policy, due to 

43

Wells Fargo & Company 

43 

Overview (continued) 

our customer-oriented remediation approach, we have 
issued refunds and interest to substantially all of our 
customers who paid rate lock extension fees during the 
period in question. We have substantially completed the 
remediation process. 

• 	 Add-on Products  The Company is reviewing practices 
related to certain consumer “add-on” products, including 
identity theft and debt protection products that were 
subject to an OCC consent order entered into in June 2015, 
as well as home and automobile warranty products, and 
memberships in discount programs. The products were 
sold to customers through a number of distribution 
channels and, in some cases, were acquired by the 
Company in connection with the purchase of loans. Sales 
of certain of these products have been discontinued over 
the past few years primarily due to decisions made by the 
Company in the normal course of business, and by 
mid-2017, the Company had ceased selling any of these 
products to consumers. We are in the process of providing 
remediation where we identify affected customers, and are 
also providing refunds to customers who purchased 
certain products. The review of the Company’s historical 
practices with respect to these products is ongoing, 
focusing on, among other topics, sales practices, adequacy 
of disclosures, customer servicing, and volume and type of 
customer complaints. 

• 	 Consumer Deposit Account Freezing/Closing 
The Company is reviewing procedures regarding the 
freezing (and, in many cases, closing) of consumer 
deposit accounts after the Company detected suspected 
fraudulent activity (by third-parties or account holders) 
that affected those accounts. This review is ongoing. 
• 	 Review of Certain Activities Within Wealth and 
Investment Management  A review of certain 
activities within Wealth and Investment Management 
(WIM) being conducted by the Board, in response to 
inquiries from federal government agencies, is assessing 
whether there have been inappropriate referrals or 
recommendations, including with respect to rollovers for 
401(k) plan participants, certain alternative investments, 
or referrals of brokerage customers to the Company’s 
investment and fiduciary services business. The Board’s 
review is substantially completed and has not, to date, 
uncovered evidence of systemic or widespread issues in 
these businesses. Federal government agencies continue 
to review this matter. 

• 	 Fiduciary and Custody Account Fee Calculations 
The Company is reviewing fee calculations within certain 
fiduciary and custody accounts in its investment and 
fiduciary services business, which is part of the wealth 
management business in WIM. The Company has 
determined that there have been instances of incorrect 
fees being applied to certain assets and accounts, 
resulting in both overcharges and undercharges to 
customers. These issues include the incorrect set-up and 
maintenance in the system of record of the values 
associated with certain assets. Systems, operations, and 
account-level reviews are underway to determine the 
extent of any assets and accounts affected, and root 
cause analyses are being performed with the assistance 
of third parties. These reviews are ongoing and, as a 
result of its reviews to date, the Company has suspended 
the charging of fees on some assets and accounts, has 
notified the affected customers, and is continuing its 
analysis of those assets and accounts. The review of 

customer accounts is ongoing to determine the extent of 
any additional necessary remediation, including with 
respect to additional accounts not yet reviewed, which 
may lead to additional accruals and fee suspensions. 

• 	 Foreign Exchange Business  The Company has 

completed an assessment, with the assistance of a third 
party, of its policies, practices, and procedures in its 
foreign exchange (FX) business. The FX business 
continues to revise and implement new policies, 
practices, and procedures, including those related to 
pricing. The Company has begun providing remediation 
to customers that may have received pricing inconsistent 
with commitments made to those customers, and rebates 
to customers where historic pricing, while consistent 
with contracts entered into with those customers, does 
not conform to the Company’s recently implemented 
standards and pricing. The Company’s review of affected 
customers is ongoing. 

• 	 Mortgage Loan Modifications  An internal review of 
the Company’s use of a mortgage loan modification 
underwriting tool identified a calculation error regarding 
foreclosure attorneys’ fees affecting certain accounts that 
were in the foreclosure process between April 13, 2010, 
and October 2, 2015, when the error was corrected. A 
subsequent expanded review identified related errors 
regarding the maximum allowable foreclosure attorneys’ 
fees permitted for certain accounts that were in the 
foreclosure process between March 15, 2010, and 
April 30, 2018, when new controls were implemented. 
Similar to the initial calculation error, these errors 
caused an overstatement of the attorneys’ fees that were 
included for purposes of determining whether a 
customer qualified for a mortgage loan modification or 
repayment plan pursuant to the requirements of 
government-sponsored enterprises (such as Fannie Mae 
and Freddie Mac), the Federal Housing Administration 
(FHA), and the U.S. Department of Treasury’s Home 
Affordable Modification Program (HAMP). Customers 
were not actually charged the incorrect attorneys’ fees. 
As previously disclosed, the Company has identified 
customers who, as a result of these errors, were 
incorrectly denied a loan modification or were not 
offered a loan modification or repayment plan in cases 
where they otherwise would have qualified, as well as 
instances where a foreclosure was completed after the 
loan modification was denied or the customer was 
deemed ineligible to be offered a loan modification or 
repayment plan. The number of previously disclosed 
customers affected by these errors may change as a 
result of ongoing validation, but is not expected to have 
changed materially upon completion of this validation. 
The Company has contacted substantially all of the 
identified customers affected by these errors and has 
provided remediation as well as the option to pursue no-
cost mediation with an independent mediator. The 
Company’s review of its mortgage loan modification 
practices is ongoing, and we are providing remediation 
to the extent we identify additional affected customers as 
a result of this review. 

To the extent issues are identified, we will continue to 

assess any customer harm and provide remediation as 
appropriate. This effort to identify other instances in which 
customers may have experienced harm is ongoing, and it is 
possible that we may identify other areas of potential concern. 

44 

Wells Fargo & Company 

44

 
  
For more information, including related legal and regulatory 
risk, see the “Risk Factors” section and Note 16 (Legal Actions) 
to Financial Statements in this Report. 

Financial Performance 
In 2018, we generated $22.4 billion of net income and diluted 
earnings per common share (EPS) of $4.28, compared with 
$22.2 billion of net income and EPS of $4.10 for 2017. We grew 
average commercial and industrial, and average real estate 1-4 
family first mortgage loans compared with 2017, maintained 
strong capital and liquidity levels, and rewarded our 
shareholders by increasing our dividend and continuing to 
repurchase shares of our common stock. Our achievements 
during 2018 continued to demonstrate the benefit of our 
diversified business model and our ability to generate consistent 
financial performance. We remain focused on meeting the 
financial needs of our customers. Noteworthy financial 
performance items for 2018 (compared with 2017) included: 
revenue of $86.4 billion, down from $88.4 billion, which 
• 	
included net interest income of $50.0 billion, up 
$438 million, or 1%; 
average loans of $945.2 billion, down 1%; 
average deposits of $1.3 trillion, down $28.8 billion, or 2%; 
return on assets (ROA) of 1.19% and return on equity (ROE) 
of 11.53%, up from 1.15% and 11.35%, respectively, a year 
ago; 

• 	
• 	
• 	

• 	 our credit results improved with a net charge-off rate of 

0.29%, compared with 0.31% a year ago; 

• 	 nonaccrual loans of $6.5 billion, down $1.2 billion, or 15%, 

from a year ago; and 

• 	 $25.8 billion in capital returned to our shareholders 

through increased common stock dividends and additional 
net share repurchases, up 78% from a year ago. 

Table 1 presents a six-year summary of selected financial 
data and Table 2 presents selected ratios and per common share 
data. 

Balance Sheet and Liquidity 
Our balance sheet remained strong during 2018 with strong 
credit quality and solid levels of liquidity and capital. Our total 
assets were $1.90 trillion at December 31, 2018. Cash and other 
short-term investments decreased $42.5 billion from 
December 31, 2017, reflecting lower deposit balances. Debt 
securities grew $11.3 billion, or 2%, from December 31, 2017. 
Our loan portfolio declined $3.7 billion from December 31, 2017. 
Growth in commercial and industrial loans and real estate 1-4 
family first mortgage loans was more than offset by declines in 
commercial real estate mortgage, real estate 1-4 family junior 
lien mortgage and automobile loans. 

Deposits at December 31, 2018, were down $49.8 billion, or 

4%, from 2017. The decline was driven by a decrease in 
commercial deposits from financial institutions, which includes 
actions the Company took in the first half of 2018 in response to 
the asset cap, and a decline in consumer and small business 
banking deposits. Our average deposit cost increased 21 basis 
points from a year ago driven by an increase in Wholesale 
Banking and Wealth and Investment Management deposit rates. 

Credit Quality 
Credit quality remained solid in 2018, driven by continued 
strong performance in the commercial and consumer real estate 
portfolios. Performance in several of our commercial and 
consumer loan portfolios remained near historically low loss 
levels and reflected our long-term risk focus. Net charge-offs 
were $2.7 billion, or 0.29% of average loans, in 2018, compared 
with $2.9 billion, or 0.31%, in 2017. 

Net losses in our commercial portfolio were $429 million, or 

9 basis points of average commercial loans, in 2018, compared 
with $446 million, or 9 basis points, in 2017, driven by 
decreased losses in our commercial and industrial loan portfolio. 
Net consumer losses decreased to 52 basis points of average 
consumer loans in 2018, compared with 55 basis points in 2017. 
Losses in our consumer real estate portfolios declined 
$93 million in 2018 to a net recovery position. The consumer 
loss levels reflected decreased losses in our automobile and other 
revolving and installment loan portfolios, lower losses in our 
residential real estate portfolios due to the benefit of the 
improving housing market, and our continued focus on 
originating high quality loans. 

The allowance for credit losses of $10.7 billion at 

December 31, 2018, declined $1.3 billion from the prior year. 
Our provision for credit losses in 2018 was $1.7 billion, 
compared with $2.5 billion in 2017, reflecting a release of 
$1.0 billion in the allowance for credit losses, compared with a 
release of $400 million in 2017. The release in 2018 and 2017 
was due to strong underlying credit performance. 

Nonperforming assets (NPAs) at the end of 2018 were 
$6.9 billion, down 16% from the end of 2017. Nonaccrual loans 
declined $1.2 billion from the prior year end while foreclosed 
assets were down $191 million from 2017. 

Capital 
Our financial performance in 2018 allowed us to maintain a solid 
capital position with total equity of $197.1 billion at 
December 31, 2018, compared with $208.1 billion at 
December 31, 2017. We returned $25.8 billion to shareholders in 
2018 ($14.5 billion in 2017) through common stock dividends 
and net share repurchases, and our net payout ratio (which is the 
ratio of (i) common stock dividends and share repurchases less 
issuances and stock compensation-related items, divided by (ii) 
net income applicable to common stock) was 125%. During 2018 
we increased our quarterly common stock dividend from $0.39 
to $0.43 per share. Our common shares outstanding declined by 
310.4 million shares, or 6%, as we continued to reduce our 
common share count through the repurchase of 375.5 million 
common shares during the year. We expect our share count to 
continue to decline in 2019 as a result of anticipated net share 
repurchases. 

We believe an important measure of our capital strength is 

the Common Equity Tier 1 ratio on a fully phased-in basis, which 
was 11.74% as of December 31, 2018, down from 11.98% a year 
ago, but still well above our internal target of 10%. Likewise, our 
other regulatory capital ratios remained strong. See the “Capital 
Management” section in this Report for more information 
regarding our capital, including the calculation of our regulatory 
capital amounts. 

45

Wells Fargo & Company 

45 

 
Overview (continued)
 

Table 1:  Six-Year Summary of Selected Financial Data
 

2018 

2017 

2016 

2015 

2014 

2013 

% 
Change
2018/
2017 

Five-year
compound
growth 
rate 

(in millions, except per share

amounts) 

Income statement 

Net interest income 

Noninterest income 

Revenue 

Provision for credit losses 

$  49,995 

36,413 

86,408 

1,744 

49,557 

38,832 

88,389 

2,528 

47,754 

40,513 

88,267 

3,770 

45,301 

40,756 

86,057 

2,442 

49,974 

43,527 

40,820 

84,347 

1,395 

49,037 

42,800 

40,980 

83,780 

2,309 

48,842 

1% 

(6) 

(2) 

(31) 

(4) 

Noninterest expense 

56,126 

58,484 

52,377 

Net income before noncontrolling

interests 

Less: Net income from 

noncontrolling interests 

22,876 

22,460 

22,045 

23,276 

23,608 

22,224 

483 

277 

107 

382 

551 

346 

Wells Fargo net income 

22,393 

22,183 

21,938 

22,894 

23,057 

21,878 

Earnings per common share 

Diluted earnings per common share 

4.31 

4.28 

4.14 

4.10 

4.03 

3.99 

4.18 

4.12 

4.17 

4.10 

3.95 

3.89 

Dividends declared per common

share 

Balance sheet (at year end) 

Debt securities 

Loans 

Allowance for loan losses 

Goodwill 

Equity securities 

Assets 

Deposits 

1.640 

1.540 

1.515 

1.475 

1.350 

1.150 

$  484,689 

473,366 

459,038 

394,744 

350,661 

298,241 

953,110 

956,770 

967,604 

916,559 

862,551 

822,286 

9,775 

26,418 

55,148 

11,004 

26,587 

62,497 

11,419 

26,693 

49,110 

11,545 

25,529 

40,266 

12,319 

25,705 

44,005 

14,502 

25,637 

32,227 

1,895,883 

1,951,757 

1,930,115 

1,787,632 

1,687,155 

1,523,502 

1,286,170 

1,335,991 

1,306,079 

1,223,312 

1,168,310 

1,079,177 

Long-term debt 

229,044 

225,020 

255,077 

199,536 

183,943 

152,998 

Wells Fargo stockholders’ equity 

196,166 

206,936 

199,581 

192,998 

184,394 

170,142 

Noncontrolling interests 

900 

1,143 

916 

893 

868 

866 

Total equity 

197,066 

208,079 

200,497 

193,891 

185,262 

171,008 

2 

74 

1 

4 

4 

6 

2% 

— 

(11) 

(1) 

(12) 

(3) 

(4) 

2 

(5) 

(21) 

(5) 

3 

(2) 

1 

(5) 

3 

1 

7 

— 

2 

2 

7 

10 

3 

(8) 

1 

11 

4 

4 

8 

3 

1 

3 

46 

Wells Fargo & Company 

46

  
 
Table 2:  Ratios and Per Common Share Data 

Profitability ratios 

Wells Fargo net income to average assets (ROA) 

1.19% 

1.15 

1.16 

Year ended December 31, 

2018 

2017 

2016 

Wells Fargo net income applicable to common stock to average Wells Fargo common 

stockholders’ equity (ROE)	 

Return on average tangible common equity (ROTCE) (1) 

Efficiency ratio (2) 

Capital ratios (3) 

At year end: 

Wells Fargo common stockholders’ equity to assets 

Total equity to assets 

Risk-based capital (4): 

Common Equity Tier 1 

Tier 1 capital 

Total capital 

Tier 1 leverage 

Average balances: 

Average Wells Fargo common stockholders’ equity to average assets 

Average total equity to average assets 

Per common share data 

Dividend payout (5) 

Book value (6) 

11.53 

13.73 

65.0 

9.20 

10.39 

11.74 

13.46 

16.60 

9.07 

9.50 

10.77 

38.3 

$ 

38.06 

11.35 

13.55 

66.2 

9.38 

10.66 

12.28 

14.14 

17.46 

9.35 

9.37 

10.64 

37.6 

37.44 

11.49 

13.85 

59.3 

9.14 

10.39 

11.13 

12.82 

16.04 

8.95 

9.40 

10.64 

38.0 

35.18 

(1) 	 Tangible common equity is a non-GAAP financial measure and represents total equity less preferred equity, noncontrolling interests, and goodwill and certain identifiable 

intangible assets (including goodwill and intangible assets associated with certain of our nonmarketable equity securities, but excluding mortgage servicing rights), net of 
applicable deferred taxes. The methodology of determining tangible common equity may differ among companies. Management believes that return on average tangible 
common equity, which utilizes tangible common equity, is a useful financial measure because it enables investors and others to assess the Company’s use of equity. For 
additional information, including a corresponding reconciliation to GAAP financial measures, see the “Capital Management – Tangible Common Equity” section in this Report. 

(2) 	 The efficiency ratio is noninterest expense divided by total revenue (net interest income and noninterest income). 
(3) 	 See the “Capital Management” section and Note 28 (Regulatory and Agency Capital Requirements) to Financial Statements in this Report for additional information. 
(4) 	 The risk-based capital ratios were calculated under the lower of Standardized or Advanced Approach determined pursuant to Basel III. Beginning January 1, 2018, the 

requirements for calculating common equity tier 1 and tier 1 capital, along with risk-weighted assets, became fully phased-in; Accordingly, the information presented 
reflects fully phased-in common equity tier 1 capital, tier 1 capital and risk-weighted assets but reflects total capital still in accordance with Transition Requirements. See 
the “Capital Management” section and Note 28 (Regulatory and Agency Capital Requirements) to Financial Statements in this Report for additional information. 

(5) 	 Dividend payout ratio is dividends declared per common share as a percentage of diluted earnings per common share. 
(6) 	 Book value per common share is common stockholders’ equity divided by common shares outstanding. 

47

Wells Fargo & Company 

47 

  
 
Earnings Performance
 

Wells Fargo net income for 2018 was $22.4 billion ($4.28 
diluted earnings per common share), compared with 
$22.2 billion ($4.10 diluted per share) for 2017 and $21.9 billion 
($3.99 diluted per share) for 2016. Our financial performance in 
2018 benefited from a $438 million increase in net interest 
income, a $784 million decrease in our provision for credit 
losses, and a $2.4 billion decrease in noninterest expense, 
partially offset by a $2.4 billion decrease in noninterest income, 
and a $745 million increase in income tax expense. 

Revenue, the sum of net interest income and noninterest 
income, was $86.4 billion in 2018, compared with $88.4 billion 
in 2017 and $88.3 billion in 2016. The decrease in revenue for 
2018 compared with 2017 was predominantly due to a decrease 
in noninterest income, reflecting decreases in mortgage banking 
income, insurance income, service charges on deposit accounts, 
and net gains (losses) from debt and equity securities, partially 
offset by an increase in all other noninterest income. Our 
diversified sources of revenue generated by our businesses 
continued to be balanced between net interest income and 
noninterest income. In 2018, net interest income of $50.0 billion 
represented 58% of revenue, compared with $49.6 billion (56%) 
in 2017 and $47.8 billion (54%) in 2016. Table 3 presents the 
components of revenue and noninterest expense as a percentage 
of revenue for year-over-year results. 

See later in this section for discussions of net interest 

income, noninterest income and noninterest expense. 

48 

Wells Fargo & Company 

48

Table 3:  Net Interest Income, Noninterest Income and Noninterest Expense as a Percentage of Revenue 

(in millions) 

Interest income (on a taxable-equivalent basis) 

2018 

% of 
revenue 

2017 

% of 
revenue 

2016 

% of 
revenue 

Year ended December 31, 

Debt securities 

$ 

14,947 

17%  $ 

14,084 

15%  $ 

12,328 

14% 

Mortgage loans held for sale (MLHFS) 

Loans held for sale (LHFS) 

Loans 

Equity securities 

Other interest income 

Total interest income (on a taxable-equivalent basis) 

Interest expense (on a taxable-equivalent basis) 

Deposits 

Short-term borrowings 

Long-term debt 

Other interest expense 

Total interest expense (on a taxable-equivalent basis) 

Net interest income (on a taxable-equivalent basis) 

Taxable-equivalent adjustment 

Net interest income (A) 

Noninterest income 

Service charges on deposit accounts 

Trust and investment fees (1) 

Card fees 

Other fees (1) 

Mortgage banking (1) 

Insurance 

Net gains from trading activities 

Net gains on debt securities 

Net gains from equity securities 

Lease income 

Other (1) 

Total noninterest income (B) 

Noninterest expense 

Salaries 

Commission and incentive compensation 

Employee benefits 

Equipment 

Net occupancy 

Core deposit and other intangibles 

FDIC and other deposit assessments 

Operating losses 

Outside professional services 

Other (2) 

Total noninterest expense 

Revenue (A) + (B) 

777 

140 

44,086 

999 

4,359 

65,308 

5,622 

1,719 

6,703 

610 

14,654 

50,654 

(659) 

49,995 

4,716 

14,509 

3,907 

3,384 

3,017 

429 

602 

108 

1,515 

1,753 

2,473 

36,413 

17,834 

10,264 

4,926 

2,444 

2,888 

1,058 

1,110 

3,124 

3,306 

9,172 

56,126 

1 

— 

51 

1 

5 

76 

7 

2 

8 

1 

17 

59 

(1) 

58 

5 

17 

5 

4 

3 

— 

1 

— 

2 

2 

3 

42 

21 

12 

6 

3 

3 

1 

1 

4 

4 

11 

65 

786 

50 

41,551 

821 

2,941 

60,233 

3,013 

761 

5,157 

424 

9,355 

50,878 

(1,321) 

49,557 

5,111 

14,495 

3,960 

3,557 

4,350 

1,049 

542 

479 

1,779 

1,907 

1,603 

1 

3 

47 

1 

3 

68 

3 

1 

6 

— 

11 

57 

(1) 

56 

6 

16 

4 

4 

5 

1 

1 

1 

2 

2 

2 

784 

38 

39,630 

669 

1,457 

54,906 

1,395 

333 

3,830 

354 

5,912 

48,994 

(1,240) 

47,754 

5,372 

14,243 

3,936 

3,727 

6,096 

1,268 

610 

942 

1,103 

1,927 

1,289 

1 

— 

45 

1 

2 

62 

2 

— 

5 

— 

7 

55 

(1) 

54 

6 

16 

5 

4 

7 

2 

1 

1 

1 

2 

1 

38,832 

44 

40,513 

46 

17,363 

10,442 

5,566 

2,237 

2,849 

1,152 

1,287 

5,492 

3,813 

8,283 

20 

12 

6 

3 

3 

1 

1 

6 

4 

9 

16,552 

10,247 

5,094 

2,154 

2,855 

1,192 

1,168 

1,608 

3,138 

8,369 

19 

12 

6 

2 

3 

1 

1 

2 

4 

9 

58,484 

66 

52,377 

59 

$ 

86,408 

$ 

88,389 

$ 

88,267 

(1)  See Table 7 – Noninterest Income in this Report for additional detail. 
(2)  See Table 8 – Noninterest Expense in this Report for additional detail. 

49

Wells Fargo & Company 

49 

  
 
Earnings Performance (continued) 

Net Interest Income 
Net interest income is the interest earned on debt securities, 
loans (including yield-related loan fees) and other interest-
earning assets minus the interest paid on deposits, short-term 
borrowings and long-term debt. Net interest margin is the 
average yield on earning assets minus the average interest rate 
paid for deposits and our other sources of funding. Net interest 
income and the net interest margin are presented on a taxable-
equivalent basis in Table 5 to consistently reflect income from 
taxable and tax-exempt loans and debt and equity securities 
based on a 21% and 35% federal statutory tax rate for the periods 
ending December 31, 2018 and 2017, respectively. 

Net interest income and the net interest margin in any one 

period can be significantly affected by a variety of factors 
including the mix and overall size of our earning assets portfolio 
and the cost of funding those assets. In addition, some variable 
sources of interest income, such as resolutions from purchased 
credit-impaired (PCI) loans, loan fees, periodic dividends, and 
collection of interest on nonaccrual loans, can vary from period 
to period. 

Net interest income on a taxable-equivalent basis was 
$50.7 billion in 2018, compared with $50.9 billion in 2017, and 
$49.0 billion in 2016. The decrease in net interest income in 
2018, compared with 2017, was driven by: 
• 	

lower loan swap income due to unwinding the receive-fixed 
loan swap portfolio; 
lower tax-equivalent net interest income from updated tax-
equivalent factors reflecting new tax law; 
a smaller balance sheet and unfavorable mix; 

• 	

unfavorable hedge ineffectiveness accounting results; 

• 	
• 	 higher premium amortization; and 
• 
partially offset by: 
• 	
• 	 higher variable income. 

the net repricing benefit of higher interest rates; and 

The slight increase in net interest margin in 2017, compared 

with 2016, was due to the repricing benefits of earning assets 
from higher interest rates exceeding the repricing costs of 
deposits and market based funding sources. 

Table 4 presents the components of earning assets and 
funding sources as a percentage of earning assets to provide a 
more meaningful analysis of year-over-year changes that 
influenced net interest income. 

Average earning assets decreased $38.1 billion in 2018 

compared with 2017. The decrease was driven by: 
average loans decreased $10.9 billion in 2018; 
• 	
average interest-earning deposits decreased $45.5 billion in 
• 	
2018; 

partially offset by: 
• 	

average federal funds sold and securities purchased under 
resale agreements increased $3.9 billion in 2018; 
average debt securities increased $13.8 billion in 2018; and 
average equity securities increased $2.0 billion in 2018. 

• 	
• 	

Deposits are an important low-cost source of funding and 

affect both net interest income and the net interest margin. 
Deposits include noninterest-bearing deposits, interest-bearing 
checking, market rate and other savings, savings certificates, 
other time deposits, and deposits in foreign offices. Average 
deposits decreased to $1.28 trillion in 2018, compared with 
$1.30 trillion in 2017, and represented 135% of average loans in 
2018, compared with 136% in 2017. Average deposits were 73% 
of average earning assets in both 2018 and 2017. 

Table 5 presents the individual components of net interest 

income and the net interest margin. The effect on interest 
income and costs of earning asset and funding mix changes 
described above, combined with rate changes during 2018, are 
analyzed in Table 6. 

The increase in net interest income for 2017, compared with 

2016, was driven by growth in earning assets and the benefit of 
higher interest rates, partially offset by growth and repricing of 
long-term debt. Deposit interest expense also increased in 2017, 
largely due to an increase in wholesale and Wealth and 
Investment Management (WIM) deposit pricing resulting from 
higher interest rates. 

Net interest margin on a taxable-equivalent basis 

was 2.91% in 2018, compared with 2.87% in 2017 and 2.86% in 
2016. The increase in net interest margin in 2018, compared 
with 2017, was driven by: 
• 	
• 	
• 
partially offset by: 
• 	

the net repricing benefit of higher interest rates; 
runoff of lower yielding assets and other favorable mix; and 
higher variable income; 

lower loan swap income due to unwinding the receive-fixed 
loan swap portfolio; 
lower tax-equivalent net interest income from updated tax-
equivalent factors reflecting new tax law; 

• 	

• 	 higher premium amortization; and 
• 	 unfavorable hedge ineffectiveness accounting results. 

50 

Wells Fargo & Company 

50

Table 4:  Average Earning Assets and Funding Sources as a Percentage of Average Earning Assets 

(in millions) 

Earning assets 

Year ended December 31, 

2018 

2017 

Average
balance 

% of earning 
assets 

Average
balance 

% of earning 
assets 

Interest-earning deposits with banks 

$ 

156,366 

9% 

$ 

201,864 

12% 

Federal funds sold, securities purchased under resale agreements 

Debt securities: 

Trading debt securities 

Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions 
Mortgage-backed securities: 

Federal agencies 
Residential and commercial 

Total mortgage-backed securities 

Other debt securities 

Total available-for-sale debt securities 

Held-to-maturity debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions 

Federal agency mortgage-backed securities 

Other debt securities 

Held-to-maturity debt securities 

Total debt securities 

Mortgage loans held for sale (1) 

Loans held for sale (1) 

Commercial loans: 

Commercial and industrial – U.S. 

Commercial and industrial – Non-U.S. 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial loans 

Consumer loans: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer loans 

Total loans (1) 

Equity securities 

Other 

Total earning assets 

Funding sources 

Deposits: 

Interest-bearing checking 

Market rate and other savings 

Savings certificates 

Other time deposits 

Deposits in foreign offices 

Total interest-bearing deposits 

Short-term borrowings 

Long-term debt 

Other liabilities 

Total interest-bearing liabilities 

Portion of noninterest-bearing funding sources 

Total funding sources 

Noninterest-earning assets 

Cash and due from banks 

Goodwill 

Other 

Total noninterest-earning assets 

Noninterest-bearing funding sources 

Deposits 

Other liabilities 

Total equity 

Noninterest-bearing funding sources used to fund earning assets 

Net noninterest-bearing funding sources 

Total assets 

(1)  Nonaccrual loans are included in their respective loan categories. 

78,547 

83,526 

6,618 

47,884 

156,052 
7,769 

163,821 

46,875 

265,198 

44,735 

6,253 

94,216 

361 

145,565 

494,289 

18,394 

2,526 

275,656 

60,718 

122,947 

23,609 

19,392 

502,322 

284,178 

36,687 

36,780 

48,115 

37,115 

442,875 

945,197 

38,092 

5,071 

5 

5 

— 

3 

9 
— 

9 

3 

15 

3 

— 

5 

— 

8 

28 

1 

— 

16 

4 

7 

1 

1 

29 

16 

2 

2 

3 

2 

25 

54 

2 

1 

74,697 

74,475 

15,966 

52,658 

145,310 
11,839 

157,149 

48,714 

274,487 

44,705 

6,268 

78,330 

2,194 

131,497 

480,459 

20,780 

1,487 

272,034 

57,198 

129,990 

24,813 

19,128 

503,163 

277,751 

42,780 

35,600 

57,900 

38,935 

452,966 

956,129 

36,105 

5,069 

4 

4 

1 

3 

8 
1 

9 

3 

16 

3 

— 

4 

— 

7 

27 

1 

— 

16 

3 

7 

1 

1 

28 

16 

3 

2 

3 

2 

26 

54 

2 

— 

$ 

1,738,482 

100% 

$ 

1,776,590 

100% 

$ 

63,243 

684,882 

20,653 

84,822 

63,945 

917,545 

104,267 

224,268 

27,648 

1,273,728 

464,754 

4% 

$ 

39 

1 

5 

4 

53 

6 

13 

1 

73 

27 

49,474 

682,053 

22,190 

61,625 

123,816 

939,158 

98,922 

246,195 

21,872 

1,306,147 

470,443 

3% 

39 

1 

3 

7 

53 

6 

14 

1 

74 

26 

$ 

1,738,482 

100% 

$ 

1,776,590 

100% 

$ 

$ 

$ 

$ 

$ 

18,777 

26,453 

105,180 

150,410 

358,312 

53,496 

203,356 

(464,754) 

150,410 

1,888,892 

18,622 

26,629 

111,164 

156,415 

365,464 

55,740 

205,654 

(470,443) 

156,415 

1,933,005 

51

Wells Fargo & Company 

51 

  
 
Earnings Performance (continued)
 

Table 5:  Average Balances, Yields and Rates Paid (Taxable-Equivalent Basis) (1)(2)
 

Average 
balance 

Yields/ 	
rates 

2018 
Interest 
income/ 
expense

Average 
balance 

Yields/
rates 

2017 
Interest
income/ 
expense 

$ 

156,366 
78,547 

1.82%  $ 
1.82 

2,854 
1,431 

83,526 

3.42 

2,856 

(in millions) 	

Earning assets 
Interest-earning deposits with banks (3) 
Federal funds sold and securities purchased under resale agreements (3) 
Debt securities (4): 

Trading debt securities 
Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
Mortgage-backed securities: 

Federal agencies 
Residential and commercial 

Total mortgage-backed securities 

Other debt securities 

Total available-for-sale debt securities	 

Held-to-maturity debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
Federal agency and other mortgage-backed securities 
Other debt securities 

Held-to-maturity debt securities 

Total debt securities 
Mortgage loans held for sale (5) 
Loans held for sale (5) 

Commercial: 

Commercial and industrial – U.S. 

Commercial and industrial – Non-U.S. 
Real estate mortgage 
Real estate construction 
Lease financing 

Total commercial loans	 

Consumer: 

Real estate 1-4 family first mortgage 
Real estate 1-4 family junior lien mortgage 
Credit card 
Automobile 
Other revolving credit and installment 

Total consumer loans	 

Total loans (5) 

Equity securities 
Other 

Total earning assets 

Funding sources 
Deposits: 

Interest-bearing checking 
Market rate and other savings 
Savings certificates 
Other time deposits 
Deposits in foreign offices 

Total interest-bearing deposits 

Short-term borrowings 
Long-term debt 
Other liabilities 

Total interest-bearing liabilities 

Portion of noninterest-bearing funding sources 

Total funding sources 

Net interest margin and net interest income on a taxable-

equivalent basis (6) 

Noninterest-earning assets 
Cash and due from banks 
Goodwill 
Other 

Total noninterest-earning assets 

Noninterest-bearing funding sources 
Deposits 
Other liabilities 
Total equity 
Noninterest-bearing funding sources used to fund earning assets 

Net noninterest-bearing funding sources 

Total assets 

6,618 
47,884 

156,052 
7,769 

163,821 
46,875 

265,198 

44,735 
6,253 
94,216 
361 

145,565 

494,289 
18,394 
2,526 

275,656 

60,718 
122,947 
23,609 
19,392 

502,322 

284,178 
36,687 
36,780 
48,115 
37,115 

442,875 

945,197 
38,092 
5,071 
$  1,738,482 

$ 

63,243 
684,882 
20,653 
84,822 
63,945 
917,545 
104,267 
224,268 
27,648 

1,273,728 

464,754 

$  1,738,482 

$ 

18,777 
26,453 
105,180 

$ 

150,410 

$ 

358,312 
53,496 
203,356 
(464,754) 

$ 

150,410 

$  1,888,892 

201,864 
74,697 

74,475 

15,966 
52,658 

145,310 
11,839 

157,149 
48,714 

274,487 

44,705 
6,268 
78,330 
2,194 

131,497 

480,459 
20,780 
1,487 

272,034 

57,198 
129,990 
24,813 
19,128 

503,163 

277,751 
42,780 
35,600 
57,900 
38,935 

452,966 

956,129 
36,105 
5,069 
1,776,590 

49,474 
682,053 
22,190 
61,625 
123,816 
939,158 
98,922 
246,195 
21,872 

1,306,147 

470,443 

1,776,590 

1.07%  $ 
0.98 

3.16 

1.49 
3.95 

2.60 
5.33 

2.81 
3.68 

3.11 

2.19 
5.32 
2.34 
2.50 

2.43 

2.93 
3.78 
3.40 

3.75 

2.86 
3.74 
4.10 
3.74 

3.66 

4.03 
4.82 
12.23 
5.34 
6.18 

5.11 

4.35 
2.27 
0.85 
3.40%  $ 

0.49%  $ 
0.14 
0.30 
1.43 
0.68 
0.32 
0.77 
2.09 
1.94 

0.72 

— 

0.53 

2,162 
735 

2,356 

239 
2,082 

3,782 
631 

4,413 
1,794 

8,528 

979 
334 
1,832 
55 

3,200 

14,084 
786 
50 

10,196 

1,639 
4,859 
1,017 
715 

18,426 

11,206 
2,062 
4,355 
3,094 
2,408 

23,125 

41,551 
821 
44 
60,233 

242 
983 
67 
880 
841 
3,013 
761 
5,157 
424 

9,355 

— 

9,355 

1.70 
3.77 

2.79 
4.62 

2.87 
4.22 

3.24 

2.19 
4.34 
2.36 
4.00 

2.40 

3.02 
4.22 
5.56 

4.16 

3.53 
4.29 
4.94 
4.74 

4.18 

4.04 
5.38 
12.72 
5.18 
6.70 

5.22 

4.66 
2.62 
1.46 
3.76%  $ 

0.96%  $ 
0.31 
0.57 
2.25 
1.30 
0.61 
1.65 
2.99 
2.21 

1.15 

— 

0.85 

112 
1,806 

4,348 
358 

4,706 
1,980 

8,604 

980 
271 
2,221 
15 

3,487 

14,947 
777 
140 

11,465 

2,143 
5,279 
1,167 
919 

20,973 

11,481 
1,975 
4,678 
2,491 
2,488 

23,113 

44,086 
999 
74 
65,308 

606 
2,157 
118 
1,906 
835 
5,622 
1,719 
6,703 
610 

14,654 

— 

14,654 

2.91%  $ 

50,654 

2.87%  $ 

50,878 

18,622 
26,629 
111,164 

156,415 

365,464 
55,740 
205,654 
(470,443) 

156,415 

1,933,005 

(1) 	 Our average prime rate was 4.91% for the year ended December 31, 2018, 4.10% for the year ended December 31, 2017, 3.51% for the year ended December 31, 2016, 
and 3.26% for the year ended December 31, 2015, and 3.25% for the year ended December 31, 2014. The average three-month London Interbank Offered Rate (LIBOR) 
was 2.31%, 1.26%, 0.74%, 0.32%, and 0.23% for the same years, respectively. 

(2) 	 Yield/rates and amounts include the effects of hedge and risk management activities associated with the respective asset and liability categories. 
(3) 	 Financial information for the prior periods has been revised to reflect the impact of our adoption of Accounting Standards Update (ASU) 2016-18 – Statement of Cash Flows 

(Topic 230): Restricted Cash in which we changed the presentation of our cash and cash equivalents to include both cash and due from banks as well as interest-earning 
deposits with banks, which are inclusive of any restricted cash. 

52 

Wells Fargo & Company 

52

  
 
 
 
Average 
balance 

Yields/ 
rates 

2016	 
Interest 
income/ 
expense 

Average 
balance 

Yields/ 	
rates 	

2015 
Interest 	
income/ 	
expense 

Average 
balance 

Yields/
rates 

2014 
Interest
income/
expense 

$ 

225,955 
61,763 

0.51%  $ 
0.48 

70,195 

29,418 
52,959 

110,637 
18,725 
129,362 

52,731 
264,470 

44,675 
2,893 
39,330 
4,043 

90,941 

425,606 
22,412 
1,361 

268,182 
51,601 
127,232 
23,197 
17,950 

488,162 

276,712 
49,735 
34,178 
61,566 
39,607 

461,798 

$ 

$ 

949,960 
27,417 
—
1,714,474 

42,379 
663,557 
25,912 
55,846 
103,206 
890,900 
115,187 
239,471 
16,702 

1,262,260 

452,214 

$ 

1,714,474 

$ 

$ 

$ 

$ 

$ 

18,617 
26,700 
125,650 

170,967 

359,666 
62,825 
200,690 
(452,214) 

170,967 

1,885,441 

1,161 
296 

2,082 

457 
2,225 

2,764 
1,029 
3,793 

1,771 
8,246 

979 
154 
786 
81 

2,000 

12,328 
784 
38 

9,243 
1,219 
4,371 
824 
916 

16,573 

11,096 
2,183 
3,970 
3,458 
2,350 

23,057 

39,630 
669 
— 
54,906 

60 
449 
91 
508 
287 
1,395 
333 
3,830 
354 

5,912 

— 

5,912 

222,773 
44,059 

51,551 

32,093 
47,404 

100,218 
22,490 

122,708 
48,515 

250,720 

44,173 
2,087 
21,967 
5,821 

74,048 

376,319 
21,603 
1,651 

237,844 
46,028 
116,893 
20,979 
12,301 

434,045 

268,560 
56,242 
31,307 
57,766 
37,512 

451,387 

885,432 
23,921 
—
1,575,758 

38,640 
625,549 
31,887 
51,790 
107,138 
855,004 
87,465 
185,078 
16,545 

1,144,092 

431,666 

1,575,758 

0.27%  $ 
0.30 

3.16 

1.58 
4.23 

2.73 
5.73 
3.28 

3.32 
3.25 

2.19 
5.40 
2.23 
1.73 

2.26 

3.04 
3.63 
2.59 

3.29 
1.90 
3.41 
3.57 
4.70 

3.23 

4.10 
4.25 
11.70 
5.84 
5.89 

5.02 

4.14 
2.94 
—

3.20%  $ 

0.05%  $ 
0.06 
0.63 
0.45 
0.13 
0.11 
0.07 
1.40 
2.15 

0.35 

— 

0.25 

605 
133 

1,627 

505 
2,007 

2,733 
1,289 
4,022 

1,609 
8,143 

968 
113 
489 
101 

1,671 

11,441 
785 
43 

7,836 
877 
3,984 
749 
577 

14,023 

11,002 
2,391 
3,664 
3,374 
2,209 

22,640 

36,663 
703 
— 
50,373 

20 
367 
201 
232 
143 
963 
64 
2,592 
357 

3,976 

— 

3,976 

209,686 
31,596 

43,108 

10,400 
43,138 

114,076 
26,475 
140,551 

45,759 
239,848 

17,239 
246 
5,921 
5,913 

29,319 

312,275 
19,018 
5,585 

204,819 
42,661 
112,710 
17,676 
12,257 

390,123 

261,620 
62,510 
27,491 
53,854 
38,834 

444,309 

834,432 
21,125 
—
1,433,717 

39,729 
585,854 
38,111 
51,434 
95,889 
811,017 
60,111 
167,420 
14,401 

1,052,949 

380,768 

1,433,717 

0.26%  $ 
0.38 

3.23 

1.64 
4.29 

2.84 
6.03 
3.44 

3.57 
3.54 

2.23 
4.93 
2.55 
1.85 

2.24 

3.37 
4.03 
2.02 

3.35 
2.03 
3.64 
4.21 
5.63 

3.40 

4.19 
4.30 
11.98 
6.27 
5.48 

5.05 

4.28 
3.08 
—

3.39%  $ 

0.07%  $ 
0.07 
0.85 
0.40 
0.14 
0.14 
0.10 
1.49 
2.65 

0.38 

— 

0.28 

554 
119 

1,392 

171 
1,852 

3,235 
1,597 
4,832 

1,635 
8,490 

385 
12 
151 
109 

657 

10,539 
767 
113 

6,869 
867 
4,100 
744 
690 

13,270 

10,961 
2,686 
3,294 
3,377 
2,127 

22,445 

35,715 
650 
— 
48,457 

26 
403 
323 
207 
137 
1,096 
62 
2,488 
382 

4,028 

— 

4,028 

2.97 

1.56 
4.20 

2.50 
5.49 
2.93 

3.36 
3.12 

2.19 
5.32 
2.00 
2.01 

2.20 

2.90 
3.50 
2.76 

3.45 
2.36 
3.44 
3.55 
5.10 

3.39 

4.01 
4.39 
11.62 
5.62 
5.93 

4.99 

4.17 
2.44 
—

3.21%  $ 

0.14%  $ 
0.07 
0.35 
0.91 
0.28 
0.16 
0.29 
1.60 
2.12 

0.47 

— 

0.35 

2.86%  $ 

48,994 

2.95%  $ 

46,397	 

3.11%  $ 

44,429 

17,327 
25,673 
124,161 

167,161	 

339,069 
68,174 
191,584 
(431,666) 
167,161 

1,742,919 

16,361 
25,687 
117,584 

159,632 

303,127 
56,985 
180,288 
(380,768) 

159,632 

1,593,349 

(4)	  Yields and rates are based on interest income/expense amounts for the period. The average balance amounts represent amortized cost for the periods presented. 
(5)	  Nonaccrual loans and related income are included in their respective loan categories. 
(6)	  Includes taxable-equivalent adjustments of $659 million, $1.3 billion, $1.2 billion, $1.1 billion and $902 million for the years ended December 31, 2018, 2017, 2016, 2015 

and 2014, respectively, predominantly related to tax-exempt income on certain loans and securities. The federal statutory tax rate utilized was 21% for the period ended 
December 31, 2018, and 35% for the periods ended December 31, 2017, 2016, 2015 and 2014. 

53

Wells Fargo & Company 

53 

Earnings Performance (continued) 

Table 6 allocates the changes in net interest income on a 
taxable-equivalent basis to changes in either average balances or 
average rates for both interest-earning assets and interest-
bearing liabilities. Because of the numerous simultaneous 
volume and rate changes during any period, it is not possible to 
precisely allocate such changes between volume and rate. For 

Table 6:  Analysis of Changes in Net Interest Income 

this table, changes that are not solely due to either volume or 
rate are allocated to these categories on a pro-rata basis based on 
the absolute value of the change due to average volume and 
average rate. 

Federal funds sold and securities purchased under resale agreements (1) 

40 

$ 

(569) 

1,261 

656 

298 

202 

(in millions) 

Increase (decrease) in interest income:
 

Interest-earning deposits with banks (1) 

Debt securities:
 

Trading debt securities	 

Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions 

Mortgage-backed securities: 

Federal agencies 

Residential and commercial 

Total mortgage-backed securities 

 Other debt securities 

Total available-for-sale debt securities	 

Held-to-maturity debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions 

Federal agency mortgage-backed securities 

Other debt securities 

  Total held-to-maturity debt securities	 

Mortgage loans held for sale 

Loans held for sale 

Commercial loans: 

Commercial and industrial – U.S. 

Commercial and industrial – Non-U.S. 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial loans	 

Consumer loans: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer loans	 

Total loans	 

Equity securities 

Other 

2018 over 2017 

Year ended December 31, 

2017 over 2016 

Volume 

Rate 

Total 

Volume 

Rate 

Total 

692 

696 

500 

(127) 

(276) 

566 

(273) 

293 

186 

76 

1 

 (63)

389 

(40) 

287 

(9) 

90 

30 

(92) 

281 

(76) 

205 

256 

399 

— 

 (62)

16 

22 

(24) 

86 

43 

1,131 

1,269 

399 

692 

201 

194 

504 

420 

150 

204 

2,617 

2,547 

27 

225 

177 

(91) 

196 

534 

275 

(87) 

323 

(603) 

80 

(12) 

3,151 

2,535 

131 

 30

178 

 30

(135) 

73 

1,136 

366 

1,001
 

439
 

134 

140 

274 

(198) 

(13) 

902 

(369) 

533 

(140) 

182 

—

 180 

893 

(43) 

1,030 

(59) 

3

135 

142 

97 

59 

57 

490 

48 

(323) 

170 

(198) 

(40) 

(343) 

147 

201 

 44 

(20) 

(130) 

116 

(29) 

87 

163 

100 

—

— 

153 

17 

170 

61 

 9

818 

278 

391 

134 

(258) 

1,363 

62 

202 

215 

(166) 

98 

411 

(218) 

(143) 

1,018 

(398) 

620

23 

282 

— 

180 

1,046 

(26)

1,200 

2 

12

953 

420 

488 

193 

(201) 

1,853 

110 

(121) 

385 

(364) 

58 

68 

1,774 

1,921 

(49) 

—

152
 

44
 

(157) 

(184) 

285 

(197) 

88 

(70) 

(323) 

1

(1)

373 

(62) 

311 

(95) 

47 

138 

105 

(272) 

(51) 

10 

(70) 

248 

(312) 

146 

(512) 

(116) 

(546) 

(616) 

47 

—

Total increase in interest income (1)	 

(860) 

5,935 

5,075 

1,620 

3,707 

5,327 

Increase (decrease) in interest expense: 

Deposits: 

Interest-bearing checking 

Market rate and other savings 

Savings certificates 

Other time deposits 

Deposits in foreign offices 

Total interest-bearing deposits 

Short-term borrowings 

Long-term debt 

Other liabilities 

         Total increase in interest expense	 

Increase (decrease) in net interest income on a taxable-equivalent basis 

$ 

82 

4 

(5) 

407 

(534) 

(46) 

43 

(495) 

122 

(376) 

(484) 

282 

1,170 

56 

619 

528 

2,655 

915 

2,041 

64 

5,675 

260 

364 

1,174 

51 

1,026 

(6) 

2,609 

958 

1,546 

186 

5,299 

11 

14 

(12) 

57 

68 

138 

(53) 

111 

102 

298 

(224) 

1,322 

171 

520 

(12) 

315 

486 

1,480 

481 

1,216 

(32) 

3,145 

562 

182 

534 

(24) 

372 

554 

1,618 

428 

1,327 

70

3,443 

1,884 

(1) 	 Financial information has been revised to reflect the impact of our adoption in first quarter 2018 of ASU 2016-18 – Statement of Cash Flows (Topic 230): Restricted Cash in 

which we changed the presentation of our cash and cash equivalents to include both cash and due from banks as well as interest-earning deposits with banks, which are 
inclusive of any restricted cash. See Note 1 (Summary of Significant Accounting Policies) to Financial Statements in this Report for more information. 

54 

Wells Fargo & Company 

54

  
 
 
Noninterest Income 

Table 7:  Noninterest Income 

(in millions) 

2018 

Service charges on deposit accounts 

$  4,716 

2017 

5,111 

2016 

5,372 

Yea

r ended Dec

ember 31, 

Trust and investment fees: 

Brokerage advisory, commissions and

other fees 

Trust and investment management 
Investment banking 

9,436 

3,316 
1,757 

9,358 

3,372 
1,765 

9,216 

3,336 
1,691 

Total trust and investment fees 

14,509 

14,495 

14,243 

Card fees 

Other fees: 

3,907 

3,960 

3,936 

Lending related charges and fees (1) 
Cash network fees 

1,526 
481 

1,568 
506 

1,562 
537 

Commercial real estate 

brokerage commissions 

Wire transfer and other remittance fees 
All other fees (2) 

468 

477 
432 

462 

448 
573 

494 

401 
733 

Total other fees 

3,384 

3,557 

3,727 

Mortgage banking: 

Servicing income, net 

Net gains on mortgage loan

origination/sales activities 

Total mortgage banking 

Insurance 

Net gains from trading activities 

Net gains on debt securities 

Net gains from equity securities 

Lease income 

Life insurance investment income 

All other 

1,373 

1,427 

1,765 

1,644 

3,017 

429 

602 

108 

1,515 

1,753 

651 

1,822 

2,923 

4,350 

1,049 

542 

479 

1,779 

1,907 

594 

1,009 

4,331 

6,096 

1,268 

610 

942 

1,103 

1,927 

587 

702 

Total	 

$ 36,413 

38,832 

40,513 

(1) 	 Represents combined amount of previously reported “Charges and fees on 

loans” and “Letters of credit fees”. 

(2) 	 All other fees have been revised to include merchant processing fees for the 

year ended 2016. 

Noninterest income of $36.4 billion represented 42% of revenue 
for 2018, compared with $38.8 billion, or 44%, for 2017 and 
$40.5 billion, or 46%, for 2016. The decline in noninterest 
income in 2018 compared with 2017 was predominantly due to 
lower mortgage banking income, lower insurance income due to 
the sale of Wells Fargo Insurance Services in fourth quarter 
2017, lower service charges on deposit accounts, lower gains on 
debt securities, and lower deferred compensation plan 
investment results (offset in employee benefits expense). These 
decreases were partially offset by higher gains from equity 
securities and higher all other income. The decline in 
noninterest income in 2017 compared with 2016 was 
predominantly driven by lower mortgage banking, impairments 
on low income housing credits and tax-advantaged renewable 
energy investments as a result of the Tax Act, and lower service 
charges on deposit accounts. These decreases in noninterest 
income were partially offset by growth in trust and investment 
fees, deferred compensation plan investment results (offset in 
employee benefits expense), and the net impact of our insurance 
services business divestiture in November 2017 and gains from 
the sale of Pick-a-Pay PCI loans. For more information on our 
performance obligations and the nature of services performed 
for certain of our revenues discussed below, see Note 21 
(Revenue from Contracts with Customers) to Financial 
Statements in this Report. 

Service charges on deposit accounts were $4.7 billion in 
2018, down from $5.1 billion in 2017 due to lower overdraft and 
monthly service fees driven by customer-friendly initiatives that 
help customers minimize monthly service charges and overdraft 
fees, and the impact of a higher earnings credit rate applied to 

commercial accounts due to increased interest rates. Service 
charges on deposit accounts decreased $261 million in 2017 
from 2016 due to lower consumer and business checking account 
service charges, lower overdraft fees driven by customer-friendly 
initiatives including the Overdraft Rewind launched in 
November 2017, and a higher earnings credit rate applied to 
commercial accounts due to increased interest rates. 

Brokerage advisory, commissions and other fees increased 

to $9.44 billion in 2018, from $9.36 billion in 2017, which 
increased $142 million from 2016. The increase in these fees in 
both 2018 and 2017 was due to higher asset-based fees, partially 
offset by lower transactional commission revenue. Retail 
brokerage client assets totaled $1.49 trillion at December 31, 
2018, compared with $1.65 trillion and $1.49 trillion at 
December 31, 2017 and 2016, respectively. All retail brokerage 
services are provided by our WIM operating segment. For 
additional information on retail brokerage client assets, see the 
discussion and Tables 9d and 9e in the “Operating Segment 
Results – Wealth and Investment Management – Retail 
Brokerage Client Assets” section in this Report. 

Trust and investment management fee income is largely 
from client assets under management (AUM), for which fees are 
based on a tiered scale relative to market value of the assets, and 
client assets under administration (AUA), for which fees are 
generally based on the extent of services to administer the assets. 
Trust and investment management fees of $3.3 billion in 2018 
declined slightly from 2017 as a decrease in corporate trust fees 
due to the sale of Wells Fargo Shareowner Services in first 
quarter 2018 was only partially offset by growth in management 
fees for investment advice on mutual funds. Trust and 
investment management fees of $3.4 billion in 2017 were 
relatively stable compared with 2016. Our AUM totaled 
$638.3 billion at December 31, 2018, compared with 
$690.3 billion and $652.2 billion at December 31, 2017 and 
2016, respectively, with substantially all of our AUM managed by 
our WIM operating segment. Additional information regarding 
our WIM operating segment AUM is provided in Table 9f and 
the related discussion in the “Operating Segment Results – 
Wealth and Investment Management – Trust and Investment 
Client Assets Under Management” section in this Report. Our 
AUA totaled $1.7 trillion at both December 31, 2018 and 2017, 
compared with $1.6 trillion at December 31, 2016. 

Investment banking fees of $1.8 billion in 2018 were 

relatively stable compared with 2017. Investment banking fees in 
2017 increased $74 million compared with 2016 due to higher 
equity and debt originations, partially offset by lower advisory 
fees. 

Card fees were $3.9 billion in 2018, compared with 
$4.0 billion in 2017 and $3.9 billion in 2016. The decrease in 
2018 reflected the impact of the new revenue recognition 
accounting standard, which reduced noninterest expense and 
lowered card fees in 2018 by an equal amount due to the netting 
of card payment network charges against related interchange 
and network revenues in card fees. This decrease in card fees in 
2018 was partially offset by higher interchange fees. Card fees 
increased in 2017, compared with 2016, predominantly due to 
increased purchase activity. 

Other fees were $3.4 billion in 2018, compared with 

$3.6 billion in 2017 and $3.7 billion in 2016. Other fees declined 
in both 2018 and 2017 predominantly due to lower all other fees. 
All other fees were $432 million in 2018, compared with 
$573 million in 2017 and $733 million in 2016. The decrease in 
2018 compared with 2017 was driven by lost fees from 
discontinued products. The decrease in all other fees in 2017 
compared with 2016 was driven by lower fees from discontinued 

55

Wells Fargo & Company 

55 

  
Table 7a:  Selected Mortgage Production Data 

Year ended December 31, 

2018 

2017 

2016 

Net gains on mortgage
loan origination/sales
activities (in millions): 

Residential 

Commercial	 

Residential pipeline
and unsold/
repurchased loan
management (1) 

(A) 

$ 1,174 

2,140 

3,168 

265 

358 

400 

205 

425 

763 

Total 

$ 1,644 

2,923 

4,331 

Residential real estate 
originations (in
billions): 

Held-for-sale 

(B) 

$  132 

45 

$  177 

160 

52 

212 

186 

63 

249 

Held-for-investment 

Total 

Production margin on
residential held-for­
sale mortgage
originations 

(A)/(B) 

0.89% 

1.34 

1.71 

(1) 	 Predominantly includes the results of Government National Mortgage 

Association (GNMA) loss mitigation activities, interest rate management 
activities and changes in estimate to the liability for mortgage loan repurchase 
losses. 

The production margin was 0.89% for 2018, compared with 
1.34% for 2017 and 1.71% for 2016. The decline in the production 
margin in 2018 was due to lower margins in both retail and 
correspondent production channels and a shift to more 
correspondent origination volume, which has a lower production 
margin. The decrease in the production margin in 2017 was due 
to a shift in origination channel mix from retail to 
correspondent. 

Mortgage applications were $230 billion in 2018, compared 

with $278 billion in 2017 and $347 billion in 2016. The 1-4 
family first mortgage unclosed pipeline was $18 billion at 
December 31, 2018, compared with $23 billion at December 31, 
2017, and $30 billion at December 31, 2016. For additional 
information about our mortgage banking activities and results, 
see the “Risk Management – Asset/Liability Management – 
Mortgage Banking Interest Rate and Market Risk” section and 
Note 10 (Mortgage Banking Activities) and Note 18 (Fair Values 
of Assets and Liabilities) to Financial Statements in this Report. 
Net gains on mortgage loan origination/sales activities 

include adjustments to the mortgage repurchase liability. 
Mortgage loans are repurchased from third parties based on 
standard representations and warranties, and early payment 
default clauses in mortgage sale contracts. 

Earnings Performance (continued) 

products and the impact of the sale of our global fund services 
business in fourth quarter 2016. 

Mortgage banking income, consisting of net servicing 
income and net gains on loan origination/sales activities, totaled 
$3.0 billion in 2018, compared with $4.4 billion in 2017 and 
$6.1 billion in 2016. As further discussed below, the decrease in 
mortgage banking income in both 2018 and 2017 was primarily 
driven by overall reductions in the size of the residential 
mortgage market as well as declines in production margins. 

In addition to servicing fees, net servicing income includes 
amortization of commercial mortgage servicing rights (MSRs), 
changes in the fair value of residential MSRs during the period, 
as well as changes in the value of derivatives (economic hedges) 
used to hedge the residential MSRs during the period. Net 
servicing income of $1.4 billion for 2018 included a $112 million 
net MSR valuation loss ($960 million increase in the fair value of 
the MSRs and a $1.1 billion hedge loss). Net servicing income of 
$1.4 billion for 2017 included a $287 million net MSR valuation 
gain ($126 million decrease in the fair value of the MSRs and a 
$413 million hedge gain), and net servicing income of 
$1.8 billion for 2016 included a $826 million net MSR valuation 
gain ($565 million increase in the fair value of MSRs and a 
$261 million hedge gain). The decline in net MSR valuation 
results in 2018, compared with 2017, was predominantly due to 
negative MSR valuation adjustments in fourth quarter 2018 for 
servicing and foreclosure costs, discount rates and prepayment 
estimates recognized as a result of recent market observations 
related to an acceleration of prepayments, including for 
Department of Veterans Affairs (VA) loans. The decrease in net 
MSR valuation gains in 2017, compared with 2016, was largely 
due to lower hedge gains in 2017 and MSR valuation 
adjustments in first quarter 2016 that reflected a reduction in 
forecasted prepayments due to updated economic, customer 
data attributes and mortgage market rate inputs. Net servicing 
income in 2018 was also favorably impacted by lower 
unreimbursed servicing and foreclosure costs as we continued to 
reduce our inventory of aged FHA loans in foreclosure. 

Our portfolio of loans serviced for others was $1.71 trillion 
at December 31, 2018, $1.70 trillion at December 31, 2017, and 
$1.68 trillion at December 31, 2016. At December 31, 2018, the 
ratio of combined residential and commercial MSRs to related 
loans serviced for others was 0.94%, compared with 0.88% at 
December 31, 2017, and 0.85% at December 31, 2016. See the 
“Risk Management – Asset/Liability Management – Mortgage 
Banking Interest Rate and Market Risk” section in this Report 
for additional information regarding our MSRs risks and 
hedging approach. 

Net gains on mortgage loan origination/sales activities was 

$1.6 billion in 2018, compared with $2.9 billion in 2017 and 
$4.3 billion in 2016. The decrease in both 2018 and 2017 was 
driven by decreased origination volumes and margins. 

Mortgage loan originations were $177 billion in 2018, 

compared with $212 billion in 2017 and $249 billion in 2016. 
The production margin on residential held-for-sale mortgage 
loan originations, which represents net gains on residential 
mortgage loan origination/sales activities divided by total 
residential held-for-sale mortgage loan originations, provides a 
measure of the profitability of our residential mortgage 
origination activity. Table 7a presents the information used in 
determining the production margin. 

56 

Wells Fargo & Company 

56

  
 
Insurance income was $429 million in 2018 compared with 

$1.0 billion in 2017 and $1.3 billion in 2016. The decrease in 
both 2018 and 2017 was driven by the sale of Wells Fargo 
Insurance Services in fourth quarter 2017. The decrease in 2017 
was also driven by the divestiture of our crop insurance business 
in first quarter 2016. 

Net gains from trading activities, which reflect unrealized 

changes in fair value of our trading positions and realized gains 
and losses, were $602 million in 2018, compared with 
$542 million in 2017 and $610 million in 2016. The increase in 
2018 was due to growth in equity trading driven by market 
volatility, partially offset by lower foreign exchange trading 
income. The decrease in 2017, compared with 2016, was driven 
by lower customer accommodation trading activity. Net gains 
from trading activities do not include interest and dividend 
income and expense on trading securities. Those amounts are 
reported within interest income from trading assets and other 
interest expense from trading liabilities. For additional 
information about trading activities, see the “Risk Management 
– Asset/Liability Management – Market Risk – Trading 
Activities” section and Note 4 (Trading Activities) to Financial 
Statements in this Report. 

Net gains on debt and equity securities totaled $1.6 billion 

for 2018 and $2.3 billion and $2.0 billion for 2017 and 2016, 
respectively, after other-than-temporary impairment (OTTI) 
write-downs of $380 million, $606 million and $642 million, 
respectively, for the same periods. The decrease in 2018 was 
predominantly driven by lower deferred compensation gains 
(offset in employee benefits expense) and lower net gains on 
debt securities, partially offset by higher net gains from 
nonmarketable equity securities and $313 million of unrealized 
gains from the impact of the new accounting standard for 
financial instruments which requires any gain or loss associated 
with the fair value measurement of equity securities to be 
reflected in earnings. The decrease in OTTI in 2018 was 
predominantly driven by lower write-downs in municipal debt 
securities, commercial mortgage-backed securities and corporate 
debt securities. The decrease in net gains on debt and equity 
securities in 2017, compared with 2016, was driven by lower net 
gains on debt securities, partially offset by higher net gains from 
nonmarketable equity securities. 

Lease income was $1.8 billion in 2018, compared with 
$1.9 billion in 2017, driven by lower rail and equipment lease 
income. Lease income in 2017 was stable compared with 2016. 
All other income was $1.8 billion in 2018, compared with 

$1.0 billion in 2017 and $702 million in 2016. All other income 
includes losses on low income housing tax credit investments, 
foreign currency adjustments, income from investments 
accounted for under the equity method, hedge accounting results 
related to hedges of foreign currency risk, and the results of 
certain economic hedges, any of which can cause decreases and 
net losses in other income. The increase in other income in 2018, 
compared with 2017, was predominantly driven by $2.0 billion 
higher pre-tax gains from the sales of purchased credit-impaired 
(PCI) Pick-a-Pay loans, a pre-tax gain from the sale of Wells 
Fargo Shareowner Services, and gains from the previously 
announced sale of 52 retail branches. The increase was partially 
offset by a gain from the sale of our insurance services business 
in 2017, a realized loss related to the previously announced sale 
of certain assets and liabilities of Reliable Financial Services, Inc. 
(a subsidiary of Wells Fargo’s automobile financing business), 
and a lower benefit from hedge ineffectiveness accounting. The 
increase in other income in 2017 compared with 2016 was driven 
by a $848 million pre-tax gain from the sale of our insurance 
services business in fourth quarter 2017 and a $309 million pre­
tax gain from the sale of a PCI Pick-a-Pay loan portfolio in 
second quarter 2017, as well as the impact of our adoption in 
fourth quarter 2017 of Accounting Standards Update (ASU) 
2017-12 – Derivatives and Hedging (Topic 815): Targeted 
Improvements to Accounting for Hedging Activities, partially 
offset by a gain from the sale of our crop insurance business in 
first quarter 2016 and a gain from the sale of our health benefit 
services business in second quarter 2016. All other income in 
2017 also included $284 million of impairments on low income 
housing investments and $130 million of impairments on tax-
advantaged renewable energy investments in each case due to 
the 2017 Tax Cuts & Jobs Act (Tax Act). 

57

Wells Fargo & Company 

57 

with 2016, due to an increase in deposit assessments as a result 
of the FDIC temporary surcharge which became effective on 
July 1, 2016. See the “Regulation and Supervision” section in our 
2018 Form 10-K for additional information. 

Year ended December 31, 

Operating losses were down $2.4 billion in 2018, compared 

Earnings Performance (continued) 

Noninterest Expense 

Table 8:  Noninterest Expense 

(in millions) 

Salaries 

Commission and incentive 

compensation 

Employee benefits 

Equipment 

Net occupancy 

Core deposit and other intangibles 

FDIC and other deposit 

assessments 

Outside professional services 

Operating losses 

Contract services (1) 

Operating leases 

Advertising and promotion 

Outside data processing 

Travel and entertainment 

Postage, stationery and supplies 

Telecommunications 

Foreclosed assets 

Insurance 

All other (1) 

Total	 

2018 

2017 

2016 

$  17,834 

17,363 

16,552 

10,264 

10,442 

10,247 

4,926 

2,444 

2,888 

1,058 

1,110 

3,306 

3,124 

2,192 

1,334 

857 

660 

618 

515 

361 

188 

101 

5,566 

2,237 

2,849 

1,152 

1,287 

3,813 

5,492 

1,638 

1,351 

614 

891 

687 

544 

364 

251 

100 

5,094 

2,154 

2,855 

1,192 

1,168 

3,138 

1,608 

1,497 

1,329 

595 

888 

704 

622 

383 

202 

179 

2,346 

1,843 

1,970 

$  56,126 

58,484 

52,377 

(1) 	 The periods prior to 2018 have been revised to conform with the current 

period presentation whereby temporary help is included in contract services 
rather than in all other noninterest expense. 

Noninterest expense was $56.1 billion in 2018, down 4% from 
$58.5 billion in 2017, which was up 12% from $52.4 billion in 
2016. The decrease in 2018, compared with 2017, was driven by 
lower operating losses, personnel expenses, outside data 
processing, and FDIC expense, partially offset by higher 
advertising and promotion, equipment, and other expense. The 
increase in 2017, compared with 2016, was predominantly 
driven by higher operating losses, personnel expenses, and 
outside professional and contract services, partially offset by 
lower insurance and postage, stationery and supplies. 

Personnel expenses, which include salaries, commissions, 

incentive compensation and employee benefits, were down 
$347 million, or 1% in 2018, compared with 2017, due to lower 
deferred compensation costs (offset in net gains from equity 
securities), and lower commission and incentive compensation, 
partially offset by salary and minimum pay increases, and higher 
company health plan and retirement plan expenses. Personnel 
expenses were up $1.5 billion, or 5% in 2017, compared with 
2016, due to annual salary increases, higher deferred 
compensation costs (offset in net gains from equity securities), 
and higher employee benefits. 

Equipment expense was up 9% in 2018, compared with 
2017, due to increased computer purchases and equipment 
expense related to the Company’s migration to Windows 10, 
higher software license and maintenance expense, as well as 
higher depreciation expense. Equipment expense was up 4% in 
2017, compared with 2016, primarily due to higher depreciation 
expense. 

FDIC and other deposit assessments were down 14% in 

2018, compared with 2017, due to the completion of the FDIC 
temporary surcharge which ended September 30, 2018. FDIC 
and other deposit assessments were up 10% in 2017, compared 

with 2017, due to lower litigation accruals, partially offset by 
higher remediation accruals for previously disclosed matters. 
Operating losses were up $3.9 billion in 2017, compared with 
2016, predominantly due to higher litigation accruals for a 
variety of matters, including mortgage-related regulatory 
investigations, sales practices, and other consumer-related 
matters. Litigation accruals in 2017 included $3.7 billion that 
were non tax-deductible. 

Outside professional and contract services expense was up 
1% in 2018, compared with 2017, driven by higher project and 
technology spending on regulatory and compliance related 
initiatives. Outside professional and contract services expense 
was up 18% in 2017, compared with 2016, driven by higher 
project and technology spending on regulatory and compliance 
related initiatives, as well as higher legal expense related to sales 
practice matters. 

Outside data processing expense was down 26% in 2018, 
compared with 2017, reflecting lower data processing expense 
related to the GE Capital business acquisitions and the impact of 
the new revenue recognition accounting standard, which 
reduced noninterest expense and lowered card fees by an equal 
amount due to the netting of card payment network charges 
against related interchange and network revenues in card fees. 
Outside data processing expense was relatively stable in 2017, 
compared with 2016. 

Advertising and promotion expense was up 40% in 2018, 

compared with 2017, due to higher advertising expense, 
including expense for the “Re-Established” advertising 
campaign launched in second quarter 2018. Advertising and 
promotion expense was up 3% in 2017, compared with 2016, 
due to higher advertising expense, including higher media and 
production expense, partially offset by lower sales promotion 
expense. 

Foreclosed assets expense was down 25% in 2018, 
compared with 2017, predominantly due to lower operating 
expenses. Foreclosed assets expense was up 24% in 2017, 
compared with 2016, due to lower gains on sales of foreclosed 
properties, partially offset by lower operating expenses. 

Insurance expense was relatively stable in 2018, compared 

with 2017, and was down 44% in 2017, compared with 2016, 
predominantly driven by the sale of our crop insurance business 
in first quarter 2016. 

All other noninterest expense was up 27% in 2018, 
compared with 2017, predominantly due to higher charitable 
donations expense, higher insurance premium payments, a 
pension plan settlement expense, and lower gains on the sale of 
corporate properties. All other noninterest expense was down 
6% in 2017, compared with 2016, due to lower insurance 
premium payments and higher gains on the sale of a corporate 
property, partially offset by higher charitable donations expense. 
All other noninterest expense in 2018 included a $305 million 
contribution to the Wells Fargo Foundation, compared with a 
$199 million contribution in 2017 and a $107 million 
contribution in 2016. 

Our full year 2018 efficiency ratio was 65.0%, compared 

with 66.2% in 2017 and 59.3% in 2016. 

58 

Wells Fargo & Company 

58

  
 
Income Tax Expense 
The 2018 annual effective income tax rate was 20.2%, compared 
with 18.1% in 2017 and 31.5% in 2016. The 2018 effective income 
tax rate reflected the reduction to the U.S. federal income tax 
rate from 35% to 21% resulting from the 2017 Tax Act. It also 
included income tax expense related to non-deductible litigation 
accruals and the reconsideration of reserves for state income 
taxes following the U.S. Supreme Court opinion in South Dakota 
v. Wayfair, Inc. In addition, we recognized $164 million of 
income tax expense associated with the final re-measurement of 
our initial estimates for the impacts of the 2017 Tax Act, in 
accordance with ASC Topic 740, Income Taxes and SEC 
Accounting Bulletin 118. The 2017 effective income tax rate 
included an estimated impact of the Tax Act including a benefit 
of $3.89 billion resulting from the re-measurement of the 
Company’s estimated net deferred tax liability as of 
December 31, 2017, partially offset by $173 million of income tax 
expense for the estimated deemed repatriation of the Company’s 
previously undistributed foreign earnings. The 2017 effective 
income tax rate also included income tax expense of $1.3 billion 
related to the effect of discrete non tax-deductible items, 
predominantly consisting of litigation accruals. The effective 
income tax rate for 2016 included net reductions in reserves for 
uncertain tax positions resulting from settlements with tax 
authorities, partially offset by a net increase in tax benefits 
related to tax credit investments. See Note 23 (Income Taxes) to 
Financial Statements in this Report for additional information 
about our income taxes. 

Table 9:  Operating Segment Results – Highlights 

Operating Segment Results 
We are organized for management reporting purposes into three 
operating segments: Community Banking; Wholesale Banking; 
and Wealth and Investment Management (WIM). These 
segments are defined by product type and customer segment and 
their results are based on our management accounting process, 
for which there is no comprehensive, authoritative financial 
accounting guidance equivalent to generally accepted accounting 
principles (GAAP). Effective first quarter 2018, we adopted a 
new funds transfer pricing methodology to allow for better 
comparability of performance across the Company. Under the 
new methodology, assets and liabilities now receive a funding 
charge or credit that considers interest rate risk, liquidity risk, 
and other product characteristics on a more granular level. This 
methodology change affects results across all three of our 
reportable operating segments and operating segment results for 
periods prior to 2018 have been revised to reflect this 
methodology change. Our previously reported consolidated 
financial results were not impacted by the methodology change; 
however, in connection with our adoption of ASU 2016-01 in 
first quarter 2018, certain reclassifications have occurred within 
noninterest income. Table 9 and the following discussion present 
our results by operating segment. For additional description of 
our operating segments, including additional financial 
information and the underlying management accounting 
process, see Note 26 (Operating Segments) to Financial 
Statements in this Report. 

(in millions, except average balances which are in billions) 

2018 

Revenue 

Provision (reversal of provision) for credit losses 

Net income (loss) 

Average loans 

Average deposits 

2017 

Revenue 

Provision (reversal of provision) for credit losses 

Net income (loss) 

Average loans 

Average deposits 

2016 

Revenue 

Provision (reversal of provision) for credit losses 

Net income (loss) 

Average loans 

Average deposits 

Community
Banking 

Wholesale 

Wealth and 
Investment 
Banking  Management 

Other (1) 

Consolidated 
Company 

Year ended December 31, 

$ 

46,913 

28,706 

16,376 

(5,587) 

86,408 

1,783 

(58) 

10,394 

11,032 

$ 

463.7 

757.2 

465.7 

423.7 

(5)

2,580 

74.6 

165.0 

 24

 1,744 

(1,613) 

22,393 

(58.8) 

(70.0) 

945.2
 

1,275.9
 

$ 

47,018 

30,000 

17,072 

(5,701) 

2,555 

10,938 

475.7 

729.6 

$ 

(19) 

9,914 

465.6 

464.2 

(5) 

2,770 

71.9 

189.0 

(3) 

(1,439) 

(57.1) 

(78.2) 

$ 

46,513 

31,047 

16,278 

(5,571) 

2,691 

10,818 

485.2 

703.6 

$ 

1,073 

9,942 

451.0 

436.2 

(5) 

2,637 

67.3 

189.7 

11 

(1,459) 

(53.5) 

(78.9) 

88,389 

2,528 

22,183 

956.1
 

1,304.6
 

88,267 

3,770 

21,938 

950.0
 

1,250.6
 

(1) 

Includes the elimination of certain items that are included in more than one business segment, most of which represents products and services for WIM customers served 
through Community Banking distribution channels. 

59

Wells Fargo & Company 

59 

 
  
Earnings Performance (continued) 

Community Banking offers a complete line of diversified 
financial products and services for consumers and small 
businesses including checking and savings accounts, credit and 
debit cards, and automobile, student, mortgage, home equity 
and small business lending, as well as referrals to Wholesale 
Banking and WIM business partners. The Community Banking 
segment also includes the results of our Corporate Treasury 
activities net of allocations (including funds transfer pricing, 

Table 9a:  Community Banking 

capital, liquidity and certain corporate expenses) in support of 
other segments and results of investments in our affiliated 
venture capital and private equity partnerships. We continue to 
wind down the personal insurance business and expect to 
substantially complete these activities in the first half of 2019. 
Table 9a provides additional financial information for 
Community Banking. 

(in millions, except average balances which are in billions) 

2018 

2017  % Change 

2016  % Change 

Year ended December 31, 

$  29,219 

28,658 

2%  $  27,333 

5% 

2,641 

2,909 

(9) 

3,111 

Brokerage advisory, commissions and other fees (1) 

1,887 

1,830 

Net interest income 

Noninterest income: 

Service charges on deposit accounts 

Trust and investment fees: 

Trust and investment management (1) 

Investment banking (2) 

Total trust and investment fees 

Card fees 

Other fees 

Mortgage banking 

Insurance 

Net gains (losses) from trading activities 

Net gains (losses) on debt securities 

Net gains from equity securities (3) 

Other income of the segment 

Total noninterest income 

Total revenue 

Provision for credit losses 

Noninterest expense: 

Personnel expense 

Equipment 

Net occupancy 

Core deposit and other intangibles 

FDIC and other deposit assessments 

Outside professional services 

Operating losses 

Other expense of the segment 

Total noninterest expense 

910 

(35) 

2,762 

3,543 

1,359 

2,659 

83 

28 

(3) 

1,505 

3,117 

889 

(59) 

2,660 

3,613 

1,497 

3,895 

139 

(251) 

709 

1,455 

1,734 

17,694 

18,360 

21,252 

20,381 

2,356 

2,166 

404 

624 

1,560 

2,656 

2,157 

2,111 

446 

715 

1,875 

5,312 

(527) 

(382) 

30,491 

32,615 

3 

2 

41 

4 

(2) 

(9) 

(32) 

(40) 

111 

NM 

3 

80 

(4) 

1,854 

849 

(141) 

2,562 

3,598 

1,636 

5,624 

112 

(148) 

933 

804 

948 

19,180 

4 

9 

3 

(9) 

(13) 

(17) 

(50) 

(38) 

(7) 

24 

497 

67 

19,382 

2,040 

2,114 

505 

651 

1,264 

1,454 

245 

27,655 

16,167 

5,213 

136 

46,913 

47,018 

— 

46,513 

1,783 

2,555 

(30) 

2,691 

(6) 

(1) 

5 

58 

4 

— 

(8) 

(31) 

24 

(70) 

(24) 

81 

83 

(4) 

1 

(5) 

5 

6 

— 

(12) 

10 

48 

265 

NM 

18 

(27) 

(88) 

103 

1 

(2) 

4 

Income before income tax expense and noncontrolling interests 

14,639 

11,848 

Income tax expense 

Net income from noncontrolling interests (4) 

3,784 

461 

634 

276 

Net income 

Average loans 

Average deposits 

$  10,394 

10,938 

(5) 

$  10,818 

$  463.7 

757.2 

475.7 

729.6 

(3)  $ 

485.2 

4 

703.6 

NM - Not meaningful 
(1)  Represents income on products and services for WIM customers served through Community Banking distribution channels and is eliminated in consolidation. 
(2) 
(3)  Largely represents gains resulting from venture capital investments. 
(4)  Reflects results attributable to noncontrolling interests predominantly associated with the Company’s consolidated venture capital investments. 

Includes syndication and underwriting fees paid to Wells Fargo Securities which are offset in our Wholesale Banking segment. 

60 

Wells Fargo & Company 

60

The provision for credit losses in 2018 decreased 
$772 million from 2017 due to credit improvement in the 
consumer real estate and automobile portfolios. The provision 
for credit losses in 2017 decreased $136 million from 2016 due to 
credit improvement in the consumer real estate portfolio. 

Income tax expense was $3.8 billion in 2018, up $3.2 billion 

from $634 million in 2017, which was down $4.6 billion from 
2016. Income tax expense in 2018 included the adverse impact 
of non-deductible litigation accruals, the reconsideration of 
reserves for state income taxes following the U.S. Supreme Court 
opinion in South Dakota v. Wayfair, Inc., and the expense 
associated with the final re-measurement of our initial estimates 
for the impacts of the 2017 Tax Act. Income tax expense in 2017 
included the estimated net benefit from the impact of the 2017 
Tax Act to the Company, partially offset by the impact of discrete 
non tax-deductible items, predominantly litigation accruals. 

Community Banking reported net income of $10.4 billion in 

2018, down $544 million, or 5%, from $10.9 billion in 2017, 
which was up $120 million, or 1%, from 2016. Revenue was 
$46.9 billion in 2018, down $105 million from $47.0 billion in 
2017, which was up $505 million, or 1%, compared with 2016. 
The decrease in revenue in 2018 was due to lower mortgage 
banking revenue driven by lower mortgage loan originations and 
a decrease in servicing income, lower gains on debt securities, 
lower service charges on deposit accounts, and lower other fees. 
These decreases were partially offset by higher other income, 
including gains from the sales of PCI mortgage loans and the sale 
of 52 branches, and higher net interest income. The increase in 
revenue in 2017 was due to higher net interest income, higher 
gains on equity securities, higher deferred compensation plan 
investment results (offset in employee benefits expense), and 
higher other income (including higher net hedge ineffectiveness 
income and a gain on the sale of PCI mortgage loans), partially 
offset by lower mortgage banking revenue, lower gains on debt 
securities, and lower service charges on deposit accounts.

 Average deposits increased $27.6 billion in 2018, or 4%, 
from 2017, which increased $26.0 billion, or 4%, from 2016. 

Noninterest expense of $30.5 billion decreased $2.1 billion 
in 2018, or 7%, from 2017, which increased $5.0 billion, or 18%, 
from 2016. The decrease in 2018 was predominantly driven by 
lower operating losses due to lower litigation accruals, partially 
offset by higher outside professional and contract services 
expense driven by project and technology spending on 
regulatory and compliance-related initiatives. The increase in 
2017 was substantially due to higher operating losses driven by 
higher litigation accruals, higher personnel expense, and higher 
outside professional services, partially offset by lower foreclosed 
assets expense driven by improvement in the residential real 
estate portfolio, lower telephone and supplies expenses, and 
lower other expense. 

61

Wells Fargo & Company 

61 

 
Earnings Performance (continued) 

Wholesale Banking provides financial solutions to businesses 
across the United States and globally with annual sales generally 
in excess of $5 million. Products and businesses include 
Commercial Banking, Commercial Real Estate, Corporate and 

Investment Banking, Credit Investment Portfolio, Treasury 
Management, and Commercial Capital. Table 9b provides 
additional financial information for Wholesale Banking. 

Table 9b:  Wholesale Banking 

(in millions, except average balances which are in billions) 

2018 

2017  % Change 

2016  % Change 

Year ended December 31, 

$  18,690 

18,810 

(1)%  $  18,699 

1% 

2,074 

2,201 

(6) 

2,260 

(3) 

Net interest income 

Noninterest income: 

Service charges on deposit accounts 

Trust and investment fees: 

Brokerage advisory, commissions and other fees 

Trust and investment management 

Investment banking 

Total trust and investment fees 

Card fees 

Other fees 

Mortgage banking 

Insurance 

Net gains from trading activities 

Net gains (losses) on debt securities 

Net gains from equity securities 

Other income of the segment 

Total noninterest income 

317 

445 

1,783 

2,545 

362 

2,019 

362 

312 

516 

102 

293 

1,431 

304 

523 

1,827 

2,654 

345

2,054 

458 

872 

701 

(232) 

116 

2,021 

10,016 

11,190 

4 

(15) 

(2) 

(4) 

5 

(2) 

(21) 

(64) 

(26) 

144 

153 

(29) 

(10) 

368 

473 

1,833 

2,674 

336 

2,085 

475 

1,156 

677 

8 

199 

2,478 

12,348 

Total revenue 

28,706 

30,000 

(4) 

31,047 

Provision (reversal of provision) for credit losses 

(58) 

(19)

 NM 

1,073 

Noninterest expense: 

Personnel expense 

Equipment 

Net occupancy 

Core deposit and other intangibles 

FDIC and other deposit assessments 

Outside professional services 

Operating losses 

Other expense of the segment 

Total noninterest expense 

5,567 

6,603 

48 

403 

378 

419 

958 

246 

8,138 

55 

425 

414 

481 

1,134 

74 

7,438 

16,157 

16,624 

Income before income tax expense and noncontrolling interest 

12,607 

13,395 

Income tax expense 

Net income (loss) from noncontrolling interest 

Net income 

Average loans 

Average deposits 

NM - Not meaningful 

1,555 

3,496 

20 

(15) 

$  11,032 

$  465.7 

423.7 

9,914 

465.6 

464.2 

(16) 

(13) 

(5) 

(9) 

(13) 

(16) 

232 

9 

(3) 

(6) 

(56) 

233 

11 

— 

(9) 

6,456 

68 

423 

385 

428 

989 

115 

7,037 

15,901 

14,073 

4,159 

(28)

9,942 

451.0 

436.2 

$ 

$ 

(17) 

11 

— 

(1) 

3
 

(1)
 

(4)
 

(25)
 

4
 

NM
 

(42)
 

(18)
 

(9) 

(3) 

NM 

2 

(19) 

— 

8 

12 

15 

(36) 

6 

5 

(5) 

(16)
 

 46

— 

3
 

6
 

62 

Wells Fargo & Company 

62

 
  


 
Noninterest expense of $16.2 billion in 2018 decreased 
$467 million, or 3%, compared with 2017, which increased 
$723 million, or 5%, compared with 2016. The decrease in 2018 
was primarily due to lower personnel expense related to the sale 
of WFIS and lower variable compensation, lower project related 
spending, and lower FDIC expense, partially offset by higher 
operating losses and increased regulatory, risk, cyber and 
technology expenses. The increase in 2017 was predominantly 
due to increased project and technology spending on compliance 
and regulatory requirements. The provision for credit losses in 
2018 decreased $39 million from 2017, from lower losses. The 
provision for credit losses in 2017 decreased from $1.1 billion in 
2016, predominantly due to lower losses in the oil and gas 
portfolio. 

Wealth and Investment Management provides a full range 
of personalized wealth management, investment and retirement 
products and services to clients across U.S. based businesses 
including Wells Fargo Advisors, The Private Bank, Abbot 
Downing, Wells Fargo Institutional Retirement and Trust, and 
Wells Fargo Asset Management. We deliver financial planning, 
private banking, credit, investment management and fiduciary 
services to high-net worth and ultra-high-net worth individuals 
and families. We also serve clients’ brokerage needs, supply 
retirement and trust services to institutional clients and provide 
investment management capabilities delivered to global 
institutional clients through separate accounts and the 
Wells Fargo Funds. Table 9c provides additional financial 
information for WIM. 

Wholesale Banking reported net income of $11.0 billion in 

2018, up $1.1 billion from 2017, which was down $28 million 
from 2016. The increase in 2018 was due to the reduced U.S. 
federal statutory income tax rate as well as lower noninterest 
expense, partially offset by lower revenue. The decrease in 2017 
compared with 2016 was due to lower noninterest income and 
higher noninterest expense, partially offset by higher net interest 
income and lower loan loss provision. Revenue in 2018 of 
$28.7 billion decreased $1.3 billion, or 4%, from 2017, which 
decreased $1.0 billion, or 3%, from 2016. Net interest income of 
$18.7 billion in 2018 decreased $120 million, or 1%, from 2017, 
which increased $111 million, or 1%, from 2016. The decrease in 
net interest income in 2018 was due to lower income on trading 
assets, debt securities, and loans, partially offset by the impact of 
higher interest rates and the increased income on leveraged 
leases related to the basis adjustment in 2017 associated with the 
Tax Act. The increase in net interest income in 2017 was due to 
strong deposit growth and the impact of rising interest rates, 
partially offset by lower income on debt securities and trading 
assets as well as the 2017 leveraged lease adjustment. 

Average loans of $465.7 billion in 2018 were relatively flat 
compared with 2017, which increased $14.6 billion, or 3%, from 
2016. Loan growth in 2018 from commercial and industrial 
loans was substantially offset by declines in commercial real 
estate loans. Loan growth in 2017 was broad based across many 
Wholesale Banking businesses and included the impact of the 
GE Capital business acquisitions in 2016. Average deposits of 
$423.7 billion in 2018 decreased $40.5 billion, or 9%, which 
increased $28 billion, or 6%, from 2016. The decline in 2018 was 
driven by actions taken in the first half of 2018 in response to the 
asset cap included in the FRB consent order on 
February 2, 2018, and declines across many businesses as 
commercial customers allocated more cash to higher-rate 
alternatives. 

Noninterest income of $10.0 billion in 2018 decreased 
$1.2 billion, or 10%, from 2017, which decreased $1.2 billion, or 
9%, from 2016. The decrease in 2018 was driven by the impact of 
the 2017 sale of Wells Fargo Insurance Services USA (WFIS), as 
well as lower trading, operating lease income, service charges on 
deposits and mortgage banking fees, partially offset by losses 
taken in fourth quarter 2017 from adjustments to tax advantaged 
businesses due to the Tax Act as well as the gain on the sale of 
Wells Fargo Shareowner Services in 2018. The decrease in 2017, 
compared with 2016, was driven by the gains on the sale of our 
crop insurance and health benefit services businesses in 2016, 
impairments to low income housing and renewable energy 
investments as a result of the Tax Act, lower insurance income 
driven by the 2016 sale of our crop insurance business, and 
lower gains on debt and equity securities. These declines were 
partially offset by a gain on the sale of our insurance services 
business in 2017. 

63

Wells Fargo & Company 

63 

Earnings Performance (continued) 

Table 9c:  Wealth and Investment Management 

(in millions, except average balances which are in billions) 

2018 

2017  % Change 

2016  % Change 

Year ended December 31, 

Net interest income 

Noninterest income: 

Service charges on deposit accounts 

Trust and investment fees: 

Brokerage advisory, commissions and other fees 

Trust and investment management 

Investment banking (1) 

Total trust and investment fees 

Card fees 

Other fees 

Mortgage banking 

Insurance 

Net gains from trading activities 

Net gains on debt securities 

Net gains (losses) from equity securities 

Other income of the segment 

Total noninterest income 

Total revenue 

Reversal of provision for credit losses 

Noninterest expense: 

Personnel expense 

Equipment 

Net occupancy 

Core deposit and other intangibles 

FDIC and other deposit assessments 

Outside professional services 

Operating losses 

Other expense of the segment 

Total noninterest expense 

Income before income tax expense and noncontrolling interest 

Income tax expense 

Net income (loss) from noncontrolling interest 

Net income 

Average loans 

Average deposits 

$  4,441 

4,641 

(4)%  $ 

4,249 

9% 

16 

17 

(6) 

19 

(11) 

9,161 

2,893 

9 

9,072 

2,877 

1 

1 

8,870 

2,891 

2 

— 

(2) 

550 

(1) 

(100) 

12,063 

11,947 

6 

17 

(11) 

82 

57 

9 

(283) 

(21) 

6 

18 

(10)

88 

92 

2 

208 

63 

11,935 

12,431 

16,376 

17,072 

(5) 

(5) 

8,085 

8,126 

42 

440 

276 

116 

815 

232 

2,932 

12,938 

3,443 

861 

2 

$  2,580 

$ 

74.6 

165.0 

28 

431 

292 

154 

834 

115 

2,643 

12,623 

4,454 

1,668 

16 

2,770 

71.9 

189.0 

1 

— 

(6) 

 (10)

(7) 

(38) 

350 

NM 

NM 

(4) 

(4) 

— 

(1) 

50 

2 

(5) 

(25) 

(2) 

102 

11 

2 

(23) 

(48) 

(88) 

(7) 

4 

(13) 

11,760 

6 

18 

(9)

— 

81 

1 

100 

53 

12,029 

16,278 

(5) 

7,704 

51 

436 

302 

152 

916 

50 

2,440 

12,051 

4,232 

1,596 

(1) 

2,637 

67.3 

189.7 

$ 

$ 

2 

— 

— 

  (11)

NM 

14 

100 

108 

19 

3 

5 

— 

5 

(45) 

(1) 

(3) 

1 

(9) 

130 

8 

5 

5 

5 

NM 

5 

7 

— 

NM - Not meaningful 
(1) 

Includes syndication and underwriting fees paid to Wells Fargo Securities which are offset in our Wholesale Banking segment. 

WIM reported net income of $2.6 billion in 2018, down 

$190 million, or 7%, from 2017, which was up $133 million, or 
5%, from 2016. Revenue of $16.4 billion in 2018 decreased 
$696 million from 2017, which was up $794 million from 2016. 
The decrease in revenue in 2018 was due to lower noninterest 
income and net interest income. The increase in revenue in 2017 
was due to growth in net interest income and asset-based fees. 
Net interest income decreased 4% in 2018 primarily due to lower 
deposit balances, partially offset by higher interest rates. Net 
interest income increased 9% in 2017 predominantly due to 
higher interest rates. Average loan balances of $74.6 billion in 
2018 increased $2.7 billion from $71.9 billion in 2017, which was 
up 7% from 2016. Average deposits of $165.0 billion in 2018 
decreased 13% from $189.0 billion in 2017, which was relatively 
flat compared with 2016. Noninterest income in 2018 decreased 
4% from 2017 due to net losses from equity securities on lower 
deferred compensation plan investment results (offset in 
employee benefits expense), the impairment on the sale of our 
ownership stake in RockCreek, and lower transaction revenue, 
partially offset by higher asset-based fees. 

Noninterest income in 2017 increased 3% from 2016 due to 
higher asset-based fees and gains on deferred compensation 
plan investments (offset in employee benefits expense), partially 
offset by lower transaction revenue. Noninterest expense of 
$12.9 billion in 2018 increased 2% from $12.6 billion in 2017 due 
to higher project and technology spending on compliance and 
regulatory requirements, higher broker commissions, higher 
operating losses and higher other personnel expense, partially 
offset by lower employee benefits from deferred compensation 
plan expense (offset in deferred compensation plan 
investments). Noninterest expense of $12.6 billion in 2017 
increased 5% from $12.1 billion in 2016 due to higher project 
and technology spending on compliance and regulatory 
requirements, higher broker commissions, and higher employee 
benefits from deferred compensation plan expense (offset in 
deferred compensation plan investments). The provision for 
credit losses was flat in both 2018 and 2017. 

64 

Wells Fargo & Company 

64

  
 
 
The following discussions provide additional information 

for client assets we oversee in our retail brokerage advisory and 
trust and investment management business lines. 

Retail Brokerage Client Assets Brokerage advisory, 
commissions and other fees are received for providing full-
service and discount brokerage services predominantly to retail 
brokerage clients. Offering advisory account relationships to our 
brokerage clients is an important component of our broader 
strategy of meeting their financial needs. Although a majority of 
our retail brokerage client assets are in accounts that earn 
brokerage commissions, the fees from those accounts generally 

Table 9d:  Retail Brokerage Client Assets 

(in billions) 

Retail brokerage client assets 

Advisory account client assets 

Advisory account client assets as a percentage of total client assets 

Retail Brokerage advisory accounts include assets that are 

financial advisor-directed and separately managed by third-
party managers, as well as certain client-directed brokerage 
assets where we earn a fee for advisory and other services, but do 
not have investment discretion. These advisory accounts 
generate fees as a percentage of the market value of the assets as 
of the beginning of the quarter, which vary across the account 
types based on the distinct 

Table 9e:  Retail Brokerage Advisory Account Client Assets 

represent transactional commissions based on the number and 
size of transactions executed at the client’s direction. Fees 
earned from advisory accounts are asset-based, are priced at the 
beginning of the quarter, and depend on changes in the value of 
the client’s assets as well as the level of assets resulting from 
inflows and outflows. A majority of our brokerage advisory, 
commissions and other fee income is earned from advisory 
accounts. Table 9d shows advisory account client assets as a 
percentage of total retail brokerage client assets at December 31, 
2018, 2017 and 2016. 

Year ended December 31, 

2018 

$ 

1,487.6 

501.1 

34% 

2017 

1,651.3 

542.8 

33 

2016 

1,486.1 

463.8 

31 

services provided, and are affected by investment performance 
as well as asset inflows and outflows. For the years ended 
December 31, 2018, 2017 and 2016, the average fee rate by 
account type ranged from 80 to 120 basis points. Table 9e 
presents retail brokerage advisory account client assets activity 
by account type for the years ended December 31, 2018, 2017 
and 2016. 

(in billions) 

December 31, 2018 

Client directed (4) 

Financial advisor directed (5) 

Separate accounts (6) 

Mutual fund advisory (7) 

Total advisory client assets	 

December 31, 2017 

Client directed (4) 

Financial advisor directed (5) 

Separate accounts (6) 

Mutual fund advisory (7) 

Total advisory client assets	 

December 31, 2016 

Client directed (4) 

Financial advisor directed (5) 

Separate accounts (6) 

Mutual fund advisory (7) 

Total advisory client assets	 

Balance, beginning
of period 

Inflows (1) 

Outflows (2) 

Market impact (3) 

Year ended 

Balance, end 
of period 

$ 

$ 

$ 

$ 

$ 

$ 

170.9 

147.0 

149.1 

75.8 

542.8 

159.1 

115.7 

125.7 

63.3 

463.8 

154.7 

91.9 

110.4 

62.9 

419.9 

33.6 

30.0 

23.8 

12.8 

(41.0) 

(32.9) 

(29.1) 

(13.8) 

100.2 

(116.8) 

37.1 

30.6 

26.1 

13.1 

106.9 

36.0 

28.6 

26.0 

8.7 

99.3 

(39.2) 

(24.5) 

(23.5) 

(11.1) 

(98.3) 

(37.5) 

(18.7) 

(21.9) 

(11.6) 

(89.7) 

(12.0) 

(2.2) 

(7.4) 

(3.5) 

(25.1) 

13.9 

25.2 

20.8 

10.5 

70.4 

5.9 

13.9 

11.2 

3.3 

34.3 

151.5 

141.9 

136.4 

71.3 

501.1 

170.9 

147.0 

149.1 

75.8 

542.8 

159.1 

115.7 

125.7 

63.3 

463.8 

(1) 	 Inflows include new advisory account assets, contributions, dividends and interest. 
(2) 	 Outflows include closed advisory account assets, withdrawals and client management fees. 
(3) 	 Market impact reflects gains and losses on portfolio investments. 
(4) 	 Investment advice and other services are provided to client, but decisions are made by the client and the fees earned are based on a percentage of the advisory account 

assets, not the number and size of transactions executed by the client. 

(5) 	 Professionally managed portfolios with fees earned based on respective strategies and as a percentage of certain client assets. 
(6) 	 Professional advisory portfolios managed by Wells Fargo Asset Management advisors or third-party asset managers. Fees are earned based on a percentage of certain client 

assets. 

(7) 	 Program with portfolios constructed of load-waived, no-load and institutional share class mutual funds. Fees are earned based on a percentage of certain client assets. 

65

Wells Fargo & Company 

65 

  
  
Earnings Performance (continued) 

Trust and Investment Client Assets Under Management 
We earn trust and investment management fees from managing 
and administering assets, including mutual funds, institutional 
separate accounts, personal trust, employee benefit trust and 
agency assets through our asset management, wealth and 
retirement businesses. Our asset management business is 
conducted by Wells Fargo Asset Management (WFAM), which 
offers Wells Fargo proprietary mutual funds and manages 
institutional separate accounts. Our wealth business manages 
assets for high net worth clients, and our retirement business 

Table 9f:  WIM Trust and Investment – Assets Under Management 

provides total retirement management, investments, and trust 
and custody solutions tailored to meet the needs of institutional 
clients. Substantially all of our trust and investment 
management fee income is earned from AUM where we have 
discretionary management authority over the investments and 
generate fees as a percentage of the market value of the AUM. 
Table 9f presents AUM activity for the years ended December 31, 
2018, 2017 and 2016. 

(in billions) 

December 31, 2018 

Assets managed by WFAM (4): 

Money market funds (5) 

Other assets managed 

Assets managed by Wealth and Retirement (6) 

Total assets under management 

December 31, 2017 

Assets managed by WFAM (4): 

Money market funds (5) 

Other assets managed 

Assets managed by Wealth and Retirement (6)	 

Total assets under management 

December 31, 2016 

Assets managed by WFAM (4): 

Money market funds (5) 

Other assets managed 

Assets managed by Wealth and Retirement (6)	 

Total assets under management 

Balance, beginning
of period 

Inflows (1) 

Outflows (2) 

Market impact (3) 

Year ended 

Balance, end of
period 

$ 

$ 

$ 

$ 

$ 

$ 

108.2 

395.7 

186.2 

690.1 

102.6 

379.6 

168.5 

650.7 

123.6 

366.1 

162.1 

651.8 

4.2 

85.5 

36.3 

126.0 

5.6 

116.0 

41.1 

162.7 

— 

114.0 

37.0 

151.0 

— 

(120.2) 

(39.5) 

(159.7) 

— 

(130.9) 

(39.4) 

(170.3) 

(21.0) 

(125.0) 

(35.9) 

(181.9) 

— 

(7.5) 

(12.3) 

(19.8) 

— 

31.0 

16.0 

47.0 

— 

24.5 

5.3 

29.8 

112.4 

353.5 

170.7 

636.6 

108.2 

395.7 

186.2 

690.1 

102.6 

379.6 

168.5 

650.7 

(1) 	 Inflows include new managed account assets, contributions, dividends and interest. 
(2) 	 Outflows include closed managed account assets, withdrawals and client management fees. 
(3) 	 Market impact reflects gains and losses on portfolio investments. 
(4) 	 Assets managed by WFAM consist of equity, alternative, balanced, fixed income, money market, and stable value, and include client assets that are managed or sub-

advised on behalf of other Wells Fargo lines of business. 

(5) 	 Money Market funds activity is presented on a net inflow or net outflow basis, because the gross flows are not meaningful nor used by management as an indicator of 

performance. 

(6) 	 Includes $4.9 billion, $5.5 billion and $6.9 billion as of December 31, 2018, 2017 and 2016, respectively, of client assets invested in proprietary funds managed by WFAM. 

66 

Wells Fargo & Company 

66

 
  
Balance Sheet Analysis
 

At December 31, 2018, our assets totaled $1.9 trillion, down 
$55.9 billion from December 31, 2017. Asset decline was 
predominantly due to interest-earning deposits with banks, 
which declined $42.8 billion. 

The following discussion provides additional information 
about the major components of our balance sheet. Information 

regarding our capital and changes in our asset mix is included in 
the “Earnings Performance – Net Interest Income” and “Capital 
Management” sections and Note 28 (Regulatory and Agency 
Capital Requirements) to Financial Statements in this Report. 

Available-for-Sale and Held-to-Maturity Debt Securities 

Table 10:  Available-for-Sale and Held-to-Maturity Debt Securities 

(in millions) 

Available-for-sale 

Held-to-maturity 

Total (1) 

December 31, 2018 

December 31, 2017 

Amortized 

Net 
unrealized 
Cost  gain (loss) 

Fair 
value 

Amortized 
Cost 

Net 
unrealized 
gain (loss) 

Fair 
value 

$  272,471 

(2,559) 

269,912 

144,788 

(2,673) 

142,115 

417,259 

(5,232) 

412,027 

275,096 

139,335 

414,431 

1,311 

276,407
 

(350) 

138,985
 

961 

415,392 

(1)  Available-for-sale debt securities are carried on the balance sheet at fair value. Held-to-maturity debt securities are carried on the balance sheet at amortized cost. 

Table 10 presents a summary of our available-for-sale and 

The held-to-maturity debt securities portfolio consists of 

held-to-maturity debt securities, which decreased $1.0 billion in 
balance sheet carrying value from December 31, 2017, largely 
due to higher net unrealized losses, partially offset by purchases 
outpacing paydowns and maturities. 

The total net unrealized losses on available-for-sale debt 
securities were $2.6 billion at December 31, 2018, down from net 
unrealized gains of $1.3 billion at December 31, 2017, primarily 
due to higher interest rates and wider credit spreads. 

The size and composition of our available-for-sale and held­

to-maturity debt securities is largely dependent upon the 
Company’s liquidity and interest rate risk management 
objectives. Our business generates assets and liabilities, such as 
loans, deposits and long-term debt, which have different 
maturities, yields, re-pricing, prepayment characteristics and 
other provisions that expose us to interest rate and liquidity risk. 

The available-for-sale debt securities portfolio 

predominantly consists of liquid, high quality U.S. Treasury and 
federal agency debt, agency mortgage-backed securities (MBS), 
privately-issued residential and commercial MBS, securities 
issued by U.S. states and political subdivisions, corporate debt 
securities, and highly rated collateralized loan obligations. Due 
to its highly liquid nature, the available-for-sale debt securities 
portfolio can be used to meet funding needs that arise in the 
normal course of business or due to market stress. Changes in 
our interest rate risk profile may occur due to changes in overall 
economic or market conditions, which could influence loan 
origination demand, prepayment speeds, or deposit balances 
and mix. In response, the available-for-sale debt securities 
portfolio can be rebalanced to meet the Company’s interest rate 
risk management objectives. In addition to meeting liquidity and 
interest rate risk management objectives, the available-for-sale 
debt securities portfolio may provide yield enhancement over 
other short-term assets. See the “Risk Management – Asset/ 
Liability Management” section in this Report for more 
information on liquidity and interest rate risk. 

high quality U.S. Treasury debt, securities issued by U.S. states 
and political subdivisions, agency MBS, asset-backed securities 
(ABS) primarily collateralized by automobile loans and leases 
and cash, and collateralized loan obligations where our intent is 
to hold these securities to maturity and collect the contractual 
cash flows. The held-to-maturity debt securities portfolio may 
also provide yield enhancement over short-term assets. 

We analyze debt securities for other-than-temporary 
impairment (OTTI) quarterly or more often if a potential loss-
triggering event occurs. In 2018, we recognized $28 million of 
OTTI write-downs on debt securities. For a discussion of our 
OTTI accounting policies and underlying considerations and 
analysis, see Note 1 (Summary of Significant Accounting 
Policies) and Note 5 (Available-for-Sale and Held-to-Maturity 
Debt Securities) to Financial Statements in this Report. 

At December 31, 2018, debt securities included $55.6 billion 

of municipal bonds, of which 93.4% were rated “A-” or better 
based predominantly on external and, in some cases, internal 
ratings. Additionally, some of the debt securities in our total 
municipal bond portfolio are guaranteed against loss by bond 
insurers. These guaranteed bonds are predominantly investment 
grade and were generally underwritten in accordance with our 
own investment standards prior to the determination to 
purchase, without relying on the bond insurer’s guarantee in 
making the investment decision. The credit quality of our 
municipal bond holdings are monitored as part of our ongoing 
impairment analysis. 

The weighted-average expected maturity of debt securities 

available-for-sale was 6.2 years at December 31, 2018. The 
expected remaining maturity is shorter than the remaining 
contractual maturity for the 59.4% of this portfolio that is MBS 
because borrowers generally have the right to prepay obligations 
before the underlying mortgages mature. The estimated effects 
of a 200 basis point increase or decrease in interest rates on the 
fair value and the expected remaining maturity of the MBS 
available-for-sale portfolio are shown in Table 11. 

67

Wells Fargo & Company 

67 

  
 
 
 
Balance Sheet Analysis (continued) 

Table 11:  Mortgage-Backed Securities Available for Sale 

(in billions) 

At December 31, 2018 

Fair 
value 

Net 
unrealized 
gain (loss) 

Expected
remaining
maturity 
(in years) 

Actual 

160.2 

(2.6) 

5.8 

Assuming a 200 basis point: 

Increase in interest rates 

Decrease in interest rates 

143.3 

171.7 

(19.5) 

8.9 

7.8 

3.1 

The weighted-average expected maturity of debt securities 

held-to-maturity was 5.6 years at December 31, 2018. See Note 5 
(Available-for-Sale and Held-to-Maturity Debt Securities) to 
Financial Statements in this Report for a summary of debt 
securities by security type. 

Table 12:  Loan Portfolios 

(in millions) 

Commercial 

Consumer 

Total loans 

Change from prior year 

Loan Portfolios 
Table 12 provides a summary of total outstanding loans by 
portfolio segment. Total loans decreased $3.7 billion from 
December 31, 2017, driven by a decline in consumer loans, 
partially offset by an increase in commercial loans. Commercial 
loan growth reflected growth in commercial and industrial loans, 
partially offset by a decline in commercial real estate loans 
reflecting continued credit discipline. The decrease in consumer 
loans reflected paydowns, sales of 1-4 family first mortgage PCI 
Pick-a-Pay loans, a continued decline in junior lien mortgage 
loans, the sale of Reliable Financial Services, Inc., and an 
expected decline in automobile loans as originations were more 
than offset by paydowns. 

December 31, 2018 

December 31, 2017 

$ 

$ 

513,405 

439,705 

953,110 

(3,660) 

503,388 

453,382 

956,770 

(10,834) 

A discussion of average loan balances and a comparative 

detail of average loan balances is included in Table 5 under 
“Earnings Performance – Net Interest Income” earlier in this 
Report. Additional information on total loans outstanding by 
portfolio segment and class of financing receivable is included in 
the “Risk Management – Credit Risk Management” section in 
this Report. Period-end balances and other loan related 

Table 13:  Maturities for Selected Commercial Loan Categories 

information are in Note 6 (Loans and Allowance for Credit 
Losses) to Financial Statements in this Report. 

Table 13 shows contractual loan maturities for loan 
categories normally not subject to regular periodic principal 
reduction and the contractual distribution of loans in those 
categories to changes in interest rates. 

(in millions) 

Selected loan maturities: 

December 31, 2018 

December 31, 2017 

Within 
one 
year 

After 
one year
through
five years 

After 
five 
years 

Total 

Within 
one 
year 

After 
one year 
through
five years 

After 
five 
years 

Total 

Commercial and industrial 

$ 109,566 

213,425 

27,208 

350,199 

105,327 

201,530 

26,268 

333,125 

Real estate mortgage 

Real estate construction 

16,413 

63,648 

40,953 

121,014 

20,069 

64,384 

42,146 

126,599 

9,958 

11,343 

1,195 

22,496 

9,555 

13,276 

1,448 

24,279 

Total selected loans 

$ 135,937 

288,416 

69,356 

493,709 

134,951 

279,190 

69,862 

484,003 

Distribution of loans to changes in interest 

rates: 

Loans at fixed interest rates 

$  17,619 

28,545 

28,163 

74,327 

18,587 

30,049 

26,748 

75,384 

Loans at floating/variable interest rates 

118,318 

259,871 

41,193 

419,382 

116,364 

249,141 

43,114 

408,619 

Total selected loans 

$ 135,937 

288,416 

69,356 

493,709 

134,951 

279,190 

69,862 

484,003 

68 

Wells Fargo & Company 

68

  
 
 
  
 
  
 
Deposits 
Deposits were $1.3 trillion at December 31, 2018, down 
$49.8 billion from December 31, 2017, due to a decrease in 
commercial deposits from financial institutions and a decline in 
consumer and small business banking deposits. The decline in 
commercial deposits from financial institutions was due to 
actions taken in the first half of 2018 in response to the asset cap 
included in the consent order issued by the FRB on 
February 2, 2018, and declines across many businesses as 

commercial customers allocated more cash to higher-rate 
alternative investments. The decline in consumer and small 
business banking deposits was due to higher balance customers 
moving a portion of those balances to other cash alternatives 
offering higher rates. Table 14 provides additional information 
regarding deposits. Information regarding the impact of deposits 
on net interest income and a comparison of average deposit 
balances is provided in “Earnings Performance – Net Interest 
Income” and Table 5 earlier in this Report. 

Table 14:  Deposits 

($ in millions) 

Noninterest-bearing 

Interest-bearing checking 

Market rate and other savings 

Savings certificates 

Other time deposits 

Deposits in foreign offices (1) 

Total deposits 

Dec 31,
2018 

% of 
total 
deposits 

Dec 31, 
2017 

% of 
total 
deposits 

% Change 

$ 

349,534 

27% 

$ 

373,722 

28% 

56,797 

703,338 

22,648 

95,602 

58,251 

4 

55 

2 

7 

5 

51,928 

690,168 

20,415 

71,715 

128,043 

4 

52 

2 

4 

10 

$  1,286,170 

100%  $  1,335,991 

100% 

(6) 

9 

2 

11 

33 

(55) 

(4) 

(1) 

Includes Eurodollar sweep balances of $31.8 billion and $80.1 billion at December 31, 2018 and 2017, respectively. 

Equity 
Total equity was $197.1 billion at December 31, 2018, compared 
with $208.1 billion at December 31, 2017. The decrease was 
driven by a $17.3 billion increase in treasury stock, a $4.2 billion 
decline in cumulative other comprehensive income 
predominantly due to fair value adjustments to available-for-sale 

securities caused by an increase in long-term interest rates, and 
a $2.1 billion decline in preferred stock, partially offset by a 
$12.9 billion increase in retained earnings from earnings net of 
dividends paid. The increase in treasury stock was the result of 
the repurchase of 375.5 million shares of common stock in 2018, 
an increase of 91% from 2017. 

Off-Balance Sheet Arrangements 

In the ordinary course of business, we engage in financial 
transactions that are not recorded on the balance sheet, or may 
be recorded on the balance sheet in amounts that are different 
from the full contract or notional amount of the transaction. Our 
off-balance sheet arrangements include commitments to lend 
and purchase debt and equity securities, transactions with 
unconsolidated entities, guarantees, derivatives, and other 
commitments. These transactions are designed to (1) meet the 
financial needs of customers, (2) manage our credit, market or 
liquidity risks, and/or (3) diversify our funding sources. 

Commitments to Lend and Purchase Debt and 
Equity Securities 
We enter into commitments to lend funds to customers, which 
are usually at a stated interest rate, if funded, and for specific 
purposes and time periods. When we make commitments, we 
are exposed to credit risk. However, the maximum credit risk for 
these commitments will generally be lower than the contractual 
amount because a significant portion of these commitments is 
expected to expire without being used by the customer. For more 
information on lending commitments, see Note 6 (Loans and 
Allowance for Credit Losses) to Financial Statements in this 
Report. We also enter into commitments to purchase securities 
under resale agreements. For more information on 
commitments to purchase securities under resale agreements, 
see Note 15 (Guarantees, Pledged Assets and Collateral, and 
Other Commitments) to Financial Statements in this Report. We 
also may enter into commitments to purchase debt and equity 
securities to provide capital for customers’ funding, liquidity or 

other future needs. For more information, see the “Off-Balance 
Sheet Arrangements – Contractual Cash Obligations” section in 
this report and Note 15 (Guarantees, Pledged Assets and 
Collateral, and Other Commitments) to Financial Statements in 
this Report. 

Transactions with Unconsolidated Entities 
In the normal course of business, we enter into various types of 
on- and off-balance sheet transactions with special purpose 
entities (SPEs), which are corporations, trusts, limited liability 
companies or partnerships that are established for a limited 
purpose. Generally, SPEs are formed in connection with 
securitization transactions and are considered variable interest 
entities (VIEs). For more information on securitizations, 
including sales proceeds and cash flows from securitizations, see 
Note 9 (Securitizations and Variable Interest Entities) to 
Financial Statements in this Report. 

Guarantees and Certain Contingent 
Arrangements 
Guarantees are contracts that contingently require us to make 
payments to a guaranteed party based on an event or a change in 
an underlying asset, liability, rate or index. Guarantees are 
generally in the form of standby letters of credit, securities 
lending and other indemnifications, written put options, 
recourse obligations and other types of arrangements. For more 
information on guarantees and certain contingent arrangements, 
see Note 15 (Guarantees, Pledged Assets and Collateral, and 
Other Commitments) to Financial Statements in this Report. 

69

Wells Fargo & Company 

69 

  
Off-Balance Sheet Arrangements (continued) 

Derivatives 
We use derivatives to manage exposure to market risk, including 
interest rate risk, credit risk and foreign currency risk, and to 
assist customers with their risk management objectives. 
Derivatives are recorded on the balance sheet at fair value, and 
volume can be measured in terms of the notional amount, which 
is generally not exchanged, but is used only as the basis on which 
interest and other payments are determined. The notional 
amount is not recorded on the balance sheet and is not, when 
viewed in isolation, a meaningful measure of the risk profile of 
the instruments. For more information on derivatives, see 
Note 17 (Derivatives) to Financial Statements in this Report. 

Other Commitments 
We also have other off-balance sheet transactions, including 
obligations to make rental payments under noncancelable 
operating leases. Our operating lease obligations are discussed in 
Note 7 (Premises, Equipment, Lease Commitments and Other 
Assets) to Financial Statements in this Report. 

Table 15:  Contractual Cash Obligations 

Contractual Cash Obligations 
In addition to the contractual commitments and arrangements 
previously described, which, depending on the nature of the 
obligation, may or may not require use of our resources, we enter 
into other contractual obligations that may require future cash 
payments in the ordinary course of business, including debt 
issuances for the funding of operations and leases for premises 
and equipment. 

Table 15 summarizes these contractual obligations as of 
December 31, 2018, excluding the projected cash payments for 
obligations for short-term borrowing arrangements and pension 
and postretirement benefit plans. More information on those 
obligations is in Note 13 (Short-Term Borrowings) and Note 22 
(Employee Benefits and Other Expenses) to Financial 
Statements in this Report. 

(in millions) 

Contractual payments by period: 

Deposits (1) 

Long-term debt (2) 

Interest (3) 

Operating leases 

Unrecognized tax obligations 

Commitments to purchase debt
and equity securities (4) 

Purchase and other obligations (5) 

Note(s) to 
Financial 
Statements 

Less than 
1 year 

1-3 
years 

3-5 
years 

12  $ 

88,435 

14 

46,547 

7 

23 

15 

8,496 

1,174 

4 

2,436 

777 

32,310 

73,239 

11,082 

1,936 

— 

409 

811 

6,188 

36,892 

6,669 

1,290 

— 

— 

258 

December 31, 2018 

Indeterminate 
maturity 

Total 

1,155,525 

1,286,170 

— 

— 

— 

3,939 

— 

— 

229,044 

51,038 

6,054 

3,943 

2,845 

2,177 

More 
than 
5 years 

3,712 

72,366 

24,791 

1,654 

— 

— 

331 

Total contractual obligations	 

$  147,869 

119,787 

51,297 

102,854 

1,159,464 

1,581,271 

(1) 	 Includes interest-bearing and noninterest-bearing checking, and market rate and other savings accounts. 
(2) 	 Balances are presented net of unamortized debt discounts and premiums and purchase accounting adjustments. 
(3) 	 Represents the future interest obligations related to interest-bearing time deposits and long-term debt in the normal course of business including a net reduction of 

$2.3 billion related to hedges used to manage interest rate risk. These interest obligations assume no early debt redemption. We estimated variable interest rate payments 
using December 31, 2018, rates, which we held constant until maturity. We have excluded interest related to structured notes where our payment obligation is contingent 
on the performance of certain benchmarks. 

(4) 	 Includes unfunded commitments to purchase debt and equity securities, excluding trade date payables, of $335 million and $2.5 billion, respectively. We have presented 

predominantly all of our contractual obligations on equity securities above in the maturing in less than one year category as there are no specified contribution dates in the 
agreements. These obligations may be requested at any time by the investment manager. 
(5) 	 Represents agreements related to unrecognized obligations to purchase goods or services. 

We are subject to the income tax laws of the U.S., its states 

and municipalities, and those of the foreign jurisdictions in 
which we operate. We have various unrecognized tax obligations 
related to these operations that may require future cash tax 
payments to various taxing authorities. Because of their 
uncertain nature, the expected timing and amounts of these 
payments generally are not reasonably estimable or 
determinable. We attempt to estimate the amount payable in the 
next 12 months based on the status of our tax examinations and 
settlement discussions. See Note 23 (Income Taxes) to Financial 
Statements in this Report for more information. 

Transactions with Related Parties 
The Related Party Disclosures topic of the Accounting Standards 
Codification (ASC) 850 requires disclosure of material related 
party transactions, other than compensation arrangements, 
expense allowances and other similar items in the ordinary 
course of business. Based on ASC 850, we had no transactions 
required to be reported for the years ended December 31, 2018, 
2017 and 2016. The Company has included within its disclosures 
information on its equity securities, relationships with variable 
interest entities, and employee benefit plan arrangements. See 
Note 8 (Equity Securities), Note 9 (Securitizations and Variable 
Interest Entities) and Note 22 (Employee Benefits and Other 
Expenses) to Financial Statements in this Report. 

70 

Wells Fargo & Company 

70

  
 
 
• 

• 

• 

	A company-wide statement of risk appetite that 
guides business and risk leaders as they manage risk on a 
daily basis. The company-wide statement of risk appetite 
describes the nature and magnitude of risk that the 
Company is willing to assume in pursuit of its business and 
strategic objectives, consistent with capital, liquidity and 
other regulatory requirements. 
	A risk management governance structure, including 
escalation requirements and a committee structure that 
helps provide comprehensive oversight of the risks we face. 
	A company-wide risk inventory that promotes a 
standardized and systematic process to identify and 
quantify risks at the business group and enterprise level to 
guide strategic business decisions and capital planning 
efforts. 

• 	 Policies, procedures, and controls which form an 

integrated risk management program that promotes active, 
prompt, and consistent identification, measurement, 
assessment, control, mitigation, reporting, and monitoring 
of current and emerging risk exposures across Wells Fargo 
and are integrated with clear enterprise risk roles and 
responsibilities for the three lines of defense. 

• 	 Three lines of defense that are closely integrated, each 

with specific roles and responsibilities for risk management 
and a clear engagement model that promotes challenge and 
appropriate escalation of issues and information. 

Board and Management-level Committee Structures 
Wells Fargo’s Board committee and management-level 
governance committee structures are designed to ensure that key 
risks are identified and escalated and, if necessary, decided upon 
at the appropriate level of the Company. Accordingly, the 
structure is built upon defined escalation and reporting paths 
from the front line to independent risk management and 
management-level governance committees and, ultimately, to 
the Board as appropriate. Each management-level governance 
committee has defined escalation processes, authorities and 
responsibilities as outlined in its charter. Our Board committee 
and management-level governance committee structures, and 
the primary risk oversight responsibilities of each of those 
committees, is presented in Table 16. 

Risk Management
 

Wells Fargo manages a variety of risks that can significantly 
affect our financial performance and our ability to meet the 
expectations of our customers, stockholders, regulators and 
other stakeholders. We operate under a Board approved risk 
management framework which outlines our company-wide 
approach to risk management and oversight and describes the 
structures and practices employed to manage current and 
emerging risks inherent to Wells Fargo. We believe that 
enhancements made during 2018 to our risk management 
framework transform and clarify our risk management approach 
by emphasizing the role of risk management when setting 
corporate strategy and by further rationalizing and integrating 
certain risk management organizational, governance and 
reporting practices. 

Risk Management Framework 
Our risk management framework defines how we manage risk in 
a comprehensive, integrated and consistent manner and lays out 
our vision for the risk management of the organization. It 
reinforces each team member’s personal accountability for risk 
management and is built on a foundation that begins with a deep 
understanding of the Company’s processes, risks and controls. 
Our risk management framework also supports members of 
senior management in achieving the Company’s strategic 
objectives and priorities, and it supports the Board as it carries 
out its risk oversight responsibilities. 

The risk management framework consists of three lines of 
defense: (1) the front line which consists of Wells Fargo’s risk-
generating activities, including all activities of its four primary 
business groups (Consumer Banking; Wholesale Banking; 
Wealth and Investment Management; and Payments, Virtual 
Solutions & Innovation) and certain activities of its enterprise 
functions (Human Resources, Enterprise Finance, Technology, 
Legal Department, Corporate Risk, Stakeholder Relations, and 
Wells Fargo Audit Services); (2) independent risk management, 
which consists of our Corporate Risk function and is led by our 
Chief Risk Officer (CRO) who reports to the Board’s Risk 
Committee; and (3) internal audit, which is Wells Fargo Audit 
Services and is led by our Chief Auditor who reports to the 
Board’s Audit & Examination Committee. In addition to the 
three lines of defense, our risk management framework includes 
enterprise control activities, which are certain specialized 
activities performed within centralized enterprise functions 
(such as Human Resources and the Legal Department) with a 
focus on controlling specific risks. Key elements of our risk 
management framework include: 
• 

	A strong culture that emphasizes each team member’s 
ownership and understanding of risk. We want to cultivate 
an environment that expects and promotes robust 
communication and cooperation among the three lines of 
defense and supports identifying, escalating and addressing 
current and emerging risk issues. 

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71 

 
 
Risk Management (continued) 

Table 16:  Board and Management-level Governance Committee Structure 

Wells Fargo & Company 

Board Committees and Primary Risk Oversight Responsibility 

Audit & 
Examination 
Committee 
(1) 

Finance 
Committee 

Corporate
Responsibility
Committee 

Risk 
Committee (2) 

Financial, regulatory
and risk reporting
and controls 

Interest Rate 
Risk 
Market Risk 

Social and public
responsibility 
matters 

COMPANY-WIDE 
RISKS 
- Compliance
(includes Conduct
and Financial Crimes)
- Liquidity
- Model 
- Operational 
(includes
Data Management,
Information 

Security/Cyber     
and Technology)
- Reputation
- Strategic 

Governance 
& 
Nominating
Committee 

Board-level 
governance 
matters 

Credit 
Committee 

Credit Risk 

Human 
Resources 
Committee 

Culture, ethics,
human capital
management and
compensation 

Management-level Governance Committees (3) 

Enterprise
Risk & Control 
Committee (4) 

Corporate
Allowance 
for Credit 
Losses 
Approval
Governance 
Committee 

Incentive 
Compensation
Committee 

Regulatory
and Risk 
Reporting
Oversight
Committee 

SOX 
Disclosure 
Committee 

Capital
Adequacy
Process 
Committee 

Capital
Management
Committee 

Corporate
Asset and 
Liability
Committee 

Recovery and
Resolution 
Committee 

Management
Reporting
Oversight
Committee 

(1) 	 The Audit & Examination Committee additionally oversees the internal audit function, external auditor independence, activities, and performance, and the disclosure 
framework for financial, regulatory and risk reports prepared for the Board, management, and bank regulatory agencies, and assists the Board in its oversight of the 
Company’s compliance with legal and regulatory requirements. 

(2) 	 The Risk Committee has a compliance subcommittee and a technology subcommittee to assist it in providing oversight of those risks as discussed herein. 
(3) 	 Pursuant to their charters, many of the management-level governance committees have formed one or more sub-committees to address specific risk matters. 
(4) 	 Certain committees report to the Enterprise Risk & Control Committee and have dual escalation and informational reporting paths to Board committees. 

Board Oversight of Risk 
The business and affairs of the Company are managed under the 
direction of the Board, whose responsibilities include overseeing 
management’s implementation of the Company’s risk 
management framework and ongoing oversight and governance 
of the Company’s risk management activities. The Board carries 
out its risk oversight responsibilities directly and through the 
work of its seven standing committees, which all report to the 
full Board. Each Board committee works closely with 
management to understand and oversee the Company’s key risk 
exposures. 

The Risk Committee oversees company-wide risks. The 
Board’s other standing committees also have primary oversight 
responsibility for certain specific risk matters, as highlighted in 
Table 16. 

The Risk Committee additionally oversees the Company’s 
Corporate Risk function and plays an active role in approving 
and overseeing the Company’s risk management framework. The 
Risk Committee and the full Board review and approve the 
enterprise statement of risk appetite annually, and the Risk 
Committee also actively monitors the Company’s risk profile 
relative to the approved risk appetite. 

The full Board receives reports at each of its regular 
meetings from the Board committee chairs about committee 
activities, including risk oversight matters, and the Risk 
Committee receives periodic reports from management 
regarding current or emerging risk matters. 

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Management Oversight of Risk 
The Company’s management-level governance committees are 
designed to enable understanding, consideration and decision-
making of significant risk and control matters at the appropriate 
level of the Company and by the appropriate mix of executives. 
Each committee has a defined set of authorities and 
responsibilities as set forth in its charter, and each committee 
has defined escalation paths and risk reporting responsibilities, 
including to the Board or Board committees, as appropriate. 

The Enterprise Risk & Control Committee is the 
management-level governance committee that governs the 
management of financial risks, non-financial risks and 
enterprise and other risk programs. The Enterprise Risk & 
Control Committee is co-chaired by the Company’s CEO and 
CRO and has an escalation path to the Board’s Risk Committee. 
It considers and decides risk and control matters, addresses 
escalated issues, actively oversees risk mitigation, and provides 
regular updates to the Board’s Risk Committee regarding 
emerging risks and senior management’s assessment of the 
effectiveness of the Company’s risk management program. It 
may escalate certain risk and control matters to other Board 
committees as appropriate based on their primary risk oversight 
responsibilities. 

Each business group and enterprise function has a Risk & 
Control Committee that reports to the Enterprise Risk & Control 
Committee and has a mandate that mirrors the Enterprise Risk 
& Control Committee but is limited to the relevant business 
group or enterprise function. These committees focus on the 
risks that each group or function generates and is responsible for 
managing, and on the controls that are expected to be in place. 
Additionally, there are standalone specific risk type- or program-
specific risk governance committees reporting to the Enterprise 
Risk & Control Committee to help provide complete and 
comprehensive governance for certain risk areas. 

While the Enterprise Risk & Control Committee and the 

committees that report to it serve as the focal point for the 
management of company-wide risk matters, the management of 
certain specific risk types is supported by additional 
management-level governance committees, which all report to at 
least one of the Board’s standing committees. 

The Corporate Risk function, which is the Company’s 
independent risk management organization, is headed by the 
Company’s CRO who, among other things, is responsible for 
setting the strategic direction and driving the execution of Wells 
Fargo’s risk management activities. The Corporate Risk function 
provides senior management and the Board with an independent 
perspective of the level of risk to which the Company is exposed. 

Corporate Risk develops the Company’s enterprise 

statement of risk appetite in the context of our risk management 
framework described above. As part of Wells Fargo’s risk 
appetite, we maintain metrics along with associated objectives to 
measure and monitor the amount of risk that the Company is 
prepared to take. Actual results of these metrics are reported to 
the Enterprise Risk & Control Committee on a quarterly basis 
and to the Board’s Risk Committee. Our business groups also 
have business-specific risk appetite statements based on the 
enterprise statement of risk appetite. The metrics included in the 
business group statements are harmonized with the enterprise 
level metrics to ensure consistency where appropriate. Business 
lines also maintain metrics and qualitative statements that are 
unique to their line of business. This allows for monitoring of 
risk and definition of risk appetite deeper within the 
organization. 

The Company’s senior management, including the CRO and 

Chief Auditor, work closely with the Board’s committees and 

provide ongoing reports and updates on risk matters during and 
outside of regular committee meetings, as appropriate. 

Operational Risk Management 
Operational risk is the risk resulting from inadequate or failed 
internal controls, processes, people and systems, or from 
external events. Operational risk is inherent in all Wells Fargo 
activities. 

The Board’s Risk Committee has primary oversight 

responsibility for all aspects of operational risk, including 
significant policies and programs regarding the Company’s 
business continuity, data management, information security, 
privacy, technology, and third-party risk management. As part of 
its oversight responsibilities, the Board’s Risk Committee 
approves the operational risk statement of risk appetite 
including inner and outer boundary thresholds, reviews and 
approves significant operational risk policies, and oversees the 
Company’s ongoing operational risk management program. 

At the management level, the Operational Risk function, 

which is part of Corporate Risk, has primary oversight 
responsibility for operational risk. The Operational Risk function 
reports to the CRO and also provides periodic reporting related 
to operational risk to the Board’s Risk Committee. Within the 
Operational Risk function, Information Security Risk 
Management has oversight responsibility for information 
security risk, and Technology Risk Management Oversight has 
oversight responsibility for technology risk. Oversight of data 
management risk, an operational risk, is an enterprise control 
activity performed within the Data Management & Insight 
function, and oversight of human capital risk, an operational 
risk, is an enterprise control activity performed within the 
Human Resources function. In addition, the Risk & Control 
Committee for each business group and enterprise function 
reports operational risk matters to the Enterprise Risk & Control 
Committee. 

Information security is a significant operational risk for 
financial institutions such as Wells Fargo, and includes the risk 
resulting from cyber attacks and other information security 
events relating to Wells Fargo technology, systems, networks, 
and data that would disrupt Wells Fargo’s businesses, result in 
the disclosure of confidential data which could damage Wells 
Fargo’s reputation, cause losses or increase costs. Wells Fargo’s 
Board is actively engaged in the oversight of the Company’s 
information security risk management and cyber defense 
programs. The Board’s Risk Committee has primary oversight 
responsibility for information security risk and approves the 
Company’s information security program, which includes the 
information security policy and the cyber defense program. The 
Risk Committee formed a Technology Subcommittee to assist it 
in providing oversight of technology, information security, and 
cyber risks as well as data management risk. The Technology 
Subcommittee reviews and recommends to the Risk Committee 
for approval any significant supporting information security 
(including cybersecurity) risk, technology risk, and data 
management risk programs and/or policies, including the 
Company’s data management strategy. The Technology 
Subcommittee reports to the Risk Committee and both provide 
updates to the full Board. 

Wells Fargo and other financial institutions continue to be 

the target of various evolving and adaptive cyber attacks, 
including malware and denial-of-service, as part of an effort to 
disrupt the operations of financial institutions, potentially test 
their cybersecurity capabilities, commit fraud, or obtain 
confidential, proprietary or other information. Cyber attacks 
have also focused on targeting online applications and services, 

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Risk Management (continued) 

such as online banking, as well as cloud-based services provided 
by third parties, and have targeted the infrastructure of the 
internet causing the widespread unavailability of websites and 
degrading website performance. Wells Fargo has not 
experienced any material losses relating to these or other types 
of cyber attacks. Cybersecurity risk is a priority for Wells Fargo, 
and we continue to develop and enhance our controls, processes 
and systems in order to protect our networks, computers, 
software and data from attack, damage or unauthorized access. 
Wells Fargo is also proactively involved in industry cybersecurity 
efforts and working with other parties, including our third-party 
service providers and governmental agencies, to continue to 
enhance defenses and improve resiliency to cybersecurity 
threats. See the “Risk Factors” section in this Report for 
additional information regarding the risks associated with a 
failure or breach of our operational or security systems or 
infrastructure, including as a result of cyber attacks. 

Compliance Risk Management 
Compliance risk is the risk resulting from the failure to comply 
with applicable laws, regulations, rules, and other regulatory 
requirements, and the failure to appropriately address and limit 
violations of law and any associated impact to customers. 
Compliance risk encompasses other standards of self-regulatory 
organizations applicable to the banking industry as well as 
nonconformance with applicable internal policies and 
procedures. 

The Board’s Risk Committee has primary oversight 

responsibility for all aspects of compliance risk, including 
financial crimes risk. As part of its oversight responsibilities, the 
Board’s Risk Committee approves the compliance risk and 
financial crimes risk statement of risk appetites including inner 
and outer boundary thresholds, reviews and approves significant 
compliance risk and financial crimes risk policies and programs, 
and oversees the Company’s ongoing compliance risk 
management and financial crimes risk management programs. 
The Compliance Subcommittee of the Risk Committee assists the 
Risk Committee in providing oversight of the Company’s 
compliance program and compliance risk management. The 
Compliance Subcommittee reports to the Risk Committee and 
both provide updates to the full Board. 

At the management level, Wells Fargo Compliance, which is 

part of Corporate Risk, monitors the implementation of the 
Company’s compliance program. Financial Crimes Risk 
Management, which is part of Wells Fargo Compliance, oversees 
and monitors financial crimes risk. Wells Fargo Compliance 
reports to the CRO and also provides periodic reporting related 
to compliance risk to the Board’s Risk Committee and 
Compliance Subcommittee. In addition, the Risk & Control 
Committee for each business group and enterprise function 
reports compliance risk matters to the Enterprise Risk & Control 
Committee. We continue to enhance our oversight of operational 
and compliance risk management, including as required by the 
FRB’s February 2, 2018, and the CFPB/OCC’s April 20, 2018, 
consent orders. 

Conduct Risk Management 
Conduct risk, a sub-category of compliance risk, is the risk 
resulting from inappropriate, unethical, or unlawful behavior on 
the part of team members or individuals acting on behalf of the 
Company, caused by deliberate actions or business practices. 
The Board has enhanced its oversight of conduct risk to 

oversee the alignment of team member conduct to the 
Company’s risk appetite (which the Board approves annually) 
and culture as reflected in our Vision, Values & Goals and Code 

of Ethics and Business Conduct. The Board’s Risk Committee 
has primary oversight responsibility for company-wide conduct 
risk and risk management components of the Company’s 
culture, while the responsibilities of the Board’s Human 
Resources Committee include oversight of the Company’s 
company-wide culture, Code of Ethics and Business Conduct, 
conflicts of interest program, human capital management 
(including talent management and succession planning), 
performance management program, and incentive compensation 
risk management program. 

At the management level, the Conduct Management Office 
has primary oversight responsibility for key elements of conduct 
risk, including internal investigations, sales practices oversight, 
complaints oversight, and ethics oversight. The Conduct 
Management Office reports to the CRO and also provides 
periodic reporting related to conduct risk to the relevant Board 
committees. In addition, the Risk & Control Committee for each 
business group and enterprise function reports conduct risk 
matters to the Enterprise Risk & Control Committee. 

The Company’s incentive compensation risk management 

program is overseen by the management-level Incentive 
Compensation Committee, which is chaired by the Head of 
Human Resources and provides periodic reporting related to 
incentive compensation risk to the Board’s Human Resources 
Committee. The Human Resources function, which reports to 
the CEO, also oversees the Company’s culture program, which 
promotes compliance with laws, consideration of risks when 
making decisions, and facilitates open dialogue and 
transparency among the lines of defense. 

Strategic Risk Management 
Strategic risk is the risk to earnings, capital, and/or liquidity 
arising from adverse or poorly executed business decisions or ill-
timed or inadequate responses to changes in the internal and 
external operating environment. 

The Board has primary oversight responsibility for strategic 

planning and oversees management’s development and 
implementation of and approves the Company’s strategic plan, 
and considers whether it is aligned with the Company’s risk 
appetite. Management develops, executes and recommends 
strategic corporate transactions and the Board evaluates 
management’s proposals, including their impact on the 
Company’s risk profile and financial position. The Board’s Risk 
Committee has primary oversight responsibility for the 
Company’s strategic risk and the adequacy of the Company’s 
strategic risk management program, including associated risk 
management practices, processes and controls. The Board’s 
Risk Committee also reviews and approves significant strategic 
risk governance documents, and receives periodic reporting 
from management regarding risks related to new products, and 
changes to products, as appropriate. 

At the management level, the Strategic Risk function, which 

is part of Corporate Risk, has primary oversight responsibility 
for strategic risk. The Strategic Risk function reports into the 
CRO and also provides periodic reporting related to strategic risk 
to the Board’s Risk Committee. In addition, the Risk & Control 
Committee for each business group and enterprise function 
reports strategic risk matters to the Enterprise Risk & Control 
Committee. 

Model Risk Management 
Model risk is the risk arising from decisions based on incorrect 
or misused model outputs or reports. 

The Board’s Risk Committee has primary oversight 

responsibility for model risk. As part of its oversight 

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Wells Fargo & Company 

74

 
responsibilities, the Board’s Risk Committee oversees the 
Company’s model risk management policy, model validation 
activities, model performance, model issue remediation status, 
and adherence to model risk appetite metrics. 

At the management level, the Corporate Model Risk 

function, which is part of Corporate Risk, has primary oversight 
responsibility for model risk and is responsible for ongoing 
governance, validation and monitoring of model risk across the 
Company. The Corporate Model Risk function reports to the 
CRO and also provides periodic reporting related to model risk 
to the Board’s Risk Committee. In addition, the Risk & Control 
Committee for each business group and enterprise function 
reports model risk matters to the Enterprise Risk & Control 
Committee. 

Reputation Risk Management 
Reputation risk is the risk arising from negative perceptions by 
stakeholders, whether real or not, resulting in potential loss of 
trust in the Company’s competence or integrity. Key external 
stakeholders include customers, potential and non-customers, 
shareholders, regulators, elected officials, advocacy groups, and 
the media. 

The Board’s Risk Committee has primary oversight 
responsibility for company-wide reputation risk, while each 
Board committee has reputation risk oversight responsibilities 
related to their primary oversight responsibilities. As part of its 
oversight responsibilities, the Board’s Risk Committee receives 
reports from management that help it monitor how effectively 
the Company is managing reputation risk. As part of its 
oversight responsibilities for social and public responsibility 
matters, the Board’s Corporate Responsibility Committee also 
receives reports from management relating to the Company’s 
brand and stakeholder perception of the Company. 

At the management level, the Reputation Risk Oversight 
function, which is part of Corporate Risk, has primary oversight 
responsibility for reputation risk. The Reputation Risk Oversight 
function reports into the CRO and also provides periodic 
reporting related to reputation risk to the Board’s Risk 
Committee. In addition, the Risk & Control Committee for each 
business group and enterprise function reports reputation risk 
matters to the Enterprise Risk & Control Committee. 

Credit Risk Management 
We define credit risk as the risk of loss associated with a 
borrower or counterparty default (failure to meet obligations in 
accordance with agreed upon terms). Credit risk exists with 
many of our assets and exposures such as debt security holdings, 
certain derivatives, and loans. 

The Board’s Credit Committee has primary oversight 
responsibility for credit risk. At the management level, the 
Corporate Credit function, which is part of Corporate Risk, has 
primary oversight responsibility for credit risk. The Corporate 
Credit function reports to the CRO and also provides periodic 
reporting related to credit risk to the Board’s Credit Committee. 
In addition, the Risk & Control Committee for each business 
group and enterprise function reports credit risk matters to the 
Enterprise Risk & Control Committee. 

The following discussion focuses on our loan portfolios, 
which represent the largest component of assets on our balance 
sheet for which we have credit risk. Table 17 presents our total 
loans outstanding by portfolio segment and class of financing 
receivable. 

Table 17:  Total Loans Outstanding by Portfolio Segment and 
Class of Financing Receivable 

(in millions) 

Commercial: 

Dec 31,
2018 

Dec 31,
2017 

Commercial and industrial 

$  350,199 

Real estate mortgage 

Real estate construction 

Lease financing 

121,014 

22,496 

19,696 

333,125 

126,599 

24,279 

19,385 

Total commercial 

513,405 

503,388 

Consumer: 

Real estate 1-4 family first mortgage 

285,065 

284,054 

Real estate 1-4 family junior lien 

mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer 

Total loans 

34,398 

39,025 

45,069 

36,148 

39,713 

37,976 

53,371 

38,268 

439,705 

453,382 

$  953,110 

956,770 

We manage our credit risk by establishing what we believe 
are sound credit policies for underwriting new business, while 
monitoring and reviewing the performance of our existing loan 
portfolios. We employ various credit risk management and 
monitoring activities to mitigate risks associated with multiple 
risk factors affecting loans we hold, could acquire or originate 
including: 
• 
• 
• 
• 
• 
•  Merger and acquisition activities 
•  Reputation risk 

Loan concentrations and related credit quality 
Counterparty credit risk 
Economic and market conditions 
Legislative or regulatory mandates 
Changes in interest rates 

Our credit risk management oversight process is governed 

centrally, but provides for decentralized management and 
accountability by our lines of business. Our overall credit process 
includes comprehensive credit policies, disciplined credit 
underwriting, frequent and detailed risk measurement and 
modeling, extensive credit training programs, and a continual 
loan review and audit process. 

A key to our credit risk management is adherence to a well-

controlled underwriting process, which we believe is appropriate 
for the needs of our customers as well as investors who purchase 
the loans or securities collateralized by the loans. 

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Wells Fargo & Company 

75 

  
Risk Management – Credit Risk Management (continued) 

Credit Quality Overview  Solid credit quality continued in 
2018, as our net charge-off rate remained low at 0.29% of 
average total loans. We continued to benefit from improvements 
in the performance of our commercial and consumer real estate 
portfolios. In particular: 
• 	 Nonaccrual loans were $6.5 billion at December 31, 2018, 
down from $7.6 billion at December 31, 2017. Commercial 
nonaccrual loans declined to $2.2 billion at December 31, 
2018, compared with $2.6 billion at December 31, 2017, and 
consumer nonaccrual loans declined to $4.3 billion at 
December 31, 2018, compared with $5.0 billion at 
December 31, 2017. The decline in nonaccrual loans 
reflected an improved housing market and credit 
improvement in commercial and industrial loans. 
Nonaccrual loans represented 0.68% of total loans at 
December 31, 2018, compared with 0.80% at December 31, 
2017. 

• 	 Net charge-offs as a percentage of average total loans 

decreased to 0.29% in 2018, compared with 0.31% in 2017. 
Net charge-offs as a percentage of our average commercial 
and consumer portfolios were 0.09% and 0.52% in 2018, 
respectively, compared with 0.09% and 0.55%, respectively, 
in 2017. 

• 	 Loans that are not government insured/guaranteed and 

90 days or more past due and still accruing were 
$94 million and $885 million in our commercial and 
consumer portfolios, respectively, at December 31, 2018, 
compared with $49 million and $1.0 billion at December 31, 
2017. 

• 	 Our provision for credit losses was $1.7 billion during 2018, 

compared with $2.5 billion in 2017. 

• 	 The allowance for credit losses declined to $10.7 billion, or 
1.12% of total loans, at December 31, 2018, compared with 
$12.0 billion, or 1.25%, at December 31, 2017. 

Additional information on our loan portfolios and our credit 

quality trends follows. 

PURCHASED CREDIT-IMPAIRED (PCI) LOANS  Loans 
acquired with evidence of credit deterioration since their 
origination and where it is probable that we will not collect all 
contractually required principal and interest payments are PCI 
loans. Substantially all of our PCI loans were acquired in the 
Wachovia acquisition on December 31, 2008. PCI loans are 
recorded at fair value at the date of acquisition, and the 
historical allowance for credit losses related to these loans is not 
carried over. The carrying value of PCI loans at December 31, 
2018, totaled $5.0 billion, compared with $12.8 billion at 
December 31, 2017, and $58.8 billion at December 31, 2008. The 
decrease from December 31, 2017, was due to the sales of 
$6.2 billion of Pick-a-Pay PCI loans during 2018, as well as 
portfolio runoff. PCI loans are considered to be accruing due to 
the existence of the accretable yield amount, which represents 
the cash expected to be collected in excess of their carrying 
value, and not based on consideration given to contractual 
interest payments. The accretable yield at December 31, 2018, 
was $3.0 billion. 

A nonaccretable difference is established for PCI loans to 

absorb losses expected on the contractual amounts of those 
loans in excess of the fair value recorded at the date of 
acquisition. Amounts absorbed by the nonaccretable difference 
do not affect the income statement or the allowance for credit 
losses. At December 31, 2018, $480 million in nonaccretable 
difference remained to absorb losses on PCI loans. 

For additional information on PCI loans, see the “Risk 
Management – Credit Risk Management – Real Estate 1-4 
Family First and Junior Lien Mortgage Loans – Pick-a-Pay 
Portfolio” section in this Report, Note 1 (Summary of Significant 
Accounting Policies ) and Note 6 (Loans and Allowance for 
Credit Losses) to Financial Statements in this Report. 

Significant Loan Portfolio Reviews  Measuring and 
monitoring our credit risk is an ongoing process that tracks 
delinquencies, collateral values, Fair Isaac Corporation (FICO) 
scores, economic trends by geographic areas, loan-level risk 
grading for certain portfolios (typically commercial) and other 
indications of credit risk. Our credit risk monitoring process is 
designed to enable early identification of developing risk and to 
support our determination of an appropriate allowance for credit 
losses. The following discussion provides additional 
characteristics and analysis of our significant portfolios. See 
Note 6 (Loans and Allowance for Credit Losses) to Financial 
Statements in this Report for more analysis and credit metric 
information for each of the following portfolios. 

COMMERCIAL AND INDUSTRIAL LOANS AND LEASE 
FINANCING  For purposes of portfolio risk management, we 
aggregate commercial and industrial loans and lease financing 
according to market segmentation and standard industry 
codes. We generally subject commercial and industrial loans and 
lease financing to individual risk assessment using our internal 
borrower and collateral quality ratings. Our ratings are aligned 
to regulatory definitions of pass and criticized categories with 
criticized divided among special mention, substandard, doubtful 
and loss categories. 

The commercial and industrial loans and lease financing 

portfolio totaled $369.9 billion, or 39% of total loans, at 
December 31, 2018. The net charge-off rate for this portfolio was 
0.13% in 2018, compared with 0.15% in 2017. At December 31, 
2018, 0.43% of this portfolio was nonaccruing, compared with 
0.56% at December 31, 2017, reflecting a decrease of 
$399 million in nonaccrual loans, predominantly due to credit 
improvement in the oil and gas portfolio. Also, $15.8 billion of 
the commercial and industrial loan and lease financing portfolio 
was internally classified as criticized in accordance with 
regulatory guidance at December 31, 2018, compared with 
$17.9 billion at December 31, 2017. The decrease in criticized 
loans, which also includes the decrease in nonaccrual loans, was 
mostly due to improvement in the oil and gas portfolio. 

Most of our commercial and industrial loans and lease 
financing portfolio is secured by short-term assets, such as 
accounts receivable, inventory and securities, as well as long-
lived assets, such as equipment and other business assets. 
Generally, the collateral securing this portfolio represents a 
secondary source of repayment. 

Table 18 provides a breakout of commercial and industrial 

loans and lease financing by industry, and includes $63.7 billion 
of foreign loans at December 31, 2018. Foreign loans totaled 
$21.8 billion within the investors category, $19.1 billion within 
the financial institutions category and $1.2 billion within the oil 
and gas category. 

The investors category includes loans to special purpose 

vehicles (SPVs) formed by sponsoring entities to invest in 
financial assets backed predominantly by commercial and 
residential real estate or corporate cash flow, and are repaid 
from the asset cash flows or the sale of assets by the SPV. We 
limit loan amounts to a percentage of the value of the underlying 
assets, as determined by us, based on analysis of underlying 

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76

 
  
 
 
 
credit risk and other factors such as asset duration and ongoing 
performance. 

We provide financial institutions with a variety of 
relationship focused products and services, including loans 
supporting short-term trade finance and working capital needs. 
The $19.1 billion of foreign loans in the financial institutions 
category were predominantly originated by our Corporate and 
Investment Banking business. 

The oil and gas loan portfolio totaled $12.2 billion, or 1% of 

total outstanding loans at December 31, 2018, compared with 
$12.5 billion, or 1% of total outstanding loans at December 31, 
2017. Oil and gas nonaccrual loans decreased to $416 million at 
December 31, 2018, compared with $1.1 billion at December 31, 
2017, due to continued credit improvement in the portfolio. 

Table 18:  Commercial and Industrial Loans and Lease 
Financing by Industry (1) 

(in millions) 

Investors 

Financial institutions 

Cyclical retailers 

Food and beverage 

Healthcare 

Technology 

Industrial equipment 

Real estate lessor 

Oil and gas 

Transportation 

Business services 

Public administration 

Other 

Total 

December 31, 2018 

Nonaccrual 
loans 

Total 
portfolio  (2) 

% of total 
loans 

$ 

24 

159 

81 

53 

126 

15 

63 

6 

416 

51 

27 

7 

73,880 

43,054 

27,875 

17,175 

16,611 

16,379 

14,780 

14,711 

12,221 

8,773 

8,245 

7,659 

548 

108,532  (3) 

8% 

5 

3 

2 

2 

2 

2 

2 

1 

1 

1 

1 

9 

$ 

1,576 

369,895 

39% 

(1) 	 Industry categories are based on the North American Industry Classification 
System and the amounts reported include foreign loans. See Note 6 (Loans 
and Allowance for Credit Losses) to Financial Statements in this Report for a 
breakout of commercial foreign loans. 

(2) 	 Includes $4 million PCI loans, which are considered to be accruing due to the 
existence of the accretable yield and not based on consideration given to 
contractual interest payments. 

(3) 	 No other single industry had total loans in excess of $6.0 billion. 

Risk mitigation actions, including the restructuring of 
repayment terms, securing collateral or guarantees, and entering 
into extensions, are based on a re-underwriting of the loan and 
our assessment of the borrower’s ability to perform under the 
agreed-upon terms. Extension terms generally range from six to 
thirty-six months and may require that the borrower provide 
additional economic support in the form of partial repayment, or 
additional collateral or guarantees. In cases where the value of 

collateral or financial condition of the borrower is insufficient to 
repay our loan, we may rely upon the support of an outside 
repayment guarantee in providing the extension. 

Our ability to seek performance under a guarantee is 

directly related to the guarantor’s creditworthiness, capacity and 
willingness to perform, which is evaluated on an annual basis, or 
more frequently as warranted. Our evaluation is based on the 
most current financial information available and is focused on 
various key financial metrics, including net worth, leverage, and 
current and future liquidity. We consider the guarantor’s 
reputation, creditworthiness, and willingness to work with us 
based on our analysis as well as other lenders’ experience with 
the guarantor. Our assessment of the guarantor’s credit strength 
is reflected in our loan risk ratings for such loans. The loan risk 
rating and accruing status are important factors in our allowance 
methodology. 

In considering the accrual status of the loan, we evaluate the 
collateral and future cash flows as well as the anticipated support 
of any repayment guarantor. In many cases, the strength of the 
guarantor provides sufficient assurance that full repayment of 
the loan is expected. When full and timely collection of the loan 
becomes uncertain, including the performance of the guarantor, 
we place the loan on nonaccrual status. As appropriate, we also 
charge the loan down in accordance with our charge-off policies, 
generally to the net realizable value of the collateral securing the 
loan, if any. 

COMMERCIAL REAL ESTATE (CRE)  We generally subject CRE 
loans to individual risk assessment using our internal borrower 
and collateral quality ratings. Our ratings are aligned to 
regulatory definitions of pass and criticized categories with 
criticized segmented among special mention, substandard, 
doubtful and loss categories. The CRE portfolio, which included 
$7.7 billion of foreign CRE loans, totaled $143.5 billion, or 15% 
of total loans, at December 31, 2018, and consisted of 
$121.0 billion of mortgage loans and $22.5 billion of 
construction loans. 

Table 19 summarizes CRE loans by state and property type 
with the related nonaccrual totals. The portfolio is diversified 
both geographically and by property type. The largest geographic 
concentrations of CRE loans are in California, New York, Florida 
and Texas, which combined represented 50% of the total CRE 
portfolio. By property type, the largest concentrations are office 
buildings at 27% and apartments at 16% of the portfolio. CRE 
nonaccrual loans totaled 0.4% of the CRE outstanding balance at 
December 31, 2018, compared with 0.4% at December 31, 2017. 
At December 31, 2018, we had $4.5 billion of criticized CRE 
mortgage loans, compared with $4.3 billion at December 31, 
2017, and $289 million of criticized CRE construction loans, 
compared with $298 million at December 31, 2017. 

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Risk Management – Credit Risk Management (continued) 

Table 19:  CRE Loans by State and Property Type 

(in millions) 

By state: 

California 

New York 

Florida 

Texas 

Arizona 

North Carolina 

Georgia 

Washington 

Virginia 

Illinois 

Other 

Total	 

By property: 

Office buildings 

Apartments 

Industrial/warehouse 

Retail (excluding shopping center) 

Shopping center 

Hotel/motel 

Mixed use properties (2) 

Institutional 

Agriculture 

1-4 family structure 

Other 

Total	 

Real estate mortgage 

Real estate construction 	

Nonaccrual 
loans 

Total 
portfolio 

Nonaccrual 
loans 

Total 
portfolio 

Nonaccrual 
loans 

$ 

143 

$ 

$ 

10 

29 

64 

33 

31 

12 

11 

12 

7 

228 

580 

142 

12 

95 

99 

6 

19 

81 

43 

46 

— 

37 

34,396 

10,676 

7,708 

7,796 

4,246 

3,679 

3,615 

3,390 

2,864 

2,958 

39,686 

121,014 

36,089 

16,107 

15,366 

14,512 

11,217 

9,649 

5,943 

3,135 

2,468 

9 

6,519 

$ 

580 

121,014 

7 

— 

2 

1 

— 

6 

— 

1 

— 

— 

15 

32 

2 

— 

— 

7 

— 

— 

2 

— 

— 

6 

15 

32 

4,559 

2,796 

2,044 

1,451 

366 

849 

606 

593 

941 

429 

7,862 

22,496 

3,079 

7,484 

1,295 

569 

1,184 

1,832 

524 

1,946 

33 

2,210 

2,340 

150 

10 

31 

65 

33 

37 

12 

12 

12 

7 

243 

612 

144 

12 

95 

106 

6 

19 

83 

43 

46 

6 

52 

December 31, 2018 

Total 

Total 
portfolio 

38,955 

13,472 

9,752 

9,247 

4,612 

4,528 

4,221 

3,983 

3,805 

3,387 

47,548  (1) 

% of 
total
loans 

4% 

1 

1 

1 

* 

* 

* 

* 

* 

* 

5 

143,510 

15% 

39,168 

23,591 

16,661 

15,081 

12,401 

11,481 

6,467 

5,081 

2,501 

2,219 

8,859 

4% 

2 

2 

2 

1 

1 

1 

1 

* 

* 

1 

22,496 

612 

143,510 

15% 

Less than 1%. 

* 	
(1) 	 Includes 40 states; no state had loans in excess of $3.4 billion. 
(2) 	 Mixed use properties are primarily owner occupied real estate, including data centers, flexible space leased to multiple tenants, light manufacturing and other specialized 

uses. 

FOREIGN LOANS AND COUNTRY RISK EXPOSURE  We 
classify loans for financial statement and certain regulatory 
purposes as foreign primarily based on whether the borrower’s 
primary address is outside of the United States. At December 31, 
2018, foreign loans totaled $71.9 billion, representing 
approximately 8% of our total consolidated loans outstanding, 
compared with $70.4 billion, or approximately 7% of total 
consolidated loans outstanding, at December 31, 2017. Foreign 
loans were approximately 4% of our consolidated total assets at 
both December 31, 2018, and December 31, 2017. 

Our country risk monitoring process incorporates frequent 
dialogue with our financial institution customers, counterparties 
and regulatory agencies, enhanced by centralized monitoring of 
macroeconomic and capital markets conditions in the respective 
countries. We establish exposure limits for each country through 
a centralized oversight process based on customer needs, and in 
consideration of relevant economic, political, social, legal, and 
transfer risks. We monitor exposures closely and adjust our 
country limits in response to changing conditions. 

We evaluate our individual country risk exposure based on 

our assessment of the borrower’s ability to repay, which gives 
consideration for allowable transfers of risk such as guarantees 
and collateral and may be different from the reporting based on 
the borrower’s primary address. Our largest single foreign 
country exposure based on our assessment of risk at 
December 31, 2018, was the United Kingdom, which totaled 

$27.2 billion, or approximately 1% of our total assets, and 
included $3.1 billion of sovereign claims. Our United Kingdom 
sovereign claims arise predominantly from deposits we have 
placed with the Bank of England pursuant to regulatory 
requirements in support of our London branch. The United 
Kingdom officially announced its intention to leave the 
European Union (Brexit) on March 29, 2017, starting the two-
year negotiation process leading to its departure. We continue to 
implement plans for Brexit. Our primary goal is to continue to 
serve our existing clients in the United Kingdom and the 
European Union as well as to continue to meet the needs of our 
domestic clients as they do business in the United Kingdom and 
the European Union. We have an existing authorized bank in 
Ireland and an asset management entity in Luxembourg. We are 
also in the process of obtaining regulatory approvals to establish 
a broker dealer in France. We continue to explore options to 
leverage these entities in order to continue to serve clients in the 
European Union. In addition, the impact of Brexit on our 
supplier contracts, staffing and business operations in the 
European Union is subject to an ongoing review, and we are 
implementing mitigating actions where possible. For additional 
information on risks associated with Brexit, see the “Risk 
Factors” section in this Report. 

Table 20 provides information regarding our top 20 
exposures by country (excluding the U.S.) and our Eurozone 
exposure, based on our assessment of risk, which gives 

78 

Wells Fargo & Company 

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consideration to the country of any guarantors and/or 
underlying collateral. 

Table 20:  Select Country Exposures 

(in millions) 

Top 20 country exposures: 

United Kingdom 
Canada 

Cayman Islands 
Germany 

Ireland 
Bermuda 

China 
Guernsey 

Netherlands 
India 

Luxembourg 

Brazil 

Chile 

Japan 

Australia 

France 

South Korea 

Switzerland 

Mexico 

Virgin Islands (British) 

Lending (1) 

Securities (2) 

Derivatives and other (3)	 

Total exposure 

Sovereign 

Non-
sovereign 

Sovereign 

Non-
sovereign 

Sovereign 

Non-
sovereign 

Sovereign 

Non­
sovereign (4) 

Total 

December 31, 2018 

$ 

3,102 
31 

— 
3,840 

20 
— 

— 
— 

— 
— 

— 

— 

1 

271 

— 

— 

— 

— 

— 

— 

22,227 
16,651 

7,208 
1,871 

3,897 
3,841 

2,754 
2,606 

2,180 
2,120 

1,502 

1,967 

1,654 

1,082 

1,288 

1,220 

1,254 

1,206 

1,164 

1,018 

— 
(27) 

— 
(10) 

— 
— 

(1) 
— 

43 
— 

— 
— 

— 

3 

— 

— 

11 

— 

— 

— 

19 

33 

— 
— 

— 

— 

33 

1,694 
190 

— 
(7) 

132 
98 

(28) 
— 

315 
156 

617 
— 

(3) 

55 

94 

81 

9 

(22) 

5 

64 

3,450 

1,138 

116 
17 

(67) 

74 

1,278 

3 
— 

— 
— 

— 
— 

25 
— 

— 
— 

— 
22 

— 

— 

— 

8 

— 

— 

— 

— 

58 

8 

— 
— 

— 

— 

8 

215 
135 

182 
340 

74 
56 

17 
2 

28 
— 

30 
— 

5 

11 

10 

3 

5 

17 

3 

— 

3,105 
4 

— 
3,830 

20 
— 

24 
— 

43 
— 

— 
22 

1 

274 

— 

8 

11 

— 

— 

— 

24,136 
16,976 

27,241 
16,980 

7,390 
2,204 

4,103 
3,995 

2,743 
2,608 

2,523 
2,276 

2,149 
1,967 

1,656 

1,148 

1,392 

1,304 

1,268 

1,201 

1,172 

1,082 

7,390 
6,034 

4,123 
3,995 

2,767 
2,608 

2,566 
2,276 

2,149 
1,989 

1,657 

1,422 

1,392 

1,312 

1,279 

1,201 

1,172 

1,082 

1,133 

7,342 

83,293 

90,635 

475 

3,901 

12,283 

16,184 

— 
35 

— 

— 

— 
— 

— 

23 

796
480

255 

261 

796 
480 

255 

284 

510 

3,924 

14,075 

17,999 

Total top 20 country exposures 

$ 

7,265 

78,710 

Eurozone exposure: 

Eurozone countries included in Top 20 above (5)  $ 

3,860 

10,670 

Austria 

Spain 
Belgium 

Other Eurozone countries (6) 

— 

— 
— 

23 

680 
428 

322 

187 

Total Eurozone exposure 

$ 

3,883 

12,287 

(1) 	 Lending exposure includes funded loans and unfunded commitments, leveraged leases, and money market placements presented on a gross basis prior to the deduction of 

impairment allowance and collateral received under the terms of the credit agreements. For the countries listed above, there are $478 million in defeased leases secured 
significantly by U.S. Treasury and government agency securities. 

(2) 	 Represents exposure on debt and equity securities of foreign issuers. Long and short positions are netted and net short positions are reflected as negative exposure. 
(3) 	 Represents counterparty exposure on foreign exchange and derivative contracts, and securities resale and lending agreements. This exposure is presented net of 

counterparty netting adjustments and reduced by the amount of cash collateral. It includes credit default swaps (CDS) predominantly used for market making activities in 
the U.S. and London based trading businesses, which sometimes results in selling and purchasing protection on the identical reference entities. Generally, we do not use 
market instruments such as CDS to hedge the credit risk of our investment or loan positions, although we do use them to manage risk in our trading businesses. At 
December 31, 2018, the gross notional amount of our CDS sold that reference assets in the Top 20 or Eurozone countries was $332 million, which was offset by the 
notional amount of CDS purchased of $484 million. We did not have any CDS purchased or sold that reference pools of assets that contain sovereign debt or where the 
reference asset was solely the sovereign debt of a foreign country. 

(4) 	 For countries presented in the table, total non-sovereign exposure comprises $41.3 billion exposure to financial institutions and $43.8 billion to non-financial corporations 

at December 31, 2018. 

(5) 	 Consists of exposure to Germany, Ireland, Netherlands, Luxembourg and France included in Top 20. 
(6) 	 Includes non-sovereign exposure to Italy, Portugal, and Greece in the amount of $141 million, $19 million and $14 million, respectively. We had no sovereign exposure in 

these countries at December 31, 2018. 

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79 

  
 
Risk Management – Credit Risk Management (continued) 

REAL ESTATE 1-4 FAMILY FIRST AND JUNIOR LIEN 
MORTGAGE LOANS  Our real estate 1-4 family first and junior 
lien mortgage loans, as presented in Table 21, include loans we 
have made to customers and retained as part of our asset/ 
liability management strategy, the Pick-a-Pay portfolio acquired 

from Wachovia which is discussed later in this Report and other 
purchased loans, and loans included on our balance sheet as a 
result of consolidation of variable interest entities (VIEs). 

Table 21:  Real Estate 1-4 Family First and Junior Lien Mortgage Loans 

(in millions) 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

December 31, 2018 

December 31, 2017 

Balance 

% of 
portfolio 

Balance 

% of 
portfolio 

$  285,065 

89% 

$ 

284,054 

34,398 

11 

39,713 

88% 

12 

Total real estate 1-4 family mortgage loans 

$  319,463 

100% 

$  323,767 

100% 

The real estate 1-4 family mortgage loan portfolio includes 

Real estate 1-4 family first and junior lien mortgage loans by 

state are presented in Table 22. Our real estate 1-4 family non-
PCI mortgage loans to borrowers in California represented 12% 
of total loans at December 31, 2018, located predominantly 
within the larger metropolitan areas, with no single California 
metropolitan area consisting of more than 5% of total loans. We 
monitor changes in real estate values and underlying economic 
or market conditions for all geographic areas of our real estate 
1-4 family first and junior lien mortgage portfolios as part of our 
credit risk management process. Our underwriting and periodic 
review of loans and lines secured by residential real estate 
collateral includes appraisals or estimates from automated 
valuation models (AVMs) to support property values. AVMs are 
computer-based tools used to estimate the market value of 
homes. AVMs are a lower-cost alternative to appraisals and 
support valuations of large numbers of properties in a short 
period of time using market comparables and price trends for 
local market areas. The primary risk associated with the use of 
AVMs is that the value of an individual property may vary 
significantly from the average for the market area. We have 
processes to periodically validate AVMs and specific risk 
management guidelines addressing the circumstances when 
AVMs may be used. AVMs are not allowed in real estate 1-4 
family first and junior lien mortgage origination underwriting. 
Broker evaluations and enhanced desktop appraisal reports are 
allowed in junior lien originations and some first lien line of 
credit originations up to $250,000. An appraisal is required for 
all real estate 1-4 family first and junior lien mortgage 
commitments greater than $250,000. Additional information 
about AVMs and our policy for their use can be found in Note 6 
(Loans and Allowance for Credit Losses) to Financial Statements 
in this Report. 

some loans with adjustable-rate features and some with an 
interest-only feature as part of the loan terms. Interest-only 
loans were approximately 4% of total loans at both December 31, 
2018 and 2017. We believe we have manageable adjustable-rate 
mortgage (ARM) reset risk across our owned mortgage loan 
portfolios. We do not offer option ARM products, nor do we offer 
variable-rate mortgage products with fixed payment amounts, 
commonly referred to within the financial services industry as 
negative amortizing mortgage loans. The option ARMs we do 
have are included in the Pick-a-Pay portfolio which was acquired 
from Wachovia. For more information, see the “Pick-a-Pay 
Portfolio” section in this Report. 

We continue to modify real estate 1-4 family mortgage loans 

to assist homeowners and other borrowers experiencing 
financial difficulties. Loans are generally underwritten at the 
time of the modification in accordance with underwriting 
guidelines established for our loan modification programs. 
Under these programs, we may provide concessions such as 
interest rate reductions, forbearance of principal, and in some 
cases, principal forgiveness. These programs generally include 
trial payment periods of three to four months, and after 
successful completion and compliance with terms during this 
period, the loan is permanently modified. Loans included under 
these programs are accounted for as troubled debt restructurings 
(TDRs) at the start of a trial period or at the time of permanent 
modification, if no trial period is used. See the “Critical 
Accounting Policies – Allowance for Credit Losses” section in 
this Report for discussion on how we determine the allowance 
attributable to our modified residential real estate portfolios. 

Part of our credit monitoring includes tracking delinquency, 
current FICO scores and loan/combined loan to collateral values 
(LTV/CLTV) on the entire real estate 1-4 family mortgage loan 
portfolio. These credit risk indicators, which exclude government 
insured/guaranteed loans, continued to improve in 2018 on the 
non-PCI mortgage portfolio. Loans 30 days or more delinquent 
at December 31, 2018, totaled $4.0 billion, or 1% of total non-
PCI mortgages, compared with $5.3 billion, or 2%, at 
December 31, 2017. Loans with FICO scores lower than 
640 totaled $9.7 billion, or 3% of total non-PCI mortgages at 
December 31, 2018, compared with $11.7 billion, or 4%, at 
December 31, 2017. Mortgages with a LTV/CLTV greater than 
100% totaled $3.9 billion at December 31, 2018, or 1% of total 
non-PCI mortgages, compared with $6.1 billion, or 2%, at 
December 31, 2017. Information regarding credit quality 
indicators, including PCI credit quality indicators, can be found 
in Note 6 (Loans and Allowance for Credit Losses) to Financial 
Statements in this Report. 

80 

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80

 
  
First Lien Mortgage Portfolio  Our total real estate 1-4 

family first lien mortgage portfolio increased $1.0 billion in 

2018, as growth in held for investment nonconforming mortgage 
loans was partially offset by payoffs and Pick-a-Pay PCI loan 
sales of $6.2 billion. In addition, $1.3 billion of nonconforming 
mortgage loan originations that would have otherwise been 
included in this portfolio, were designated as held for sale in 
2018 in anticipation of the future issuance of residential 
mortgage-backed securities. We retained $42.0 billion in 
nonconforming originations, consisting of loans that exceed 
conventional conforming loan amount limits established by 
federal government-sponsored entities (GSEs) in 2018. 

The credit performance associated with our real estate 1-4 

family first lien mortgage portfolio continued to improve in 
2018, as measured through net charge-offs and nonaccrual 
loans. Net charge-offs as a percentage of average real estate 1-4 
family first lien mortgage loans improved to a net recovery of 
0.03% in 2018, compared with a net recovery of 0.02% in 2017. 
Nonaccrual loans were $3.2 billion at December 31, 2018, 
compared with $3.7 billion at December 31, 2017. The decrease 
in nonaccrual loans from December 31, 2017, was driven by 
nonaccrual loan sales and an improving housing environment. 

Table 23 shows certain delinquency and loss information for 

the first lien mortgage portfolio and lists the top five states by 
outstanding balance. 

Table 22:  Real Estate 1-4 Family First and Junior Lien 
Mortgage Loans by State 

December 31, 2018 

Real 
estate 
1-4 family
first 
mortgage 

Real 
estate 
1-4 
family
junior
lien 
mortgage 

Total real 
estate 
1-4 
family 
mortgage 

% of 
total 
loans 

$ 109,092 

9,338 

118,430 

12% 

28,954 

13,811 

12,350 

9,677 

8,343 

8,566 

5,888 

5,422 

1,714 

3,152 

3,140 

30,668 

16,963 

15,490 

759 

10,436 

2,020 

10,363 

658 

1,608 

1,929 

9,224 

7,496 

7,351 

65,042 

10,063 

75,105 

12,932 

— 

12,932 

3 

2 

2 

1 

1 

1 

1 

1 

8 

1 

280,077 

34,381 

314,458 

33 

4,988 

17 

5,005 

1 

(in millions) 

Real estate 1-4 family
loans (excluding PCI): 

California 

New York 

New Jersey 

Florida 

Washington 

Virginia 

Texas 

North Carolina 

Pennsylvania 

Other (1) 

Government insured/

guaranteed loans (2) 

Real estate 1-4 family
loans (excluding PCI) 

Real estate 1-4 family
PCI loans 

Total 

$ 285,065 

34,398 

319,463 

34% 

(1) 	 Consists of 41 states; no state had loans in excess of $6.8 billion. 
(2) 	 Represents loans whose repayments are predominantly insured by the Federal 

Housing Administration (FHA) or guaranteed by the Department of Veterans 
Affairs (VA). 

Table 23:  First Lien Mortgage Portfolio Performance 

(in millions) 

California 

New York 

New Jersey 

Florida 

Washington 

Other 

Total 

Government insured/guaranteed loans 

PCI 

Outstanding balance 

% of loans 30 days or
more past due 

Loss (recovery) rate 

December 31, 

December 31, 

Year ended December 31, 

2018 

2017 

$ 

109,092 

101,464 

2018 

0.68% 

28,954 

13,811 

12,350 

9,677 

26,624 

13,212 

13,083 

8,845 

93,261 

92,961 

267,145 

256,189 

12,932 

4,988 

15,143 

12,722 

1.12 

1.91 

2.58 

0.57 

1.70 

1.23 

2017 

1.06 

1.65 

2.74 

3.95 

0.85 

2.25 

1.78 

2018 

(0.06) 

0.04 

0.03 

(0.17) 

(0.06) 

(0.02) 

(0.03) 

2017 

(0.07) 

0.03 

0.16 

(0.16) 

(0.08) 

0.02 

(0.02) 

Total first lien mortgages 

$  285,065 

284,054 

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81 

  
  
Risk Management – Credit Risk Management (continued) 

Pick-a-Pay Portfolio  The Pick-a-Pay portfolio was one of the 
consumer residential first lien mortgage portfolios we acquired 
from Wachovia and a majority of the portfolio was identified as 
PCI loans. 

The Pick-a-Pay portfolio is included in the consumer real 
estate 1-4 family first mortgage class of loans throughout this 
Report. Table 24 provides balances by types of loans as of 
December 31, 2018. As a result of our loan modification and loss 
mitigation efforts as well as borrower payoffs, Pick-a-Pay option 
payment loans have been reduced to $8.8 billion at 
December 31, 2018, from $99.9 billion at acquisition. Total 

Table 24:  Pick-a-Pay Portfolio – Comparison to Acquisition Date 

adjusted unpaid principal balance of Pick-a-Pay PCI loans was 
$6.6 billion at December 31, 2018, compared with $61.0 billion 
at acquisition. Due to loan modification and loss mitigation 
efforts as well as borrower payoffs, the adjusted unpaid principal 
balance of option payment PCI loans has declined to 19% of the 
total Pick-a-Pay portfolio at December 31, 2018, compared with 
51% at acquisition. As favorable sale opportunities arise, we may 
sell portions of this portfolio. We expect to close on the sale of 
approximately $2.4 billion unpaid principal balance of Pick-a-
Pay PCI loans in first quarter 2019. 

December 31, 2018 

December 31, 2008 

(in millions) 

Option payment loans 

Non-option payment adjustable-rate and fixed-rate loans 

Full-term loan modifications 

Total adjusted unpaid principal balance 

Total carrying value 

Adjusted
unpaid
principal

balance (1)  % of total 

Adjusted
unpaid
principal
balance (1) 

$ 

$ 

$ 

8,813 

2,848 

6,080 

17,741 

16,115 

50% 

$ 

99,937 

16 

34 

15,763 

—

% of total 

86% 

14 

— 

100% 

$  115,700 

100% 

$ 

95,315 

(1)  Adjusted unpaid principal balance includes write-downs taken on loans where severe delinquency (normally 180 days) or other indications of severe borrower financial 

stress exist that indicate there will be a loss of contractually due amounts upon final resolution of the loan. 

Pick-a-Pay option payment loans may have fixed or 

During 2018, we sold $6.2 billion of Pick-a-Pay PCI loans 

adjustable rates with payment options that include a minimum 
payment, an interest-only payment or fully amortizing payment 
(both 15- and 30-year options). 

Since December 31, 2008, we have completed over 138,000 

proprietary and Home Affordability Modification Program 
(HAMP) Pick-a-Pay loan modifications, which have resulted in 
over $6.1 billion of principal forgiveness. We have also provided 
interest rate reductions and loan term extensions to enable 
sustainable homeownership for our Pick-a-Pay customers. 

The predominant portion of our PCI loans is included in the 

Pick-a-Pay portfolio. Our cash flows expected to be collected 
have been favorably affected over time by lower expected 
defaults and losses as a result of observed and forecasted 
economic strengthening, particularly in housing prices, and our 
loan modification efforts. Since acquisition, we have reclassified 
$9.3 billion from the nonaccretable difference to the accretable 
yield. Fluctuations in the accretable yield are driven by changes 
in interest rate indices for variable rate PCI loans, prepayment 
assumptions, and expected principal and interest payments over 
the estimated life of the portfolio, which will be affected by the 
pace and degree of improvements in the U.S. economy and 
housing markets and projected lifetime performance resulting 
from loan modification activity. Changes in the projected timing 
of cash flow events, including loan liquidations, prepayments, 
modifications and short sales, can also affect the accretable yield 
and the estimated weighted-average life of the portfolio. 

that resulted in a gain of $2.4 billion. The accretable yield 
balance related to our Pick-a-Pay PCI loan portfolio declined 
$5.9 billion during 2018, driven by realized accretion of 
$1.0 billion, $2.4 billion from the gain on the loan sales, a 
$2.1 billion reduction in expected interest cash flows resulting 
from the loan sales, and a $752 million reduction in cash flows 
resulting from higher prepayments, partially offset by a 
$372 million reclassification from nonaccretable difference. An 
increase in expected prepayments and passage of time lowered 
our estimated weighted-average life to approximately 5.5 years 
at December 31, 2018, from 6.8 years at December 31, 2017. The 
accretable yield percentage for Pick-a-Pay PCI loans for fourth 
quarter 2018 was 11.47%, up from 9.83% in fourth quarter 2017, 
due to an increase in the amount of accretable yield relative to 
the shortened weighted-average life. Based on loan sales in 
fourth quarter 2018, we expect the accretable yield percentage to 
increase to approximately 11.49% for first quarter 2019. 

For further information on the judgment involved in 

estimating expected cash flows for PCI loans, see Note 1 
(Summary of Significant Accounting Policies) to Financial 
Statements in this Report. 

82 

Wells Fargo & Company 

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Junior Lien Mortgage Portfolio  The junior lien mortgage 
portfolio consists of residential mortgage lines and loans that are 
subordinate in rights to an existing lien on the same property. It 
is not unusual for these lines and loans to have draw periods, 
interest only payments, balloon payments, adjustable rates and 
similar features. Junior lien loan products are mostly amortizing 
payment loans with fixed interest rates and repayment periods 
between five to 30 years. 

We continuously monitor the credit performance of our 

junior lien mortgage portfolio for trends and factors that 
influence the frequency and severity of loss. We have observed 
that the severity of loss for junior lien mortgages is high and 
generally not affected by whether we or a third party own or 
service the related first lien mortgage, but the frequency of 
delinquency is typically lower when we own or service the first 
lien mortgage. In general, we have limited information available 
on the delinquency status of the third party owned or serviced 
first lien where we also hold a junior lien. To capture this 
inherent loss content, our allowance process for junior lien 
mortgages considers the relative difference in loss experience for 
junior lien mortgages behind first lien mortgage loans we own or 
service, compared with those behind first lien mortgage loans 
owned or serviced by third parties. In addition, our allowance 
process for junior lien mortgages that are current, but are in 

Table 25:  Junior Lien Mortgage Portfolio Performance 

their revolving period, considers the inherent loss where the 
borrower is delinquent on the corresponding first lien mortgage 
loans. 

Table 25 shows certain delinquency and loss information for 

the junior lien mortgage portfolio and lists the top five states by 
outstanding balance. The decrease in outstanding balances since 
December 31, 2017, predominantly reflects loan paydowns. As of 
December 31, 2018, 6% of the outstanding balance of the junior 
lien mortgage portfolio was associated with loans that had a 
combined loan to value (CLTV) ratio in excess of 100%. Of those 
junior lien mortgages with a CLTV ratio in excess of 100%, 
2.93% were 30 days or more past due. CLTV means the ratio of 
the total loan balance of first lien mortgages and junior lien 
mortgages (including unused line amounts for credit line 
products) to property collateral value. The unsecured portion 
(the outstanding amount that was in excess of the most recent 
property collateral value) of the outstanding balances of these 
loans totaled 2% of the junior lien mortgage portfolio at 
December 31, 2018. For additional information on consumer 
loans by LTV/CLTV, see Table 6.12 in Note 6 (Loans and 
Allowance for Credit Losses) to Financial Statements in this 
Report. 

(in millions) 

California 

New Jersey 

Florida 

Virginia 

Pennsylvania 

Other 

Total 

PCI 

Outstanding balance 

% of loans 30 days or
more past due 

Loss (recovery) rate 

December 31, 

December 31, 

Year ended December 31, 

$ 

2018 

9,338 

3,152 

3,140 

2,020 

1,929 

14,802 

34,381 

17 

2017 

10,599 

3,606 

3,688 

2,358 

2,210 

17,225 

39,686 

27 

2018 

1.67% 

2.57 

2.73 

1.91 

2.10 

2.12 

2.08 

2017 

2.09 

2.86 

3.05 

2.34 

2.37 

2.33 

2.38 

2018 

(0.46) 

0.25 

— 

0.19 

0.15 

(0.07) 

(0.11) 

2017 

(0.40) 

0.64 

0.10 

0.29 

0.39 

0.08 

0.03 

Total junior lien mortgages 

$ 

34,398 

39,713 

83

Wells Fargo & Company 

83 

 
  
Risk Management – Credit Risk Management (continued) 

Our junior lien, as well as first lien, lines of credit portfolios 

generally have draw periods of 10, 15 or 20 years with variable 
interest rate and payment options during the draw period of 
(1) interest only or (2) 1.5% of outstanding principal balance plus 
accrued interest. During the draw period, the borrower has the 
option of converting all or a portion of the line from a variable 
interest rate to a fixed rate with terms including interest-only 
payments for a fixed period between three to seven years or a 
fully amortizing payment with a fixed period between five to 
30 years. At the end of the draw period, a line of credit generally 
converts to an amortizing payment schedule with repayment 
terms of up to 30 years based on the balance at time of 
conversion. Certain lines and loans have been structured with a 
balloon payment, which requires full repayment of the 
outstanding balance at the end of the term period. The 
conversion of lines or loans to fully amortizing or balloon payoff 
may result in a significant payment increase, which can affect 
some borrowers’ ability to repay the outstanding balance. 

On a monthly basis, we monitor the payment characteristics 
of borrowers in our first and junior lien lines of credit portfolios. 
In December 2018, approximately 44% of these borrowers paid 
only the minimum amount due and approximately 50% paid 
more than the minimum amount due. The rest were either 
delinquent or paid less than the minimum amount due. For the 
borrowers with an interest only payment feature, approximately 

30% paid only the minimum amount due and approximately 
63% paid more than the minimum amount due. 

The lines that enter their amortization period may 

experience higher delinquencies and higher loss rates than the 
ones in their draw or term period. We have considered this 
increased inherent risk in our allowance for credit loss estimate. 

In anticipation of our borrowers reaching the end of their 

contractual commitment, we have created a program to inform, 
educate and help these borrowers transition from interest-only 
to fully-amortizing payments or full repayment. We monitor the 
performance of the borrowers moving through the program in 
an effort to refine our ongoing program strategy. 

Table 26 reflects the outstanding balance of our portfolio of 

junior lien mortgages, including lines and loans, and first lien 
lines segregated into scheduled end of draw or end of term 
periods and products that are currently amortizing, or in balloon 
repayment status. It excludes real estate 1-4 family first lien line 
reverse mortgages, which total $109 million, because they are 
predominantly insured by the FHA, and it excludes PCI loans, 
which total $34 million, because their losses were generally 
reflected in our nonaccretable difference established at the date 
of acquisition. 

Table 26:  Junior Lien Mortgage Line and Loan and First Lien Mortgage Line Portfolios Payment Schedule 

(in millions) 

Junior lien lines and loans 

First lien lines 

Total (2)(3)	 

% of portfolios	 

Outstanding balance 

December 31, 2018 

2019 

2020 

$ 

$ 

34,381 

11,802 

46,183 

100%

456 

169 

625 

1 

499 

197 

696 

2 

Scheduled end of draw/term 

2024 and 

2021 

1,107 

509 

1,616 

3

2022 

3,964 

1,887 

5,851 

13 

2023 

thereafter (1) 

Amortizing 

2,754 

1,419 

4,173 

9 

14,291 

5,616 

19,907 

43

11,310 

2,005 

13,315 

29 

(1) 	 Substantially all lines and loans are scheduled to convert to amortizing loans by the end of 2028, with annual scheduled amounts through 2028 ranging from $2.4 billion to 

$5.8 billion and averaging $3.9 billion per year. 

(2) 	 Junior and first lien lines are primarily interest-only during their draw period. The unfunded credit commitments for junior and first lien lines totaled $60.1 billion at 

December 31, 2018. 

(3) 	 Includes scheduled end-of-term balloon payments for lines and loans totaling $179 million, $223 million, $365 million, $172 million, $7 million and $30 million for 2019, 
2020, 2021, 2022, 2023, and 2024 and thereafter, respectively. Amortizing lines and loans include $56 million of end-of-term balloon payments, which are past due. At 
December 31, 2018, $488 million, or 4% of outstanding lines of credit that are amortizing, are 30 days or more past due compared to $553 million or 2% for lines in their 
draw period. 

CREDIT CARDS  Our credit card portfolio totaled $39.0 billion 
at December 31, 2018, which represented 4% of our total 
outstanding loans. The net charge-off rate for our credit card 
portfolio was 3.51% for 2018, compared with 3.49% for 2017. 

AUTOMOBILE  Our automobile portfolio, predominantly 
composed of indirect loans, totaled $45.1 billion at December 31, 
2018. The net charge-off rate for our automobile portfolio was 
1.21% for 2018, compared with 1.18% for 2017. 

OTHER REVOLVING CREDIT AND INSTALLMENT  Other 
revolving credit and installment loans totaled $36.1 billion at 
December 31, 2018, and primarily included student and 
securities-based loans. Our private student loan portfolio totaled 
$11.2 billion at December 31, 2018. The net charge-off rate for 
other revolving credit and installment loans was 1.53% for 2018, 
compared with 1.52% for 2017. 

84 

Wells Fargo & Company 

84

  
 
 
 
 
 
NONPERFORMING ASSETS (NONACCRUAL LOANS AND 
FORECLOSED ASSETS)  Table 27 summarizes nonperforming 
assets (NPAs) for each of the last five years. We generally place 
loans on nonaccrual status when: 
• 	

the full and timely collection of interest or principal 
becomes uncertain (generally based on an assessment of the 
borrower’s financial condition and the adequacy of 
collateral, if any), such as in bankruptcy or other 
circumstances; 
they are 90 days (120 days with respect to real estate 1-4 
family first and junior lien mortgages) past due for interest 
or principal, unless both well-secured and in the process of 
collection; 

• 	

• 	 part of the principal balance has been charged off; or 
• 	

for junior lien mortgages, we have evidence that the related 
first lien mortgage may be 120 days past due or in the 

process of foreclosure regardless of the junior lien 
delinquency status. 

Credit card loans are not placed on nonaccrual status, but 
are generally fully charged off when the loan reaches 180 days 
past due. 

Note 1 (Summary of Significant Accounting Policies – 

Loans) to Financial Statements in this Report describes our 
accounting policy for nonaccrual and impaired loans. 

Nonaccrual loans were $6.5 billion at December 31, 2018, 
down $1.2 billion from a year ago, due to a $413 million decrease 
in commercial and industrial nonaccruals reflecting continued 
credit improvement in the portfolio, as well as a decrease of 
$690 million in consumer real estate nonaccruals. 

Table 27:  Nonperforming Assets (Nonaccrual Loans and Foreclosed Assets) 

(in millions)	 

Nonaccrual loans: 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial	 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Automobile 

Other revolving credit and installment 

Total consumer	 

Total nonaccrual loans (1)(2)(3)(4)	 

As a percentage of total loans	 

Foreclosed assets: 

Government insured/guaranteed (5) 

Non-government insured/guaranteed 

Total foreclosed assets	 

Total nonperforming assets	 

As a percentage of total loans	 

2018 

2017 

2016 

2015 

2014 

December 31, 

$ 

1,486 

580 

32 

90 

1,899 

628 

37 

76

3,199 

685 

43 

115 

1,363 

969 

66

26 

537 

1,490 

187 

24 

2,188 

2,640 

4,042 

2,424 

2,238 

3,183 

945 

130 

50 

4,308 

$ 

6,496 

0.68% 

$

 88

363 

451 

$ 

6,947 

0.73% 

3,732 

1,086 

130 

58 

5,006 

7,646 

0.80 

120 

522 

642 

8,288 

0.87 

4,516 

1,206 

106 

51 

5,879 

9,921 

1.03 

197 

781 

978 

10,899 

1.13 

6,829 

1,495 

121 

49 

8,494 

10,918 

1.19 

446 

979 

1,425 

12,343 

1.35 

8,056 

1,848 

137 

41 

10,082 

12,320 

1.43 

982 

1,627 

2,609 

14,929 

1.73 

(1) 	 Financial information for periods prior to December 31, 2018, has been revised to exclude mortgage loans held for sale (MLHFS), loans held for sale (LHFS) and loans held 

at fair value of $390 million, $463 million, $464 million, and $528 million at December 31, 2017, 2016, 2015, and 2014, respectively. 

(2) 	 Excludes PCI loans because they continue to earn interest income from accretable yield, independent of performance in accordance with their contractual terms. 
(3) 	 Real estate 1-4 family mortgage loans predominantly insured by the FHA or guaranteed by the VA are not placed on nonaccrual status because they are insured or 

guaranteed. 

(4) 	 See Note 6 (Loans and Allowance for Credit Losses) to Financial Statements in this Report for further information on impaired loans. 
(5) 	 Consistent with regulatory reporting requirements, foreclosed real estate resulting from government insured/guaranteed loans are classified as nonperforming. However, 

both principal and interest related to these foreclosed real estate assets are collectible because the loans were predominantly insured by the FHA or guaranteed by the VA. 
Foreclosure of certain government guaranteed residential real estate mortgage loans that meet criteria specified by Accounting Standards Update (ASU) 2014-14, 
Classification of Certain Government-Guaranteed Mortgage Loans Upon Foreclosure, effective as of January 1, 2014, are excluded from this table and included in Accounts 
Receivable in Other Assets. For more information on the classification of certain government-guaranteed mortgage loans upon foreclosure, see Note 1 (Summary of 
Significant Accounting Policies) to Financial Statements in this Report. 

85

Wells Fargo & Company 

85 

  
  
 
Risk Management – Credit Risk Management (continued) 

Table 28 provides a summary of nonperforming assets 

during 2018. 

Table 28:  Nonperforming Assets by Quarter During 2018 

(in millions) 

Nonaccrual loans: 

Commercial: 

December 31, 2018 

September 30, 2018 

June 30, 2018 

March 31, 2018 

% of 

total 

% of 

total 

% of 

total 

Balance 

loans 

Balance 

loans 

Balance 

loans 

Balance 

% of 

total 

loans 

Commercial and industrial 

$  1,486 

0.42%  $  1,555 

0.46%  $  1,559 

0.46%  $  1,516 

0.45% 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Automobile 

Other revolving credit and installment 

Total consumer 

Total nonaccrual loans (1) 

Foreclosed assets: 

Government insured/guaranteed 

Non-government insured/guaranteed 

Total foreclosed assets 

0.48 

0.14 

0.46 

0.43 

1.12 

2.75 

0.29 

0.14 

0.98 

0.68 

580 

32 

90 

2,188 

3,183 

945 

130 

50 

4,308 

6,496 

88 

363 

451 

0.50 

0.19 

0.49 

0.46 

1.15 

2.78 

0.26 

0.13 

1.00 

0.71 

603 

44 

96 

2,298 

3,267 

983 

118 

48 

4,416 

6,714 

87 

435 

522 

0.62 

0.22 

0.41 

0.49 

1.23 

2.82 

0.25 

0.14 

1.06 

0.75 

765 

51 

80 

2,455 

3,469 

1,029 

119 

54 

4,671 

7,126 

90 

409 

499 

0.60 

0.19 

0.48 

0.48 

1.30 

2.87 

0.24 

0.14 

1.11 

0.77 

755 

45 

93 

2,409 

3,673 

1,087 

117 

53 

4,930 

7,339 

103 

468 

571 

Total nonperforming assets 

$  6,947 

0.73%  $  7,236 

0.77%  $  7,625 

0.81%  $  7,910 

0.83% 

Change in NPAs from prior quarter 

$ 

(289) 

(389) 

(285) 

(378) 

(1)  Financial information for periods prior to December 31, 2018, has been revised to exclude MLHFS, LHFS and loans held at fair value of $339 million, $360 million, and $380 

million, at September 30, June 30, and March 31, 2018, respectively. 

86 

Wells Fargo & Company 

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Table 29 provides an analysis of the changes in nonaccrual 

loans. 

Table 29:  Analysis of Changes in Nonaccrual Loans 

(in millions) 

Commercial nonaccrual loans 

Balance, beginning of period 

Inflows 

Outflows: 

Returned to accruing 

Foreclosures 

Charge-offs 

Payments, sales and other 

Total outflows	 

Balance, end of period	 

Consumer nonaccrual loans 

Balance, beginning of period 

Inflows 

Outflows: 

Returned to accruing 

Foreclosures 

Charge-offs 

Payments, sales and other 

Total outflows	 

Balance, end of period	 

Dec 31, 

Sep 30, 

Jun 30, 

Mar 31, 

Year ended Dec 31, 

2018 

2018 

2018 

2018 

2018 

2017 

Quarter ended 

$ 

2,298 

662 

(45) 

(12) 

(193) 

(522) 

(772) 

2,455 

774 

2,409 

726 

2,640 

605 

2,640 

2,767 

(122) 

—

(191) 

(618) 

(931) 

(43) 

—

(133) 

(504) 

(680) 

(113) 

— 

(119) 

(604) 

(836) 

(323) 

(12) 

(636) 

(2,248) 

(3,219) 

2,188 

2,298 

2,455 

2,409 

2,188 

4,059 

2,893 

(417) 

(20) 

(630) 

(3,245) 

(4,312) 

2,640 

5,879 

3,093 

4,416 

569 

(269) 

(35) 

(57) 

(316) 

(677) 

4,308 

4,671 

572 

(319) 

(41) 

(65) 

(402) 

(827) 

4,416 

6,714 

4,930 

578 

(342) 

(40) 

(84) 

(371) 

(837) 

4,671 

7,126 

5,006 

714 

5,006 

2,433 

(374) 

(1,304) 

(1,583) 

(50) 

(86) 

(280) 

(790) 

4,930 

7,339 

(166) 

(292) 

(1,369) 

(3,131) 

4,308 

6,496 

(218) 

(468) 

(1,697) 

(3,966) 

5,006 

7,646 

Total nonaccrual loans (1) 

$ 

6,496 

(1)  Financial information for periods prior to December 31, 2018, has been revised to exclude MLHFS, LHFS and loans held at fair value of $339 million, $360 million, and $380 

million, at September 30, June 30, and March 31, 2018, respectively, and $390 million at December 31, 2017. 

Typically, changes to nonaccrual loans period-over-period 
represent inflows for loans that are placed on nonaccrual status 
in accordance with our policy, offset by reductions for loans that 
are paid down, charged off, sold, foreclosed, or are no longer 
classified as nonaccrual as a result of continued performance 
and an improvement in the borrower’s financial condition and 
loan repayment capabilities. Also, reductions can come from 
borrower repayments even if the loan remains on nonaccrual. 
While nonaccrual loans are not free of loss content, we 

believe exposure to loss is significantly mitigated by the 
following factors at December 31, 2018: 
• 	 Over 96% of total commercial nonaccrual loans and 99% of 

• 	

total consumer nonaccrual loans are secured. Of the 
consumer nonaccrual loans, 96% are secured by real estate 
and 87% have a combined LTV (CLTV) ratio of 80% or less. 
losses of $358 million and $1.5 billion have already been 
recognized on 20% of commercial nonaccrual loans and 
45% of consumer nonaccrual loans, respectively. Generally, 
when a consumer real estate loan is 120 days past due 
(except when required earlier by guidance issued by bank 
regulatory agencies), we transfer it to nonaccrual status. 
When the loan reaches 180 days past due, or is active or 
discharged in bankruptcy, it is our policy to write these 
loans down to net realizable value (fair value of collateral 
less estimated costs to sell). Thereafter, we re-evaluate each 
loan regularly and record additional write-downs if needed. 

• 	 82% of commercial nonaccrual loans were current on 

interest, but were on nonaccrual status because the full or 
timely collection of interest or principal had become 
uncertain. 

• 	

• 	

• 	

72% of commercial nonaccrual loans were current on both 
principal and interest, but will remain on nonaccrual status 
until the full and timely collection of principal and interest 
becomes certain. 
the remaining risk of loss of all nonaccrual loans has been 
considered and we believe is adequately covered by the 
allowance for loan losses. 
of $1.9 billion of consumer loans in bankruptcy or 
discharged in bankruptcy, and classified as nonaccrual, 
$1.3 billion were current. 

We continue to work with our customers experiencing 

financial difficulty to determine if they can qualify for a loan 
modification so that they can stay in their homes. Under our 
proprietary modification programs, customers may be required 
to provide updated documentation, and some programs require 
completion of payment during trial periods to demonstrate 
sustained performance before the loan can be removed from 
nonaccrual status. 

If interest due on all nonaccrual loans (including loans that 

were, but are no longer on nonaccrual at year end) had been 
accrued under the original terms, approximately $446 million of 
interest would have been recorded as income on these loans, 
compared with $426 million actually recorded as interest 
income in 2018, versus $500 million and $395 million, 
respectively, in 2017. 

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Wells Fargo & Company 

87 

  
   
 
Risk Management – Credit Risk Management (continued) 

Table 30 provides a summary of foreclosed assets and an 

analysis of changes in foreclosed assets. 

Table 30:  Foreclosed Assets 

(in millions) 

Summary by loan segment 

Dec 31, 

Sep 30, 

Jun 30, 

Mar 31, 

Year ended Dec 31, 

2018 

2018 

2018 

2018 

2018 

2017 

Quarter ended 

Government insured/guaranteed 

$ 

88 

PCI loans: 

Commercial 

Consumer 

Total PCI loans	 

All other loans: 

Commercial 

Consumer 

Total all other loans	 

Total foreclosed assets	 

Analysis of changes in foreclosed assets 

Balance, beginning of period 

Net change in government insured/guaranteed (2) 

Additions to foreclosed assets (3) 

$ 

$ 

24 

72 

96 

103 

164 

267 

451 

522 

1 

193 

Reductions: 

Sales 

Write-downs and gains (losses) on sales 

Total reductions	 

Balance, end of period	 

(274) 

9 

(265) 

$ 

451 

87 

31 

63 

94 

170 

171 

341 

522 

499 

(3)

209 

(181) 

(2)

(183) 

522 

90 

42 

61 

103 

134 

172 

306 

499 

571 

 (13)

191 

(257) 

7 

(250) 

499 

103 

59 

58 

117 

162 

189 

351 

571 

642 

 (17)

185 

88 

24 

72 

96 

103 

164 

267 

451 

642 

 (32) 

778 

120 

57 

62 

119 

207 

196 

403 

642 

978 

(77) 

899 

(245) 

(957) 

(1,125) 

6 

(239) 

571 

20 

(33) 

(937) 

(1,158) 

451 

642 

(1) 	Foreclosed government insured/guaranteed loans are temporarily transferred to and held by us as servicer, until reimburseme nt is received from FHA or VA. The net change 
in government insured/guaranteed foreclosed assets is generally made up of inflows from mortgages held for investment and MLHFS, and outflows when we are reimbursed 
by FHA/VA. 

(2) 	Includes loans moved into foreclosure from nonaccrual status, PCI loans transitioned directly to foreclosed assets and repossessed automobiles. 

Foreclosed assets at December 31, 2018, included 

$317 million of foreclosed residential real estate, of which 28% is 
predominantly FHA insured or VA guaranteed and expected to 
have minimal or no loss content. The remaining foreclosed 
assets balance of $134 million has been written down to 
estimated net realizable value. Of the $451 million in foreclosed 
assets at December 31, 2018, 65% have been in the foreclosed 
assets portfolio one year or less. 

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Wells Fargo & Company 

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TROUBLED DEBT RESTRUCTURINGS (TDRs) 

Table 31:  Troubled Debt Restructurings (TDRs) 

(in millions) 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial TDRs 

Consumer: 

2018 

2017 

2016 

2015 

2014 

December 31, 

$ 

1,623 

704 

39 

56 

2,096 

901 

44 

35

2,584 

1,119 

91 

 6

2,422 

3,076 

3,800 

1,123 

1,456 

125 

 1

2,705 

724 

1,880 

314 

 2

2,920 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

10,629 

1,639 

12,080 

1,849 

14,134 

2,074 

16,812 

2,306 

18,226 

2,437 

Credit Card 

Automobile 

Other revolving credit and installment 

Trial modifications 

Total consumer TDRs 

Total TDRs 

TDRs on nonaccrual status 

TDRs on accrual status: 

Government insured/guaranteed 

Non-government insured/guaranteed 

449 

89 

154 

149 

13,109 

15,531 

4,058 

1,299 

10,174 

$ 

$ 

Total TDRs 

$ 

15,531 

Table 32:  TDRs Balance by Quarter During 2018 

(in millions) 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial TDRs 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit Card 

Automobile 

Other revolving credit and installment 

Trial modifications 

Total consumer TDRs 

Total TDRs 

TDRs on nonaccrual status 

TDRs on accrual status: 

Government insured/guaranteed 

Non-government insured/guaranteed 

Total TDRs 

356 

87 

126 

194 

14,692 

17,768 

4,801 

1,359 

11,608 

17,768 

300 

85 

101 

299 

16,993 

20,793 

6,193 

1,526 

13,074 

20,793 

299 

105 

73 

402 

19,997 

22,702 

6,506 

1,771 

14,425 

22,702 

338 

127 

49 

452 

21,629 

24,549 

7,104 

2,078 

15,367 

24,549 

Dec 31, 

Sep 30, 

2018 

2018 

Jun 30, 

2018 

Mar 31, 

2018 

$ 

1,623 

704 

39 

56 

1,837 

782 

49 

65 

1,792 

904 

40 

50 

1,703 

939 

45 

53 

2,422 

2,733 

2,786 

2,740 

10,629 

1,639 

10,967 

1,689 

11,387 

1,735 

11,782 

1,794 

449 

89 

154 

149 

13,109 

15,531 

4,058 

1,299 

10,174 

$ 

$ 

$ 

15,531 

431 

91 

146 

163 

13,487 

16,220 

4,298 

1,308 

10,614 

16,220 

410 

81 

141 

200 

13,954 

16,740 

4,454 

1,368 

10,918 

16,740 

386 

83 

137 

198 

14,380 

17,120 

4,428 

1,375 

11,317 

17,120 

Table 31 and Table 32 provide information regarding the 
recorded investment of loans modified in TDRs. The allowance 
for loan losses for TDRs was $1.2 billion and $1.6 billion at 
December 31, 2018 and 2017, respectively. See Note 6 (Loans 
and Allowance for Credit Losses) to Financial Statements in this 
Report for additional information regarding TDRs. In those 
situations where principal is forgiven, the entire amount of such 

forgiveness is immediately charged off to the extent not done so 
prior to the modification. When we delay the timing on the 
repayment of a portion of principal (principal forbearance), we 
charge off the amount of forbearance if that amount is not 
considered fully collectible. 

Our nonaccrual policies are generally the same for all loan 

types when a restructuring is involved. We typically 

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Risk Management – Credit Risk Management (continued) 

re-underwrite loans at the time of restructuring to determine 
whether there is sufficient evidence of sustained repayment 
capacity based on the borrower’s documented income, debt to 
income ratios, and other factors. Loans lacking sufficient 
evidence of sustained repayment capacity at the time of 
modification are charged down to the fair value of the collateral, 
if applicable. For an accruing loan that has been modified, if the 
borrower has demonstrated performance under the previous 
terms and the underwriting process shows the capacity to 
continue to perform under the restructured terms, the loan will 
generally remain in accruing status. Otherwise, the loan will be 
placed in nonaccrual status and may be returned to accruing 
status when the borrower demonstrates a sustained period of 
performance, generally six consecutive months of payments, or 

Table 33:  Analysis of Changes in TDRs 

equivalent, inclusive of consecutive payments made prior to 
modification. Loans will also be placed on nonaccrual, and a 
corresponding charge-off is recorded to the loan balance, when 
we believe that principal and interest contractually due under 
the modified agreement will not be collectible. 

Table 33 provides an analysis of the changes in TDRs. Loans 
modified more than once are reported as TDR inflows only in the 
period they are first modified. Other than resolutions such as 
foreclosures, sales and transfers to held for sale, we may remove 
loans held for investment from TDR classification, but only if 
they have been refinanced or restructured at market terms and 
qualify as a new loan. 

(in millions) 

Commercial TDRs 

Balance, beginning of period 

Inflows (1)(2) 

Outflows 

Charge-offs 

Foreclosure 

Payments, sales and other (2)(3) 

Balance, end of period	 

Consumer TDRs 

Balance, beginning of period 

Inflows (1) 

Outflows 

Charge-offs 

Foreclosure 

Payments, sales and other (3) 

Net change in trial modifications (4) 

Balance, end of period	 

Total TDRs	 

Dec 31, 

Sep 30, 

Jun 30, 

Mar 31, 

Year ended Dec 31, 

2018 

2018 

2018 

2018 

2018 

2017 

Quarter ended 

$ 

2,733 

374 

(88) 

(2) 

(595) 

2,786 

588 

(92) 

(13)

(536) 

2,740 

481 

(41) 

— 

(394) 

3,076 

321 

3,076 

1,764 

(63) 

— 

(284) 

(15) 

3,800 

2,117 

(306) 

(15) 

(594) 

(2,119) 

(2,520) 

2,422 

2,733 

2,786 

2,740 

2,422 

3,076 

13,487 

379 

(57) 

(90) 

(595) 

(15) 

13,109 

$ 

15,531 

13,954 

414 

(56) 

(116) 

(672) 

(37)

13,487 

16,220 

14,380 

467 

(56) 

(133) 

(706) 

2 

13,954 

16,740 

14,692 

487 

14,692 

1,747 

(54) 

(131) 

(618) 

4 

14,380 

17,120 

(223) 

(470) 

(2,591) 

(46) 

13,109 

15,531 

16,993 

1,817 

(205) 

(619) 

(3,189) 

(105) 

14,692 

17,768 

(1) 	 Inflows include loans that modify, even if they resolve within the period, as well as gross advances on term loans that modified in a prior period and net advances on 

revolving commercial TDRs that modified in a prior period. 

(2) 	 Information for the quarter ended June 30, 2018, has been revised to offset payments and advances (i.e., inflows) on revolving commercial TDRs, for consistent 

presentation of this activity for all periods. 

(3) 	 Other outflows include normal amortization/accretion of loan basis adjustments and loans transferred to held-for-sale. It also includes $59 million and $5 million of loans 

refinanced or restructured at market terms and qualifying as new loans and removed from TDR classification for the quarters ended December 31 and March 31, 2018, 
respectively, while no loans were removed from TDR classification for the quarters ended September 30 and June 30, 2018. During 2017, $6 million of loans refinanced or 
structured as new loans and were removed from TDR classification. 

(4) 	 Net change in trial modifications includes: inflows of new TDRs entering the trial payment period, net of outflows for modifications that either (i) successfully perform and 

enter into a permanent modification, or (ii) did not successfully perform according to the terms of the trial period plan and are subsequently charged-off, foreclosed upon or 
otherwise resolved. 

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LOANS 90 DAYS OR MORE PAST DUE AND STILL ACCRUING 
Loans 90 days or more past due as to interest or principal are 
still accruing if they are (1) well-secured and in the process of 
collection or (2) real estate 1-4 family mortgage loans or 
consumer loans exempt under regulatory rules from being 
classified as nonaccrual until later delinquency, usually 120 days 
past due. PCI loans are not included in past due and still 
accruing loans even when they are 90 days or more contractually 
past due. These PCI loans are considered to be accruing because 
they continue to earn interest from accretable yield, independent 
of performance in accordance with their contractual terms. 

Excluding insured/guaranteed loans, loans 90 days or more 

past due and still accruing at December 31, 2018, were down 
$78 million, or 7%, from December 31, 2017, due to payoffs, 
modifications and other loss mitigation activities and credit 
stabilization. 

Table 34:  Loans 90 Days or More Past Due and Still Accruing (1) 

Loans 90 days or more past due and still accruing whose 

repayments are predominantly insured by the FHA or 
guaranteed by the VA for mortgages were $7.7 billion at 
December 31, 2018, down from $10.5 billion at December 31, 
2017, due to an improvement in delinquencies, loan 
modification activity, as well as runoff. All remaining student 
loans guaranteed by agencies on behalf of the U.S. Department 
of Education under the FFELP were sold as of March 31, 2017. 
Table 34 reflects non-PCI loans 90 days or more past due 

and still accruing by class for loans not government insured/ 
guaranteed. For additional information on delinquencies by loan 
class, see Note 6 (Loans and Allowance for Credit Losses) to 
Financial Statements in this Report. 

(in millions) 

Total (excluding PCI)(2): 

2018 

2017 

2016 

2015 

2014 

$ 

8,704 

11,532 

11,437 

13,866 

17,183 

December 31, 

Less: FHA insured/VA guaranteed (3) 

7,725 

10,475 

10,467 

12,863 

16,204 

Less: Student loans guaranteed under the FFELP (4) 

— 

—

Total, not government insured/guaranteed	 

$ 

979 

1,057 

By segment and class, not government insured/guaranteed: 

$

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Total commercial	 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer	 

Total, not government insured/guaranteed	 

$ 

 43

51 

— 

94 

124 

32 

513 

114 

102 

885 

979 

  26 

23 

—

49 

213 

60 

492 

143 

100 

1,008 

1,057 

 3

967 

28 

36 

— 

64

170 

56 

452 

112 

113 

903 

967 

26

977 

97 

13 

4

114 

220 

65 

397 

79 

102 

863 

977 

 63 

916 

31 

16 

— 

47 

256 

83 

364 

73 

93 

869 

916 

(1) 	 Financial information for periods prior to December 31, 2018, has been revised to exclude MLHFS, LHFS and loans held at fair value, which reduced “Total, not government 

insured/guaranteed” by $6 million, $5 million, $4 million and $4 million at December 31, 2017, 2016, 2015 and 2014, respectively. 

(2) 	 PCI loans totaled $370 million, $1.4 billion, $2.0 billion, $2.9 billion and $3.7 billion at December 31, 2018, 2017, 2016, 2015 and 2014, respectively. 
(3) 	 Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. 
(4) 	 Represents loans whose repayments are largely guaranteed by agencies on behalf of the U.S. Department of Education under the FFELP. All remaining student loans 

guaranteed under the FFELP were sold as of March 31, 2017. 

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Risk Management – Credit Risk Management (continued) 

NET CHARGE-OFFS 

Table 35:  Net Charge-offs 

($ in millions) 

2018 

Commercial: 

Year ended 

Quarter ended 

December 31, 

December 31, 

September 30, 

June 30, 

March 31, 

Net loan 

% of 

Net loan 

% of 

Net loan 

% of 

Net loan 

% of 

Net loan 

% of 

charge-
offs 

avg. 
loans 

charge-
offs 

avg. 
loans (1) 

charge-
offs 

avg. 
loans (1) 

charge-
offs 

avg. 
loans (1) 

charge-
offs 

avg. 
loans (1) 

Commercial and industrial 

$ 

Real estate mortgage 
Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first 

mortgage 

Real estate 1-4 family

junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and

installment 

Total consumer 

Total 

2017 

Commercial: 

Commercial and industrial 

$ 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first 

mortgage 

Real estate 1-4 family junior

lien mortgage 

Credit card 

Automobile 

Other revolving credit and

installment 

Total consumer 

Total 

423 
(28) 
(13) 
47 

429 

0.13%  $ 

132 

0.15%  $ 

148 

0.18%  $ 

(0.02) 
(0.05) 

0.24 

0.09 

(12) 
(1) 

13 

132 

(0.04) 
(0.01) 

0.26 

0.10 

(1) 
(2) 

7 

152 

— 

(0.04) 

0.14 

0.12 

58 

— 
(6) 

15 

67 

0.07%  $ 

— 

(0.09) 

0.32 

0.05 

85 

(15) 
(4) 

12 

78 

0.10% 

(0.05) 
(0.07) 

0.25 

0.06 

(88) 

(0.03) 

(22) 

(0.03) 

(25) 

(0.04) 

(23) 

(0.03) 

(18) 

(0.03) 

(40) 

(0.11) 

(10) 

(0.11) 

(9) 

(0.10) 

(13) 

(0.13) 

(8) 

(0.09) 

1,292 
584 

567 

2,315 

3.51 

1.21 

1.53 

0.52 

$  2,744 

0.29%  $ 

338 

133 

150 

589 

721 

3.54 

1.16 

1.64 

0.53 

0.30%  $ 

299 

130 

133 

528 

680 

3.22 

1.10 

1.44 

0.47 

0.29%  $ 

323 

113 

135 

535 

602 

3.61 

0.93 

1.44 

0.49 

0.26%  $ 

492 

(44) 

(30) 

28 

446 

0.15 %  $ 

(0.03) 

(0.12) 

0.15 

0.09 

118 
(10) 
(3) 
10 

115 

0.14 %  $ 

(0.03) 

(0.05) 

0.20 

0.09 

125 

(3) 

(15) 

6 

113 

0.15 %  $ 

(0.01) 

(0.24) 

0.12 

0.09 

78 

(6) 

(4) 

7 

75 

0.10 %  $ 

(0.02) 

(0.05) 

0.15 

0.06 

(48) 

(0.02) 

(23) 

(0.03) 

(16) 

(0.02) 

(16) 

(0.02) 

7 

0.01 

13 

1,242 

683 

592 

2,482 

0.03 

3.49 
1.18 

1.52 

0.55 

$ 

2,928 

0.31 %  $ 

(7) 

(0.06) 

336 
188 

142 

636 

751 

3.66 
1.38 

1.46 

0.56 

0.31 %  $ 

1 

277 
202 

140 

604 

717 

— 

3.08 
1.41 

1.44 

0.53 

0.30 %  $ 

(4) 

(0.03) 

320 
126 

154 

580 

655 

3.67 
0.86 

1.58 

0.51 

0.27 %  $ 

23 

309 
167 

156 

662 

805 

0.21 

3.54 
1.10 

1.60 

0.59 

0.34 % 

332 

208 

149 

663 

741 

171 

(25) 

(8) 

5 

143 

3.69 

1.64 

1.60 

0.60 

0.32% 

0.21 % 

(0.08) 

(0.15) 

0.11 

0.11 

(1)  Quarterly net charge-offs (recoveries) as a percentage of average respective loans are annualized. 

Table 35 presents net charge-offs for the four quarters and full 
year of 2018 and 2017. Net charge-offs in 2018 were $2.7 billion 
(0.29% of average total loans outstanding), compared with 
$2.9 billion (0.31%) in 2017. 

The decrease in commercial and industrial net charge-offs 

in 2018 reflected continued improvement in our oil and gas 
portfolio. Our commercial real estate portfolios were in a net 
recovery position every quarter in 2018 and 2017. Total net 
charge-offs decreased from the prior year across all consumer 
portfolios, except for the credit card portfolio, which had a slight 
increase. 

ALLOWANCE FOR CREDIT LOSSES  The allowance for credit 
losses, which consists of the allowance for loan losses and the 
allowance for unfunded credit commitments, is management’s 
estimate of credit losses inherent in the loan portfolio and 
unfunded credit commitments at the balance sheet date, 
excluding loans carried at fair value. The detail of the changes in 
the allowance for credit losses by portfolio segment (including 
charge-offs and recoveries by loan class) is in Note 6 (Loans and 
Allowance for Credit Losses) to Financial Statements in this 
Report. 

We apply a disciplined process and methodology to 
establish our allowance for credit losses each quarter. This 

process takes into consideration many factors, including 
historical and forecasted loss trends, loan-level credit quality 
ratings and loan grade-specific characteristics. The process 
involves subjective and complex judgments. In addition, we 
review a variety of credit metrics and trends. These credit 
metrics and trends, however, do not solely determine the 
amount of the allowance as we use several analytical tools. Our 
estimation approach for the commercial portfolio reflects the 
estimated probability of default in accordance with the 
borrower’s financial strength, and the severity of loss in the 
event of default, considering the quality of any underlying 
collateral. Probability of default and severity at the time of 
default are statistically derived through historical observations of 
defaults and losses after default within each credit risk rating. 
Our estimation approach for the consumer portfolio uses 
forecasted losses that represent our best estimate of inherent 
loss based on historical experience, quantitative and other 
mathematical techniques. For additional information on our 
allowance for credit losses, see the “Critical Accounting Policies 
– Allowance for Credit Losses” section and Note 1 (Summary of 
Significant Accounting Policies) and Note 6 (Loans and 
Allowance for Credit Losses) to Financial Statements in this 
Report. 

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Table 36 presents the allocation of the allowance for credit 

losses by loan segment and class for the last five years. 

Table 36:  Allocation of the Allowance for Credit Losses (ACL) 

Dec 31, 2018 

Dec 31, 2017 

Dec 31, 2016 

Dec 31, 2015 

Dec 31, 2014 

Loans 

as % 

of total 

Loans 

as % 

of total 

Loans 

as % 

of total 

Loans 

as % 

of total 

Loans 

as % 

of total 

ACL 

loans 

ACL 

loans 

ACL 

loans 

ACL 

loans 

ACL 

loans 

(in millions) 

Commercial: 

Commercial and industrial 

$  3,628 

37%  $  3,752 

35%  $  4,560 

34%  $  4,231 

33%  $  3,506 

32% 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

1,282 

1,200 

307 

6,417 

13 

2 

2 

54 

1,374 

1,238 

268

13 

3 

2 

1,320 

1,294 

220

14 

2 

2 

1,264 

1,210 

167

13 

3 

1 

1,576 

1,097 

198

13 

2 

1 

6,632 

53 

7,394 

52 

6,872 

50 

6,377 

48 

Real estate 1-4 family first mortgage 

750 

30 

1,085 

30 

1,270 

29 

1,895 

30 

2,878 

31 

Real estate 1-4 family junior lien 

mortgage 

Credit card 

Automobile 

431 

2,064 

475 

Other revolving credit and installment 

570 

3 

4 

5 

4 

608 

1,944 

1,039

652

4 

4 

5 

4 

815 

1,605 

817

639

5 

4 

6 

4 

1,223 

1,412 

529

581

6 

4 

6 

4 

1,566 

1,271 

516

561

7 

4 

6 

4 

Total consumer 

Total 

4,290 

46 

5,328 

47 

5,146 

48 

5,640 

50 

6,792 

52 

$10,707 

100%  $11,960 

100%  $12,540 

100%  $12,512 

100%  $13,169 

100% 

Dec 31, 2018 

Dec 31, 2017 

Dec 31, 2016 

Dec 31, 2015 

Dec 31, 2014 

Components: 

Allowance for loan losses 

Allowance for unfunded credit 

commitments 

Allowance for credit losses 

Allowance for loan losses as a percentage

of total loans 

Allowance for loan losses as a percentage

of total net charge-offs 

Allowance for credit losses as a 
percentage of total loans 

Allowance for credit losses as a 

percentage of total nonaccrual loans (1) 

$ 

$ 

9,775 

932 

10,707 

1.03% 

356 

1.12 

165 

11,004 

956 

11,960 

1.15 

376 

1.25 

156 

11,419 

1,121 

12,540 

1.18 

324 

1.30 

126 

11,545 

967 

12,512 

1.26 

399 

1.37 

115 

12,319 

850 

13,169 

1.43 

418 

1.53 

107 

(1)  Financial information for periods prior to December 31, 2018, has been revised to exclude MLHFS, LHFS and loans held at fair value from nonaccrual loans. 

In addition to the allowance for credit losses, there was 

$480 million at December 31, 2018, and $474 million at 
December 31, 2017, of nonaccretable difference to absorb losses 
for PCI loans, which totaled $5.0 billion at December 31, 2018. 
The allowance for credit losses is lower than otherwise would 
have been required without PCI loan accounting. As a result of 
PCI loans, certain ratios of the Company may not be directly 
comparable with credit-related metrics for other financial 
institutions. Additionally, loans purchased at fair value, 
including loans from the GE Capital business acquisitions in 
2016, generally reflect a lifetime credit loss adjustment and 
therefore do not initially require additions to the allowance as is 
typically associated with loan growth. For additional information 
on PCI loans, see the “Risk Management – Credit Risk 
Management – Purchased Credit-Impaired Loans” section, 
Note 1 (Summary of Significant Accounting Policies) and Note 6 
(Loans and Allowance for Credit Losses) to Financial Statements 
in this Report. 

The ratio of the allowance for credit losses to total 
nonaccrual loans may fluctuate significantly from period to 
period due to such factors as the mix of loan types in the 

portfolio, borrower credit strength and the value and 
marketability of collateral. 

The allowance for credit losses decreased $1.3 billion, or 

10%, in 2018, due to continued improvement in the credit 
quality of our residential real estate portfolios and a decrease in 
allowance for our automobile portfolio reflecting an 
improvement in our outlook for hurricane-related losses in 
Puerto Rico, partially offset by an increase in allowance for the 
credit card portfolio. Total provision for credit losses was 
$1.7 billion in 2018, $2.5 billion in 2017, and $3.8 billion in 
2016. The provision for credit losses was $1.0 billion less than 
net charge-offs in 2018, reflecting the same changes mentioned 
above for the allowance for credit losses, compared with 
$400 million less than net charge-offs in 2017. The 2016 
provision was $250 million more than net charge-offs. 

We believe the allowance for credit losses of $10.7 billion at 

December 31, 2018, was appropriate to cover credit losses 
inherent in the loan portfolio, including unfunded credit 
commitments, at that date. The entire allowance is available to 
absorb credit losses inherent in the total loan portfolio. The 
allowance for credit losses is subject to change and reflects 

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Risk Management – Credit Risk Management (continued) 

existing factors as of the date of determination, including 
economic or market conditions and ongoing internal and 
external examination processes. Due to the sensitivity of the 
allowance for credit losses to changes in the economic and 
business environment, it is possible that we will incur 
incremental credit losses not anticipated as of the balance sheet 
date. Future allowance levels will be based on a variety of factors, 
including loan growth, portfolio performance and general 
economic conditions. Our process for determining the allowance 
for credit losses is discussed in the “Critical Accounting Policies 
– Allowance for Credit Losses” section and Note 1 (Summary of 
Significant Accounting Policies) to Financial Statements in this 
Report. 

LIABILITY FOR MORTGAGE LOAN REPURCHASE LOSSES 
We sell residential mortgage loans to various parties, including 
(1) government-sponsored entities (GSEs) Federal Home Loan 
Mortgage Corporation (FHLMC) and Federal National Mortgage 
Association (FNMA) who include the mortgage loans in GSE-
guaranteed mortgage securitizations, (2) SPEs that issue private 
label MBS, and (3) other financial institutions that purchase 
mortgage loans for investment or private label securitization. In 
addition, we pool FHA-insured and VA-guaranteed mortgage 
loans that are then used to back securities guaranteed by the 
Government National Mortgage Association (GNMA). We may 
be required to repurchase these mortgage loans, indemnify the 
securitization trust, investor or insurer, or reimburse the 
securitization trust, investor or insurer for credit losses incurred 
on loans (collectively, repurchase) in the event of a breach of 
contractual representations or warranties that is not remedied 
within a period (usually 90 days or less) after we receive notice 
of the breach. 

In connection with our sales and securitization of residential 

mortgage loans to various parties, we have established a 
mortgage repurchase liability, initially at fair value, related to 
various representations and warranties that reflect 
management’s estimate of losses for loans for which we could 
have a repurchase obligation, whether or not we currently 
service those loans, based on a combination of factors. Our 
mortgage repurchase liability estimation process also 
incorporates a forecast of repurchase demands associated with 
mortgage insurance rescission activity. 

The overall level of unresolved repurchase demands and 
mortgage insurance rescissions outstanding at December 31, 
2018, was $49 million, representing 230 loans, down from 
$108 million, or 482 loans, a year ago both in number of 
outstanding loans and in total dollar balances. The decrease was 
predominantly due to private investor demands resolved in third 
quarter 2018. 

Customary with industry practice, we have the right of 

recourse against correspondent lenders from whom we have 
purchased loans with respect to representations and warranties. 
Historical recovery rates as well as projected lender performance 
are incorporated in the establishment of our mortgage 
repurchase liability. 

We do not typically receive repurchase requests from 
GNMA, FHA and the Department of Housing and Urban 
Development (HUD) or VA. As an originator of an FHA-insured 
or VA-guaranteed loan, we are responsible for obtaining the 
insurance with the FHA or the guarantee with the VA. To the 
extent we are not able to obtain the insurance or the guarantee 
we must request permission to repurchase the loan from the 
GNMA pool. Such repurchases from GNMA pools typically 
represent a self-initiated process upon discovery of the 
uninsurable loan (usually within 180 days from funding of the 

loan). Alternatively, in lieu of repurchasing loans from GNMA 
pools, we may be asked by FHA/HUD or the VA to indemnify 
them (as applicable) for defects found in the Post Endorsement 
Technical Review process or audits performed by FHA/HUD or 
the VA. The Post Endorsement Technical Review is a process 
whereby HUD performs underwriting audits of closed/insured 
FHA loans for potential deficiencies. Our liability for mortgage 
loan repurchase losses incorporates probable losses associated 
with such indemnification. 

RISKS RELATING TO SERVICING ACTIVITIES  In addition to 
servicing loans in our portfolio, we act as servicer and/or master 
servicer of residential mortgage loans included in GSE-
guaranteed mortgage securitizations, GNMA-guaranteed 
mortgage securitizations of FHA-insured/VA-guaranteed 
mortgages and private label mortgage securitizations, as well as 
for unsecuritized loans owned by institutional investors. The 
following discussion summarizes the primary duties and 
requirements of servicing and related industry developments. 
The loans we service were originated by us or by other 
mortgage loan originators. As servicer, our primary duties are 
typically to (1) collect payments due from borrowers, (2) advance 
certain delinquent payments of principal and interest on the 
mortgage loans, (3) maintain and administer any hazard, title or 
primary mortgage insurance policies relating to the mortgage 
loans, (4) maintain any required escrow accounts for payment of 
taxes and insurance and administer escrow payments, (5) 
foreclose on defaulted mortgage loans or, to the extent 
consistent with the related servicing agreement, consider 
alternatives to foreclosure, such as loan modifications or short 
sales, and (6) for loans sold into private label securitizations, 
manage the foreclosed property through liquidation. As master 
servicer, our primary duties are typically to (1) supervise, 
monitor and oversee the servicing of the mortgage loans by the 
servicer, (2) consult with each servicer and use reasonable 
efforts to cause the servicer to observe its servicing obligations, 
(3) prepare monthly distribution statements to security holders 
and, if required by the securitization documents, certain periodic 
reports required to be filed with the SEC, (4) if required by the 
securitization documents, calculate distributions and loss 
allocations on the mortgage-backed securities, (5) prepare tax 
and information returns of the securitization trust, and (6) 
advance amounts required by non-affiliated servicers who fail to 
perform their advancing obligations. 

Each agreement under which we act as servicer or master 

servicer generally specifies a standard of responsibility for 
actions we take in such capacity and provides protection against 
expenses and liabilities we incur when acting in compliance with 
the specified standard. For example, private label securitization 
agreements under which we act as servicer or master servicer 
typically provide that the servicer and the master servicer are 
entitled to indemnification by the securitization trust for taking 
action or refraining from taking action in good faith or for errors 
in judgment. However, we are not indemnified, but rather are 
required to indemnify the securitization trustee, against any 
failure by us, as servicer or master servicer, to perform our 
servicing obligations or against any of our acts or omissions that 
involve willful misfeasance, bad faith or gross negligence in the 
performance of, or reckless disregard of, our duties. In addition, 
if we commit a material breach of our obligations as servicer or 
master servicer, we may be subject to termination if the breach is 
not cured within a specified period following notice, which can 
generally be given by the securitization trustee or a specified 
percentage of security holders. Whole loan sale contracts under 
which we act as servicer generally include similar provisions 

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• 	

interest rates may also have a direct or indirect effect on 
loan demand, collateral values, credit losses, mortgage 
origination volume, the fair value of MSRs and other 
financial instruments, the value of the pension liability and 
other items affecting earnings. 

We assess interest rate risk by comparing outcomes under 

various net interest income simulations using many interest rate 
scenarios that differ in the direction of interest rate changes, the 
degree of change over time, the speed of change and the 
projected shape of the yield curve. These simulations require 
assumptions regarding drivers of earnings and balance sheet 
composition such as loan originations, prepayment speeds on 
loans and debt securities, deposit flows and mix, as well as 
pricing strategies. 

Currently, our profile is such that we project net interest 
income will benefit modestly from higher interest rates as our 
assets would reprice faster and to a greater degree than our 
liabilities, while in the case of lower interest rates, our assets 
would reprice downward and to a greater degree than our 
liabilities. 

Our most recent simulations estimate net interest income 
sensitivity over the next two years under a range of both lower 
and higher interest rates. Measured impacts from standardized 
ramps (gradual changes) and shocks (instantaneous changes) 
are summarized in Table 37, indicating net interest income 
sensitivity relative to the Company’s base net interest income 
plan. Ramp scenarios assume interest rates move gradually in 
parallel across the yield curve relative to the base scenario in 
year one, and the full amount of the ramp is held as a constant 
differential to the base scenario in year two. The following 
describes the simulation assumptions for the scenarios 
presented in Table 37: 
• 	

Simulations are dynamic and reflect anticipated growth 
across assets and liabilities. 

• 	 Other macroeconomic variables that could be correlated 
with the changes in interest rates are held constant. 
• 	 Mortgage prepayment and origination assumptions vary 

across scenarios and reflect only the impact of the higher or 
lower interest rates. 

• 	 Our base scenario deposit forecast incorporates mix changes 
consistent with the base interest rate trajectory. Deposit mix 
is modeled to be the same as in the base scenario across the 
alternative scenarios. In higher interest rate scenarios, 
customer activity that shifts balances into higher-yielding 
products could reduce expected net interest income. 
• 	 We hold the size of the projected debt and equity securities 

portfolios constant across scenarios. 

with respect to our actions as servicer. The standards governing 
servicing in GSE-guaranteed securitizations, and the possible 
remedies for violations of such standards, vary, and those 
standards and remedies are determined by servicing guides 
maintained by the GSEs, contracts between the GSEs and 
individual servicers and topical guides published by the GSEs 
from time to time. Such remedies could include indemnification 
or repurchase of an affected mortgage loan. In addition, in 
connection with our servicing activities, we could become subject 
to consent orders and settlement agreements with federal and 
state regulators for alleged servicing issues and practices. In 
general, these can require us to provide customers with loan 
modification relief, refinancing relief, and foreclosure prevention 
and assistance, as well as can impose certain monetary penalties 
on us. 

Asset/Liability Management 
Asset/liability management involves evaluating, monitoring and 
managing interest rate risk, market risk, liquidity and funding. 
Primary oversight of interest rate risk and market risk resides 
with the Finance Committee of our Board of Directors (Board), 
which oversees the administration and effectiveness of financial 
risk management policies and processes used to assess and 
manage these risks. Primary oversight of liquidity and funding 
resides with the Risk Committee of the Board. At the 
management level we utilize a Corporate Asset/Liability 
Management Committee (Corporate ALCO), which consists of 
senior financial, risk, and business executives, to oversee these 
risks and report on them periodically to the Board’s Finance 
Committee and Risk Committee as appropriate. As discussed in 
more detail for market risk activities below, we employ separate 
management level oversight specific to market risk. 

INTEREST RATE RISK  Interest rate risk, which potentially can 
have a significant earnings impact, is an integral part of being a 
financial intermediary. We are subject to interest rate risk 
because: 
• 	

assets and liabilities may mature or reprice at different 
times (for example, if assets reprice faster than liabilities 
and interest rates are generally rising, earnings will initially 
increase); 
assets and liabilities may reprice at the same time but by 
different amounts (for example, when the general level of 
interest rates is rising, we may increase rates paid on 
checking and savings deposit accounts by an amount that is 
less than the general rise in market interest rates); 
short-term and long-term market interest rates may change 
by different amounts (for example, the shape of the yield 
curve may affect new loan yields and funding costs 
differently); 
the remaining maturity of various assets or liabilities may 
shorten or lengthen as interest rates change (for example, if 
long-term mortgage interest rates increase sharply, MBS 
held in the debt securities portfolio may pay down slower 
than anticipated, which could impact portfolio income); or 

• 	

• 	

• 	

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Risk Management – Asset/Liability Management (continued) 

Table 37:  Net Interest Income Sensitivity Over Next Two-Year 
Horizon Relative to Base Expectation 

Lower Rates 

Higher Rates 

100 bps
Ramp 
Parallel
Decrease 

100 bps
Instantaneous 
Parallel 
Increase 

200 bps
Ramp
Parallel 
Increase 

$ 

(0.9) - (0.4) 

0.9 - 1.4 

0.9 - 1.4 

($ in billions) 

Base 

First Year of 

Forecasting
Horizon 

Net Interest Income 
Sensitivity to
Base Scenario 

Key Rates at

Horizon End 

Fed Funds Target 

3.00  % 

10-year CMT (1) 

3.72 

2.00 

2.72 

4.00 

4.72 

5.00 

5.72 

Second Year of 
Forecasting
Horizon 

Net Interest Income 
Sensitivity to
Base Scenario 

Key Rates at

Horizon End 

$ 

(1.7) - (1.2) 

1.4 - 1.9 

2.3 - 2.8 

Fed Funds Target 

3.00  % 

10-year CMT (1) 

4.01 

2.00 

3.01 

4.00 

5.01 

5.00 

6.01 

(1) 	 U.S. Constant Maturity Treasury Rate 

The sensitivity results above do not capture interest rate 
sensitive noninterest income and expense impacts. Our interest 
rate sensitive noninterest income and expense is predominantly 
driven by mortgage activity, and may move in the opposite 
direction of our net interest income. Typically, in response to 
higher interest rates, mortgage activity, primarily refinancing 
activity, generally declines. And in response to lower interest 
rates, mortgage activity generally increases. Mortgage results are 
also impacted by the valuation of MSRs and related hedge 
positions. See the “Risk Management – Asset/Liability 
Management – Mortgage Banking Interest Rate and Market 
Risk” section in this Report for more information. 

Interest rate sensitive noninterest income also results from 
changes in earnings credit for noninterest-bearing deposits that 
reduce treasury management deposit service fees. Furthermore, 
for the trading portfolio, interest rate changes may result in net 
interest income compression (generally as interest rates rise) or 
expansion (generally as interest rates fall) that does not reflect 
the offsetting effects of certain economic hedges. Instead, as a 
result of GAAP requirements, the effects of such economic 
hedges are recorded in noninterest income. 

We use the debt securities portfolio and exchange-traded 
and over-the-counter (OTC) interest rate derivatives to hedge 
our interest rate exposures. See the “Balance Sheet Analysis – 
Available-for-Sale and Held-to-Maturity Debt Securities” section 
in this Report for more information on the use of the available-
for-sale and held-to-maturity securities portfolios. The notional 
or contractual amount, credit risk amount and fair value of the 
derivatives used to hedge our interest rate risk exposures as of 
December 31, 2018, and December 31, 2017, are presented in 
Note 17 (Derivatives) to Financial Statements in this Report. We 
use derivatives for asset/liability management in two main ways: 
to convert the cash flows from selected asset and/or liability 
• 	
instruments/portfolios including investments, commercial 
loans and long-term debt, from fixed-rate payments to 
floating-rate payments, or vice versa; and 
to economically hedge our mortgage origination pipeline, 
funded mortgage loans and MSRs using interest rate swaps, 
swaptions, futures, forwards and options. 

• 	

MORTGAGE BANKING INTEREST RATE AND MARKET RISK 
We originate, fund and service mortgage loans, which subjects 
us to various risks, including credit, liquidity and interest rate 
risks. Based on market conditions and other factors, we reduce 
credit and liquidity risks by selling or securitizing a majority of 
the long-term fixed-rate mortgage and ARM loans we originate. 
On the other hand, we may hold originated ARMs and fixed-rate 
mortgage loans in our loan portfolio as an investment for our 
deposits. We determine whether the loans will be held for 
investment or held for sale at the time of commitment. We may 
subsequently change our intent to hold loans for investment and 
sell some or all of our ARMs or fixed-rate mortgages as part of 
our corporate asset/liability management. We may also acquire 
and add to our securities available for sale a portion of the 
securities issued at the time we securitize MLHFS. 

Interest rate and market risk can be substantial in the 
mortgage business. Changes in interest rates may potentially 
reduce total origination and servicing fees, the value of our 
residential MSRs measured at fair value, the value of MLHFS 
and the associated income and loss reflected in mortgage 
banking noninterest income, the income and expense associated 
with instruments (economic hedges) used to hedge changes in 
the fair value of MSRs and MLHFS, and the value of derivative 
loan commitments (interest rate “locks”) extended to mortgage 
applicants. 

Interest rates affect the amount and timing of origination 
and servicing fees because consumer demand for new mortgages 
and the level of refinancing activity are sensitive to changes in 
mortgage interest rates. Typically, a decline in mortgage interest 
rates will lead to an increase in mortgage originations and fees 
and may also lead to an increase in servicing fee income, 
depending on the level of new loans added to the servicing 
portfolio and prepayments. Given the time it takes for consumer 
behavior to fully react to interest rate changes, as well as the 
time required for processing a new application, providing the 
commitment, and securitizing and selling the loan, interest rate 
changes will affect origination and servicing fees with a lag. The 
amount and timing of the impact on origination and servicing 
fees will depend on the magnitude, speed and duration of the 
change in interest rates. 

We measure originations of MLHFS at fair value where an 
active secondary market and readily available market prices exist 
to reliably support fair value pricing models used for these loans. 
Loan origination fees on these loans are recorded when earned, 
and related direct loan origination costs are recognized when 
incurred. We also measure at fair value certain of our other 
interests held related to residential loan sales and 
securitizations. We believe fair value measurement for MLHFS 
and other interests held, which we hedge with free-standing 
derivatives (economic hedges) along with our MSRs measured at 
fair value, reduces certain timing differences and better matches 
changes in the value of these assets with changes in the value of 
derivatives used as economic hedges for these assets. During 
2016, 2017, and 2018, in response to continued secondary 
market illiquidity, as well as our desire to retain high quality 
loans on our balance sheet, we continued to originate certain 
prime non-agency loans to be substantially held for investment. 
We did however designate a small portion of our non-agency 
originations in 2018 to MLHFS in support of future issuances of 
private label residential mortgage backed securities (RMBS). We 
issued $441 million of RMBS in fourth quarter 2018. 

We initially measure all of our MSRs at fair value and carry 
substantially all of them at fair value depending on our strategy 
for managing interest rate risk. Under this method, the MSRs 
are recorded at fair value at the time we sell or securitize the 

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Wells Fargo & Company 

96

  
 
 
 
related mortgage loans. The carrying value of MSRs carried at 
fair value reflects changes in fair value at the end of each quarter 
and changes are included in net servicing income, a component 
of mortgage banking noninterest income. If the fair value of the 
MSRs increases, income is recognized; if the fair value of the 
MSRs decreases, a loss is recognized. We use a dynamic and 
sophisticated model to estimate the fair value of our MSRs and 
periodically benchmark our estimates to independent appraisals. 
The valuation of MSRs can be highly subjective and involve 
complex judgments by management about matters that are 
inherently unpredictable. See “Critical Accounting Policies – 
Valuation of Residential Mortgage Servicing Rights” section in 
this Report for additional information. Changes in interest rates 
influence a variety of significant assumptions included in the 
periodic valuation of MSRs, including prepayment speeds, 
expected returns and potential risks on the servicing asset 
portfolio, the value of escrow balances and other servicing 
valuation elements. 

An increase in interest rates generally reduces the 

propensity for refinancing, extends the expected duration of the 
servicing portfolio and, therefore, increases the estimated fair 
value of the MSRs. However, an increase in interest rates can 
also reduce mortgage loan demand and, therefore, reduce 
origination income. A decline in interest rates generally 
increases the propensity for refinancing, reduces the expected 
duration of the servicing portfolio and therefore reduces the 
estimated fair value of MSRs. This reduction in fair value causes 
a charge to income for MSRs carried at fair value, net of any 
gains on free-standing derivatives (economic hedges) used to 
hedge MSRs. We may choose not to fully hedge the entire 
potential decline in the value of our MSRs resulting from a 
decline in interest rates because the potential increase in 
origination/servicing fees in that scenario provides a partial 
“natural business hedge.” 

The price risk associated with our MSRs is economically 
hedged with a combination of highly liquid interest rate forward 
instruments including mortgage forward contracts, interest rate 
swaps and interest rate options. All of the instruments included 
in the hedge are marked to fair value daily. Because the hedging 
instruments are traded in predominantly highly liquid markets, 
their prices are readily observable and are fully reflected in each 
quarter’s mark to market. Quarterly MSR hedging results 
include a combination of directional gain or loss due to market 
changes as well as any carry income generated. If the economic 
hedge is effective, its overall directional hedge gain or loss will 
offset the change in the valuation of the underlying MSR asset. 
Gains or losses associated with these economic hedges are 
included in mortgage banking noninterest income. Consistent 
with our longstanding approach to hedging interest rate risk in 
the mortgage business, the size of the hedge and the particular 
combination of forward hedging instruments at any point in 
time is designed to reduce the volatility of the mortgage 
business’s earnings over various time frames within a range of 
mortgage interest rates. Because market factors, the composition 
of the mortgage servicing portfolio and the relationship between 
the origination and servicing sides of our mortgage business 
change continually, the types of instruments used in our hedging 
are reviewed daily and rebalanced based on our evaluation of 
current market factors and the interest rate risk inherent in our 
MSRs portfolio. Throughout 2018, our economic hedging 
strategy generally used forward mortgage purchase contracts 
that were effective at offsetting the impact of interest rates on 
the value of the MSR asset. 

Mortgage forward contracts are designed to pass the full 
economics of the underlying reference mortgage securities to the 

holder of the contract, including both the directional gain and 
loss from the forward delivery of the reference securities and the 
corresponding carry income. Carry income represents the 
contract’s price accretion from the forward delivery price to the 
spot price including both the yield earned on the reference 
securities and the market implied cost of financing during the 
period. The actual amount of carry income earned on the hedge 
each quarter will depend on the amount of the underlying asset 
that is hedged and the particular instruments included in the 
hedge. The level of carry income is driven by the slope of the 
yield curve and other market driven supply and demand factors 
affecting the specific reference securities. A steep yield curve 
generally produces higher carry income while a flat or inverted 
yield curve can result in lower or potentially negative carry 
income. The level of carry income is also affected by the type of 
instrument used. In general, mortgage forward contracts tend to 
produce higher carry income than interest rate swap contracts. 
Carry income is recognized over the life of the mortgage forward 
as a component of the contract’s mark to market gain or loss. 

Hedging the various sources of interest rate risk in mortgage 

banking is a complex process that requires sophisticated 
modeling and constant monitoring. While we attempt to balance 
these various aspects of the mortgage business, there are several 
potential risks to earnings: 
• 	 Valuation changes for MSRs associated with interest rate 
changes are recorded in earnings immediately within the 
accounting period in which those interest rate changes 
occur, whereas the impact of those same changes in interest 
rates on origination and servicing fees occur with a lag and 
over time. Thus, the mortgage business could be protected 
from adverse changes in interest rates over a period of time 
on a cumulative basis but still display large variations in 
income from one accounting period to the next. 

• 	 The degree to which our net gains on loan originations 

offsets valuation changes for MSRs is imperfect, varies at 
different points in the interest rate cycle, and depends not 
just on the direction of interest rates but on the pattern of 
quarterly interest rate changes. 

• 	 Origination volumes, the valuation of MSRs and hedging 
results and associated costs are also affected by many 
factors. Such factors include the mix of new business 
between ARMs and fixed-rate mortgages, the relationship 
between short-term and long-term interest rates, the degree 
of volatility in interest rates, the relationship between 
mortgage interest rates and other interest rate markets, and 
other interest rate factors. Additional factors that can 
impact the valuation of the MSRs include changes in 
servicing and foreclosure costs due to changes in investor or 
regulatory guidelines, as well as individual state foreclosure 
legislation, and changes in discount rates due to market 
participants requiring a higher return due to updated 
market expectations on costs and risks associated with 
investing in MSRs. Many of these factors are hard to predict 
and we may not be able to directly or perfectly hedge their 
effect. 

• 	 While our hedging activities are designed to balance our 
mortgage banking interest rate risks, the financial 
instruments we use may not perfectly correlate with the 
values and income being hedged. For example, the change 
in the value of ARM production held for sale from changes 
in mortgage interest rates may or may not be fully offset by 
index-based financial instruments used as economic hedges 
for such ARMs. Additionally, hedge-carry income on our 
economic hedges for the MSRs may not continue at recent 
levels if the spread between short-term and long-term 

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Wells Fargo & Company 

97 

Risk Management – Asset/Liability Management (continued) 

interest rates decreases, the overall level of hedges changes 
as interest rates change, or there are other changes in the 
market for mortgage forwards that affect the implied carry. 

The total carrying value of our residential and commercial 
MSRs was $16.1 billion and $15.0 billion at December 31, 2018 
and 2017, respectively. The weighted-average note rate on our 
portfolio of loans serviced for others was 4.32% and 4.23% at 
December 31, 2018 and 2017, respectively. The carrying value of 
our total MSRs represented 0.94% and 0.88% of mortgage loans 
serviced for others at December 31, 2018 and 2017, respectively. 
As part of our mortgage banking activities, we enter into 
commitments to fund residential mortgage loans at specified 
times in the future. A mortgage loan commitment can be either a 
floating rate commitment, where the interest rate is not yet 
determined, or it can be an interest rate lock that binds us to 
lend funds to a potential borrower at a specified interest rate and 
within a specified period of time, generally up to 60 days after 
inception of the rate lock. These loan commitments are 
derivative loan commitments if the loans that will result from 
the exercise of the commitments will be held for sale. These 
derivative loan commitments are recognized at fair value on the 
balance sheet with changes in their fair values recorded as part 
of mortgage banking noninterest income. The fair value of these 
commitments include, at inception and during the life of the 
loan commitment, the expected net future cash flows related to 
the associated servicing of the loan as part of the fair value 
measurement of derivative loan commitments. Changes 
subsequent to inception are based on changes in fair value of the 
underlying loan resulting from the exercise of the commitment 
and changes in the probability that the loan will not fund within 
the terms of the commitment, referred to as a fall-out factor. The 
value of the underlying loan commitment is affected by changes 
in interest rates and the passage of time. 

Outstanding derivative loan commitments (interest rate 
“locks”) expose us to the risk that the price of the mortgage loans 
underlying the commitments might decline due to increases in 
mortgage interest rates from inception of the rate lock to the 
funding of the loan. To minimize this risk, we employ mortgage 
forwards and options and Eurodollar futures and options 
contracts as economic hedges against the potential decreases in 
the values of the loans. We expect that these derivative financial 
instruments will experience changes in fair value that will either 
fully or partially offset the changes in fair value of the derivative 
loan commitments. However, changes in investor demand, such 
as concerns about credit risk, can also cause changes in the 
spread relationships between underlying loan value and the 
derivative financial instruments that cannot be hedged. 

MARKET RISK  Market risk is the risk of possible economic loss 
from adverse changes in market risk factors such as interest 
rates, credit spreads, foreign exchange rates, equity and 
commodity prices, and the risk of possible loss due to 
counterparty risk. This includes implied volatility risk, basis risk, 
and market liquidity risk. Market risk also includes counterparty 
credit risk, price risk in the trading book, mortgage servicing 
rights and the associated hedge effectiveness risk associated with 
the mortgage book, and impairment on private equity 
investments. 

The Board’s Finance Committee has primary oversight 
responsibility for market risk and oversees the Company’s 
market risk exposure and market risk management strategies. In 
addition, the Board’s Risk Committee has certain oversight 
responsibilities with respect to market risk, including adjusting 
the Company’s market risk appetite with input from the Finance 
Committee. The Finance Committee also reports key market risk 
matters to the Risk Committee. 

At the management level, the Market and Counterparty Risk 

Management function, which is part of Corporate Risk, has 
primary oversight responsibility for market risk. The Market and 
Counterparty Risk Management function reports into the CRO 
and also provides periodic reporting related to market risk to the 
Board’s Finance Committee. In addition, the Risk & Control 
Committee for each business group and enterprise function 
reports market risk matters to the Enterprise Risk & Control 
Committee. 

MARKET RISK – TRADING ACTIVITIES  We engage in trading 
activities to accommodate the investment and risk management 
activities of our customers and to execute economic hedging to 
manage certain balance sheet risks. These trading activities 
predominantly occur within our Wholesale Banking businesses 
and to a lesser extent other divisions of the Company. Debt 
securities held for trading, equity securities held for trading, 
trading loans and trading derivatives are financial instruments 
used in our trading activities, and all are carried at fair value. 
Income earned on the financial instruments used in our trading 
activities include net interest income, changes in fair value and 
realized gains and losses. Net interest income earned from our 
trading activities is reflected in the interest income and interest 
expense components of our income statement. Changes in fair 
value of the financial instruments used in our trading activities 
are reflected in net gains on trading activities, a component of 
noninterest income in our income statement. For more 
information on the financial instruments used in our trading 
activities and the income from these trading activities, see 
Note 4 (Trading Activities) to Financial Statements in this 
Report. 

Value-at-risk (VaR) is a statistical measure used to estimate 

the potential loss from adverse moves in the financial markets. 
The Company uses VaR metrics complemented with sensitivity 
analysis and stress testing in measuring and monitoring market 
risk. These market risk measures are monitored at both the 
business unit level and at aggregated levels on a daily basis. Our 
corporate market risk management function aggregates and 
monitors all exposures to ensure risk measures are within our 
established risk appetite. Changes to the market risk profile are 
analyzed and reported on a daily basis. The Company monitors 
various market risk exposure measures from a variety of 
perspectives, including line of business, product, risk type, and 
legal entity. 

Trading VaR is the measure used to provide insight into the 

market risk exhibited by the Company’s trading positions. The 
Company calculates Trading VaR for risk management purposes 
to establish line of business and Company-wide risk limits. 
Trading VaR is calculated based on all trading positions on our 
balance sheet. 

98 

Wells Fargo & Company 

98

Table 38 shows the Company’s Trading General VaR by risk 

category. As presented in Table 38, average Company Trading 
General VaR was $16 million for the quarter ended December 31, 
2018, compared with $12 million for the quarter ended 
September 30, 2018, and $13 million for the quarter ended 

Table 38:  Trading 1-Day 99% General VaR by Risk Category 

December 31, 2017. The increase in average Company Trading 
General VaR for the quarter ended December 31, 2018, was 
mainly driven by changes in portfolio composition. 

(in millions) 

end  Average 

Low 

High 

Period 

Period 
end 

Average 

Low 

High 

Period 
end 

Average 

Low 

High 

December 31, 2018 

September 30, 2018 

December 31, 2017 

Quarter ended 

Company Trading
General VaR Risk 
Categories 

Credit 

Interest rate 

Equity 

Commodity 

Foreign exchange 

$18

28 

5 

2 

1 

16

20

5

2

1

  13

24

 13 

14 

28 

18 

2

1

0

7 

4 

2 

5 

2 

0 

17

18 

5 

1

1

11 

6

4 

1

0

55

52 

7

2

1

12 

13 

10 

1 

0 

16

10 

11

1

0

11 

6

10 

1

0

28 

17 

14 

2 

1 

Diversification benefit (1) 

(33) 

(28) 

(25) 

(30)	 

(24) 

(25) 

Company Trading
General VaR 

$

 21

16

13 

12	 

12

13 

(1) 	 The period-end VaR was less than the sum of the VaR components described above, which is due to portfolio diversification. The diversification effect arises because the 
risks are not perfectly correlated causing a portfolio of positions to usually be less risky than the sum of the risks of the positions alone. The diversification benefit is not 
meaningful for low and high metrics since they may occur on different days. 

Sensitivity Analysis Given the inherent limitations of the VaR 
models, the Company uses other measures, including sensitivity 
analysis, to measure and monitor risk. Sensitivity analysis is the 
measure of exposure to a single risk factor, such as a 0.01% 
increase in interest rates or a 1% increase in equity prices. We 
conduct and monitor sensitivity on interest rates, credit spreads, 
volatility, equity, commodity, and foreign exchange exposure. 
Sensitivity analysis complements VaR as it provides an 
indication of risk relative to each factor irrespective of historical 
market moves. 

Stress Testing While VaR captures the risk of loss due to adverse 
changes in markets using recent historical market data, stress 
testing is designed to capture the Company’s exposure to 
extreme but low probability market movements. Stress scenarios 
estimate the risk of losses based on management’s assumptions 
of abnormal but severe market movements such as severe credit 
spread widening or a large decline in equity prices. These 
scenarios assume that the market moves happen instantaneously 
and no repositioning or hedging activity takes place to mitigate 
losses as events unfold (a conservative approach since 
experience demonstrates otherwise). 

An inventory of scenarios is maintained representing both 
historical and hypothetical stress events that affect a broad range 
of market risk factors with varying degrees of correlation and 
differing time horizons. Hypothetical scenarios assess the impact 
of large movements in financial variables on portfolio values. 
Typical examples include a 1% (100 basis point) increase across 
the yield curve or a 10% decline in equity market indexes. 
Historical scenarios utilize an event-driven approach: the stress 
scenarios are based on plausible but rare events, and the analysis 
addresses how these events might affect the risk factors relevant 
to a portfolio. 

The Company’s stress testing framework is also used in 
calculating results in support of the Federal Reserve Board’s 
Comprehensive Capital Analysis and Review (CCAR) and 
internal stress tests. Stress scenarios are regularly reviewed and 
updated to address potential market events or concerns. For 

more detail on the CCAR process, see the “Capital Management” 
section in this Report. 

MARKET RISK – EQUITY SECURITIES  We are directly and 
indirectly affected by changes in the equity markets. We make 
and manage direct investments in start-up businesses, emerging 
growth companies, management buy-outs, acquisitions and 
corporate recapitalizations. We also invest in non-affiliated 
funds that make similar private equity investments. These 
private equity investments are made within capital allocations 
approved by management and the Board. The Board’s policy is 
to review business developments, key risks and historical returns 
for the private equity investment portfolio at least annually. 
Management reviews these investments at least quarterly and 
assesses them for possible OTTI. For nonmarketable equity 
securities, the analysis is based on facts and circumstances of 
each individual investment and the expectations for that 
investment’s cash flows and capital needs, the viability of its 
business model and our exit strategy. Investments in 
nonmarketable equity securities include private equity 
investments accounted for under the equity method, fair value 
through net income, and the measurement alternative. 

In conjunction with the March 2008 initial public offering 

(IPO) of Visa, Inc. (Visa), we received approximately 
20.7 million shares of Visa Class B common stock, the class 
which was apportioned to member banks of Visa at the time of 
the IPO. To manage our exposure to Visa and realize the value of 
the appreciated Visa shares, we incrementally sold these shares 
through a series of sales, thereby eliminating this position as of 
September 30, 2015. As part of these sales, we agreed to 
compensate the buyer for any additional contributions to a 
litigation settlement fund for the litigation matters associated 
with the Class B shares we sold. Our exposure to this retained 
litigation risk has been updated quarterly and is reflected on our 
balance sheet. For additional information about the associated 
litigation matters, see the “Interchange Litigation” section in 
Note 16 (Legal Actions) to Financial Statements in this Report. 

99

Wells Fargo & Company 

99 

  
 
 
 
 
Risk Management – Asset/Liability Management (continued) 

As part of our business to support our customers, we trade 

The FRB, OCC and FDIC have proposed a rule that would 

public equities, listed/OTC equity derivatives and convertible 
bonds. We have parameters that govern these activities. We also 
have marketable equity securities that include investments 
relating to our venture capital activities. We manage these 
marketable equity securities within capital risk limits approved 
by management and the Board and monitored by Corporate 
ALCO and the Market Risk Committee. The fair value changes in 
these marketable equity securities are recognized in net income. 
For more information, see Note 8 (Equity Securities) to 
Financial Statements in this Report. 

Changes in equity market prices may also indirectly affect 

our net income by (1) the value of third-party assets under 
management and, hence, fee income, (2) borrowers whose 
ability to repay principal and/or interest may be affected by the 
stock market, or (3) brokerage activity, related commission 
income and other business activities. Each business line 
monitors and manages these indirect risks. 

LIQUIDITY AND FUNDING  The objective of effective liquidity 
management is to ensure that we can meet customer loan 
requests, customer deposit maturities/withdrawals and other 
cash commitments efficiently under both normal operating 
conditions and under periods of Wells Fargo-specific and/or 
market stress. To achieve this objective, the Board of Directors 
establishes liquidity guidelines that require sufficient asset-
based liquidity to cover potential funding requirements and to 
avoid over-dependence on volatile, less reliable funding markets. 
These guidelines are monitored on a monthly basis by the 
Corporate ALCO and on a quarterly basis by the Board of 
Directors. These guidelines are established and monitored for 
both the consolidated company and for the Parent on a stand­
alone basis to ensure that the Parent is a source of strength for 
its regulated, deposit-taking banking subsidiaries. 

Liquidity Standards  In September 2014, the FRB, OCC and 
FDIC issued a final rule that implements a quantitative liquidity 
requirement consistent with the liquidity coverage ratio (LCR) 
established by the Basel Committee on Banking Supervision 
(BCBS). The rule requires banking institutions, such as 
Wells Fargo, to hold high-quality liquid assets (HQLA), such as 
central bank reserves and government and corporate debt that 
can be converted easily and quickly into cash, in an amount 
equal to or greater than its projected net cash outflows during a 
30-day stress period. The rule is applicable to the Company on a 
consolidated basis and to our insured depository institutions 
with total assets greater than $10 billion. In addition, the FRB 
finalized rules imposing enhanced liquidity management 
standards on large bank holding companies (BHC) such as 
Wells Fargo, and has finalized a rule that requires large bank 
holding companies to publicly disclose on a quarterly basis 
certain quantitative and qualitative information regarding their 
LCR calculations. 

implement a stable funding requirement, the net stable funding 
ratio (NSFR), which would require large banking organizations, 
such as Wells Fargo, to maintain a sufficient amount of stable 
funding in relation to their assets, derivative exposures and 
commitments over a one-year horizon period. 

Liquidity Coverage Ratio  As of December 31, 2018, the 
consolidated Company and Wells Fargo Bank, N.A. were above 
the minimum LCR requirement of 100%, which is calculated as 
HQLA divided by projected net cash outflows, as each is defined 
under the LCR rule. Table 39 presents the Company’s quarterly 
average values for the daily-calculated LCR and its components 
calculated pursuant to the LCR rule requirements. 

Table 39:  Liquidity Coverage Ratio 

(in millions, except ratio) 

HQLA (1)(2) 

Projected net cash outflows 

LCR 

Average for Quarter ended
December 31, 2018 

$ 

366,578
 

303,158
 

121% 

(1) Excludes excess HQLA at Wells Fargo Bank, N.A. 
(2) Net of applicable haircuts required under the LCR rule. 

Liquidity Sources  We maintain liquidity in the form of cash, 
cash equivalents and unencumbered high-quality, liquid debt 
securities. These assets make up our primary sources of liquidity 
which are presented in Table 40. Our primary sources of 
liquidity are substantially the same in composition as HQLA 
under the LCR rule; however, our primary sources of liquidity 
will generally exceed HQLA calculated under the LCR rule due to 
the applicable haircuts to HQLA and the exclusion of excess 
HQLA at our subsidiary insured depository institutions required 
under the LCR rule. 

Our cash is predominantly on deposit with the Federal 
Reserve. Debt securities included as part of our primary sources 
of liquidity are comprised of U.S. Treasury and federal agency 
debt, and mortgage-backed securities issued by federal agencies 
within our debt securities portfolio. We believe these debt 
securities provide quick sources of liquidity through sales or by 
pledging to obtain financing, regardless of market conditions. 
Some of these debt securities are within the held-to-maturity 
portion of our debt securities portfolio and as such are not 
intended for sale but may be pledged to obtain financing. Some 
of the legal entities within our consolidated group of companies 
are subject to various regulatory, tax, legal and other restrictions 
that can limit the transferability of their funds. We believe we 
maintain adequate liquidity for these entities in consideration of 
such funds transfer restrictions. 

100 

Wells Fargo & Company 

100

 
Table 40:  Primary Sources of Liquidity 

December 31, 2018 

December 31, 2017 

(in millions) 

Total  Encumbered  Unencumbered 

Total 

Encumbered  Unencumbered 

Interest-earning deposits with banks 

$  149,736 

— 

149,736 

192,580 

Debt securities of U.S. Treasury and federal agencies 

57,688 

Mortgage-backed securities of federal agencies (1) 

244,211 

Total 

$  451,635 

1,504 

35,656 

37,160 

56,184 

51,125 

208,555 

246,894 

414,475 

490,599 

— 

964 

46,062 

47,026 

192,580 

50,161 

200,832 

443,573 

(1) 

Included in encumbered securities at December 31, 2018, were securities with a fair value of $261 million which were purchased in December 2018, but settled in January 
2019. 

In addition to our primary sources of liquidity shown in 
Table 40, liquidity is also available through the sale or financing 
of other debt securities including trading and/or available-for­
sale debt securities, as well as through the sale, securitization or 
financing of loans, to the extent such debt securities and loans 
are not encumbered. In addition, other debt securities in our 
held-to-maturity portfolio, to the extent not encumbered, may be 
pledged to obtain financing. 

Deposits have historically provided a sizable source of 
relatively low-cost funds. Deposits were 135% of total loans at 
December 31, 2018, and 140% at December 31, 2017. 

Table 41:  Short-Term Borrowings 

(in millions) 

Balance, period end 

Additional funding is provided by long-term debt and short-

term borrowings. We access domestic and international capital 
markets for long-term funding (generally greater than one year) 
through issuances of registered debt securities, private 
placements and asset-backed secured funding. 

Table 41 shows selected information for short-term 

borrowings, which generally mature in less than 30 days. 

Dec 31,
2018 

Sep 30,
2018 

Jun 30, 
2018 

Mar 31, 
2018 

Dec 31, 
2017 

Quarter ended 

Federal funds purchased and securities sold under agreements to repurchase 

$  92,430 

Other short-term borrowings 

Total 

Average daily balance for period 

Other short-term borrowings 

Total 

Maximum month-end balance for period 

Federal funds purchased and securities sold under agreements to repurchase 

$  93,483 

13,357 

92,418 

13,033 

89,307 

15,189 

80,916 

16,291 

88,684 

14,572 

$  105,787 

105,451 

104,496 

97,207 

103,256 

12,479 

92,141 

13,331 

89,138 

14,657 

86,535 

15,244 

88,197 

13,945 

$  105,962 

105,472 

103,795 

101,779 

102,142 

Federal funds purchased and securities sold under agreements to repurchase (1) 

$  93,918 

Other short-term borrowings (2) 

13,357 

92,531 

14,270 

92,103 

15,272 

88,121 

16,924 

91,604 

14,948 

(1)  Highest month-end balance in each of the last five quarters was in November, July, May and January 2018, and November 2017. 
(2)  Highest month-end balance in each of the last five quarters was in December, July, May and January 2018, and November 2017. 

Parent  In February 2017, the Parent filed a registration 
statement with the SEC for the issuance of senior and 
subordinated notes, preferred stock and other securities. The 
Parent’s ability to issue debt and other securities under 
this registration statement is limited by the debt issuance 
authority granted by the Board. As of December 31, 2018, the 
Parent was authorized by the Board to issue up to $180 billion in 
outstanding long-term debt. The Parent’s long-term debt 
issuance authority granted by the Board includes debt issued to 
affiliates and others. At December 31, 2018, the Parent had 
available $38.1 billion in long-term debt issuance authority. In 
2018, the Parent issued $2.0 billion of senior notes, of which 
$1.5 billion were registered with the SEC. In addition, the Parent 
issued $5.5 billion of registered senior notes in January 2019 
and issued CAD $1.0 billion of senior notes in February 2019 
that were registered in the U.S. and distributed on a private 
placement basis in Canada. The Parent’s short-term debt 
issuance authority granted by the Board was limited to debt 
issued to affiliates, and was revoked by the Board at 
management’s request in January 2018. 

The Parent’s proceeds from securities issued were used for 
general corporate purposes, and, unless otherwise specified in 

the applicable prospectus or prospectus supplement, we expect 
the proceeds from securities issued in the future will be used for 
the same purposes. Depending on market conditions, we may 
purchase our outstanding debt securities from time to time in 
privately negotiated or open market transactions, by tender 
offer, or otherwise. 

Wells Fargo Bank, N.A.  As of December 31, 2018, 
Wells Fargo Bank, N.A. was authorized by its board of directors 
to issue $100 billion in outstanding short-term debt and 
$175 billion in outstanding long-term debt and had available 
$99.1 billion in short-term debt issuance authority and 
$96.4 billion in long-term debt issuance authority. In April 2018, 
Wells Fargo Bank, N.A. established a new $100 billion bank note 
program under which, subject to any other debt outstanding 
under the limits described above, it may issue $50 billion in 
outstanding short-term senior notes and $50 billion in 
outstanding long-term senior or subordinated notes. At 
December 31, 2018, Wells Fargo Bank, N.A. had remaining 
issuance capacity under the new bank note program of 
$50.0 billion in short-term senior notes and $39.8 billion in 
long-term senior or subordinated notes. In 2018, Wells Fargo 

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Wells Fargo & Company 

101 

  
  
 
Risk Management – Asset/Liability Management (continued) 

Bank, N.A. issued $17.8 billion of unregistered senior notes, 
including $1.0 billion of senior redeemable floating rate notes 
issued in September 2018 with an interest rate indexed to the 
new Secured Overnight Financing Rate (SOFR) published by the 
Federal Reserve Bank of New York, and $6.0 billion of which 
were issued under a prior bank note program. SOFR is an 
alternative to the London Interbank Offered Rate (LIBOR) and is 
a broad measure of the cost of borrowing cash overnight 
collateralized by U.S. Treasury securities. Due to the uncertainty 
surrounding the future of LIBOR, it is expected that a transition 
away from the widespread use of LIBOR to alternative 
benchmark rates will occur by the end of 2021. Accordingly, the 
FASB recently issued a pronouncement that includes SOFR, 
among others, as a permitted benchmark interest rate for the 
application of hedge accounting. We have a significant amount 
of assets and liabilities referenced to LIBOR such as commercial 
loans, adjustable rate mortgage loans, derivatives, securities, and 
long-term debt. We have established a LIBOR Transition Office 
to develop and direct a coordinated strategy to transition 
numerous products and exposures away from LIBOR. The 
LIBOR Transition Office has initiated a comprehensive, 
company-wide process to address certain challenges and risks 
associated with the transition away from the widespread use of 
LIBOR and has directed an evaluation of the provisions in our 
contracts that could apply in connection with any 
discontinuation of, or change to, LIBOR, as well as the 
operational issues that could arise. In addition, regulators and 
trade associations periodically issue guidance, consultations and 
recommendations relating to LIBOR-transition matters, which 
will inform our overall planning. See the “Risk Factors” section 
in this Report for additional information regarding the potential 
impact of a benchmark rate, such as LIBOR, or other referenced 
financial metric being significantly changed, replaced or 
discontinued. 

Table 42:  Credit Ratings as of December 31, 2018 

Moody’s 

S&P Global Ratings 

Fitch Ratings, Inc. 

DBRS 

In addition, during 2018, Wells Fargo Bank, N.A. executed 
advances of $29.2 billion with the Federal Home Loan Bank of 
Des Moines, and as of December 31, 2018, Wells Fargo Bank, 
N.A. had outstanding advances of $49.6 billion across the 
Federal Home Loan Bank System. In addition, Wells Fargo 
Bank, N.A. executed $3.0 billion in Federal Home Loan Bank 
advances in February 2019. 

Credit Ratings  Investors in the long-term capital markets, as 
well as other market participants, generally will consider, among 
other factors, a company’s debt rating in making investment 
decisions. Rating agencies base their ratings on many 
quantitative and qualitative factors, including capital adequacy, 
liquidity, asset quality, business mix, the level and quality of 
earnings, and rating agency assumptions regarding the 
probability and extent of federal financial assistance or support 
for certain large financial institutions. Adverse changes in these 
factors could result in a reduction of our credit rating; however, 
our debt securities do not contain credit rating covenants. 

There were no actions undertaken by the rating agencies 
with regard to our credit ratings during fourth quarter 2018. 
Both the Parent and Wells Fargo Bank, N.A. remain among the 
highest-rated financial firms in the U.S. 

See the “Risk Factors” section in this Report for additional 

information regarding our credit ratings and the potential 
impact a credit rating downgrade would have on our liquidity 
and operations, as well as Note 17 (Derivatives) to Financial 
Statements in this Report for information regarding additional 
collateral and funding obligations required for certain derivative 
instruments in the event our credit ratings were to fall below 
investment grade. 

The credit ratings of the Parent and Wells Fargo Bank, N.A. 

as of December 31, 2018, are presented in Table 42. 

Wells Fargo & Company 

Wells Fargo Bank, N.A. 

Senior debt 

Short-term 
borrowings 

Long-term
deposits 

Short-term 
borrowings 

A2 

A­

A+ 

P-1 

A-2 

F1 

AA(low) 

R-1(middle) 

Aa1 

A+ 

AA 

AA 

P-1 

A-1 

F1+ 

R-1(high) 

FEDERAL HOME LOAN BANK MEMBERSHIP  The Federal 
Home Loan Banks (the FHLBs) are a group of cooperatives that 
lending institutions use to finance housing and economic 
development in local communities. We are a member of the 
FHLBs based in Dallas, Des Moines and San Francisco. Each 
member of the FHLBs is required to maintain a minimum 
investment in capital stock of the applicable FHLB. The board of 
directors of each FHLB can increase the minimum investment 

requirements in the event it has concluded that additional 
capital is required to allow it to meet its own regulatory capital 
requirements. Any increase in the minimum investment 
requirements outside of specified ranges requires the approval of 
the Federal Housing Finance Agency. Because the extent of any 
obligation to increase our investment in any of the FHLBs 
depends entirely upon the occurrence of a future event, potential 
future payments to the FHLBs are not determinable. 

Capital Management 

We have an active program for managing capital through a 
comprehensive process for assessing the Company’s overall 
capital adequacy. Our objective is to maintain capital at an 
amount commensurate with our risk profile and risk tolerance 
objectives, and to meet both regulatory and market expectations. 
We primarily fund our working capital needs through the 
retention of earnings net of both dividends and share 

repurchases, as well as through the issuance of preferred stock 
and long and short-term debt. Retained earnings increased 
$12.9 billion from December 31, 2017, predominantly from 
Wells Fargo net income of $22.4 billion, less common and 
preferred stock dividends of $9.5 billion. During 2018, we issued 
65.1 million shares of common stock. During 2018, we 
repurchased 375.5 million shares of common stock in open 

102 

Wells Fargo & Company 

102

  
market transactions, including through forward repurchase 
transactions, and from employee benefit plans, at a cost of 
$20.6 billion. The amount of our repurchases are subject to 
various factors as discussed in the “Securities Repurchases” 
section below. For additional information about our forward 
repurchase agreements, see Note 1 (Summary of Significant 
Accounting Policies) to Financial Statements in this Report. 

On September 17, 2018, we redeemed all of our 8.00% Non-

Cumulative Perpetual Class A Preferred Stock, Series J, at a 
redemption price equal to $1,000 per share. 

Regulatory Capital Guidelines 
The Company and each of our insured depository institutions are 
subject to various regulatory capital adequacy requirements 
administered by the FRB and the OCC. Risk-based capital (RBC) 
guidelines establish a risk-adjusted ratio relating capital to 
different categories of assets and off-balance sheet exposures as 
discussed below. 

RISK-BASED CAPITAL AND RISK-WEIGHTED ASSETS  The 
Company is subject to final and interim final rules issued by 
federal banking regulators to implement Basel III capital 
requirements for U.S. banking organizations. These rules are 
based on international guidelines for determining regulatory 
capital issued by the Basel Committee on Banking Supervision 
(BCBS). The federal banking regulators’ capital rules, among 
other things, require on a fully phased-in basis: 
• 	

a minimum Common Equity Tier 1 (CET1) ratio of 9.0%, 
comprised of a 4.5% minimum requirement plus a capital 
conservation buffer of 2.5% and for us, as a global 
systemically important bank (G-SIB), a capital surcharge to 
be calculated annually, which is 2.0% based on our year-
end 2017 data; 
a minimum tier 1 capital ratio of 10.5%, comprised of a 
6.0% minimum requirement plus the capital conservation 
buffer of 2.5% and the G-SIB capital surcharge of 2.0%; 
a minimum total capital ratio of 12.5%, comprised of a 
8.0% minimum requirement plus the capital conservation 
buffer of 2.5% and the G-SIB capital surcharge of 2.0%; 
a potential countercyclical buffer of up to 2.5% to be added 
to the minimum capital ratios, which is currently not in 
effect but could be imposed by regulators at their 
discretion if it is determined that a period of excessive 
credit growth is contributing to an increase in systemic 
risk; 
a minimum tier 1 leverage ratio of 4.0%; and 
a minimum supplementary leverage ratio (SLR) of 5.0% 
(comprised of a 3.0% minimum requirement plus a 
supplementary leverage buffer of 2.0%) for large and 
internationally active bank holding companies (BHCs). 

• 	

• 	

• 	

• 	
• 	

under the Standardized Approach and under the Advanced 
Approach. 

On April 10, 2018, the FRB issued a proposed rule that 
would add a stress capital buffer and a stress leverage buffer to 
the minimum capital and tier 1 leverage ratio requirements. 
The buffers would be calculated based on the decrease in a 
financial institution’s risk-based capital and tier 1 leverage 
ratios under the supervisory severely adverse scenario in 
CCAR, plus four quarters of planned common stock dividends. 
The stress capital buffer would replace the 2.5% capital 
conservation buffer under the Standardized Approach, 
whereas the stress leverage buffer would be added to the 
current 4% minimum tier 1 leverage ratio. 

Because the Company has been designated as a G-SIB, we 

are also subject to the FRB’s rule implementing the additional 
capital surcharge of between 1.0-4.5% on G-SIBs. Under the 
rule, we must annually calculate our surcharge under two 
methods and use the higher of the two surcharges. The first 
method (method one) considers our size, interconnectedness, 
cross-jurisdictional activity, substitutability, and complexity, 
consistent with the methodology developed by the BCBS and the 
Financial Stability Board (FSB). The second (method two) uses 
similar inputs, but replaces substitutability with use of short-
term wholesale funding and will generally result in higher 
surcharges than the BCBS methodology. The G-SIB surcharge 
became fully effective on January 1, 2019. Based on year-end 
2017 data, our 2019 G-SIB surcharge under method two is 2.0% 
of the Company’s RWAs, which is the higher of method one and 
method two. Because the G-SIB surcharge is calculated annually 
based on data that can differ over time, the amount of the 
surcharge is subject to change in future years. Under the 
Standardized Approach (fully phased-in), our CET1 ratio of 
11.74% exceeded the minimum of 9.0% by 274 basis points at 
December 31, 2018. 

The tables that follow provide information about our risk-

based capital and related ratios as calculated under Basel III 
capital guidelines. For banking industry regulatory reporting 
purposes, we continue to report our tier 2 and total capital in 
accordance with Transition Requirements but are managing our 
capital based on a fully phased-in calculation. For information 
about our capital requirements calculated in accordance with 
Transition Requirements, see Note 28 (Regulatory and Agency 
Capital Requirements) to Financial Statements in this Report. 

We were required to comply with the final Basel III 
capital rules beginning January 2014, with certain provisions 
subject to phase-in periods. Beginning January 1, 2018, the 
requirements for calculating CET1 and tier 1 capital, along 
with RWAs, became fully phased-in. However, the 
requirements for calculating tier 2 and total capital are still in 
accordance with Transition Requirements. The entire Basel III 
capital rules are scheduled to be fully phased in by the end of 
2021. The Basel III capital rules contain two frameworks for 
calculating capital requirements, a Standardized Approach, 
which replaced Basel I, and an Advanced Approach applicable 
to certain institutions, including Wells Fargo. Accordingly, in 
the assessment of our capital adequacy, we must report the 
lower of our CET1, tier 1 and total capital ratios calculated 

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103 

Capital Management (continued) 

Table 43 summarizes our CET1, tier 1 capital, total capital, 

risk-weighted assets and capital ratios on a fully phased-in basis 
at December 31, 2018 and December 31, 2017. As of 
December 31, 2018, our CET1, tier 1, and total capital ratios were 
lower using RWAs calculated under the Standardized Approach. 

Table 43:  Capital Components and Ratios (Fully Phased-In) (1) 

(in millions, except ratios) 

Common Equity Tier 1 

Tier 1 Capital 

Total Capital 

Risk-Weighted Assets 

Common Equity Tier 1 Capital Ratio 

Tier 1 Capital Ratio 

Total Capital Ratio 

December 31, 2018 

Advanced 
Approach 

Standardized 
Approach 

$ 

146,363 

167,866 

198,103 

146,363 

167,866 

206,346 

Advanced 
Approach 

154,022 

177,466 

208,395 

December 31, 2017 

Standardized 
Approach 

154,022 

177,466 

218,159 

1,177,350 

1,247,210 

1,225,939 

1,285,563 

12.43% 

14.26 

16.83 

11.74  * 

13.46  * 

16.54  * 

12.56 

14.48 

17.00 

11.98  * 

13.80  * 

16.97  * 

(A) 

(B) 

(C) 

(D) 

(A)/(D) 

(B)/(D) 

(C)/(D) 

Denotes the lowest capital ratio as determined under the Advanced and Standardized Approaches. 

* 	
(1) 	 Beginning January 1, 2018, the requirements for calculating CET1 and tier 1 capital, along with RWAs, became fully phased-in. However, the requirements for calculating 

tier 2 and total capital are still in accordance with Transition Requirements. Accordingly, fully phased-in total capital amounts and ratios are considered non-GAAP financial 
measures that are used by management, bank regulatory agencies, investors and analysts to assess and monitor the Company’s capital position. See Table 44 for 
information regarding the calculation and components of CET1, tier 1 capital, total capital and RWAs, as well as the corresponding reconciliation of our fully phased-in 
regulatory capital amounts to GAAP financial measures. 

104 

Wells Fargo & Company 

104

  
 
Table 44 provides information regarding the calculation and 

composition of our risk-based capital under the Advanced and 
Standardized Approaches at December 31, 2018 and 
December 31, 2017. 

Table 44:  Risk-Based Capital Calculation and Components 

(in millions) 

Total equity 

Adjustments: 

Preferred stock 
Additional paid-in capital on ESOP preferred stock 

Unearned ESOP shares 
Noncontrolling interests 

Total common stockholders’ equity 

Adjustments: 
Goodwill 

Certain identifiable intangible assets (other than MSRs) 
Other assets (1) 

Applicable deferred taxes (2) 
Investment in certain subsidiaries and other 

Common Equity Tier 1 (Fully Phased-In) 

Effect of Transition Requirements (3) 

Common Equity Tier 1 (Transition Requirements) 

Common Equity Tier 1 (Fully Phased-In)	 

Preferred stock 

Additional paid-in capital on ESOP preferred stock 

Unearned ESOP shares 

Other	 

Total Tier 1 capital (Fully Phased-In) 

Effect of Transition Requirements (3) 

Total Tier 1 capital (Transition Requirements) 

Total Tier 1 capital (Fully Phased-In) 

Long-term debt and other instruments qualifying as Tier 2 

Qualifying allowance for credit losses (4) 

Other	 

Total Tier 2 capital (Fully Phased-In) 

Effect of Transition Requirements 

Total Tier 2 capital (Transition Requirements) 

Total qualifying capital (Fully Phased-In) 

Total Effect of Transition Requirements 

Total qualifying capital (Transition Requirements) 

Risk-Weighted Assets (RWAs) (5)(6): 

Credit risk 

Market risk 

Operational risk 

December 31, 2018 

December 31, 2017 

Advanced 
Approach 

Standardized 
Approach 

$ 

197,066 

197,066 

Advanced 
Approach 

208,079 

Standardized 
Approach 

208,079 

(23,214) 
(95) 

1,502 
(900) 

(23,214) 
(95) 

1,502 
(900) 

174,359 

174,359 

(26,418) 

(559) 
(2,187) 

785 
383 

(26,418) 

(559) 
(2,187) 

785 
383 

146,363 

146,363 

—

— 

146,363 

146,363 

146,363 

23,214 

95 

(1,502) 

(304) 

146,363 

23,214 

95 

(1,502) 

(304) 

$ 

$ 

(A) 

167,866 

167,866 

—

— 

167,866 

167,866 

$ 

$ 

(B) 

167,866 

27,946 

2,463 

(172) 

30,237 

695 

$ 

30,932 

(A)+(B)  $ 

198,103 

695 

$ 

198,798 

167,866 

27,946 

10,706 

(172) 

38,480 

695 

39,175 

206,346 

695 

207,041 

$ 

803,273 

1,201,246 

45,964 

328,113 

45,964 

N/A 

(25,358) 
(122) 

1,678 
(1,143) 

183,134 

(26,587) 

(1,624) 
(2,155) 

962 
292 

154,022 

743 

154,765 

(25,358) 
(122) 

1,678 
(1,143) 

183,134 

(26,587) 

(1,624) 
(2,155) 

962 
292 

154,022 

743 

154,765 

154,022 

154,022 

25,358 

122 

(1,678) 

(358)

177,466 

743 

178,209 

177,466 

28,994 

2,196 

(261)

30,929 

1,195 

32,124 

208,395 

1,938 

210,333 

890,171 

36,168 

299,600 

25,358 

122 

(1,678) 

(358) 

177,466 

743 

178,209 

177,466 

28,994 

11,960 

(261) 

40,693 

1,195 

41,888 

218,159 

1,938 

220,097 

1,249,395 

36,168 

N/A 

Total RWAs (Fully Phased-In) (3) 

$ 

1,177,350 

1,247,210 

1,225,939 

1,285,563 

(1) 	 Represents goodwill and other intangibles on nonmarketable equity securities, which are included in other assets. 
(2) 	 Applicable deferred taxes relate to goodwill and other intangible assets. They were determined by applying the combined federal statutory rate and composite state income 

tax rates to the difference between book and tax basis of the respective goodwill and intangible assets at period end. 

(3) 	 Beginning January 1, 2018, the requirements for calculating CET1 and tier 1 capital, along with RWAs, became fully phased-in, so the effect of the transition requirements 

was $0 at December 31, 2018. 

(4) 	 Under the Advanced Approach the allowance for credit losses that exceeds expected credit losses is eligible for inclusion in Tier 2 Capital, to the extent the excess 

allowance does not exceed 0.6% of Advanced credit RWAs, and under the Standardized Approach, the allowance for credit losses is includable in Tier 2 Capital up to 1.25% 
of Standardized credit RWAs, with any excess allowance for credit losses being deducted from total RWAs. 

(5) 	 RWAs calculated under the Advanced Approach utilize a risk-sensitive methodology, which relies upon the use of internal credit models based upon our experience with 

internal rating grades. Advanced Approach also includes an operational risk component, which reflects the risk of operating loss resulting from inadequate or failed internal 
processes or systems. 

(6) 	 Under the regulatory guidelines for risk-based capital, on-balance sheet assets and credit equivalent amounts of derivatives and off-balance sheet items are assigned to 

one of several broad risk categories according to the obligor, or, if relevant, the guarantor or the nature of any collateral. The aggregate dollar amount in each risk category 
is then multiplied by the risk weight associated with that category. The resulting weighted values from each of the risk categories are aggregated for determining total 
RWAs. 

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Capital Management (continued) 

Table 45 presents the changes in Common Equity Tier 1 
under the Advanced Approach for the year ended December 31, 
2018. 

Table 45:  Analysis of Changes in Common Equity Tier 1 

(in millions) 

Common Equity Tier 1 (Fully Phased-In) at December 31, 2017 

$ 

154,022 

Net income applicable to common stock 

Common stock dividends 

Common stock issued, repurchased, and stock compensation-related items 

Goodwill 

Certain identifiable intangible assets (other than MSRs) 

Other assets (1) 

Applicable deferred taxes (2) 

Investment in certain subsidiaries and other 

Change in Common Equity Tier 1 

20,689 

(7,889) 

(17,881) 

170 

1,065 

(32) 

(177) 

(3,604) 

(7,659) 

Common Equity Tier 1 (Fully Phased-In) at December 31, 2018 

$ 

146,363 

(1) 	 Represents goodwill and other intangibles on nonmarketable equity securities, which are included in other assets. 
(2) 	 Applicable deferred taxes relate to goodwill and other intangible assets. They were determined by applying the combined federal statutory rate and composite state income 

tax rates to the difference between book and tax basis of the respective goodwill and intangible assets at period end. 

Table 46 presents net changes in the components of RWAs 
under the Advanced and Standardized Approaches for the year 
ended December 31, 2018. 

Table 46:  Analysis of Changes in RWAs 

(in millions) 

RWAs (Fully Phased-In) at December 31, 2017 

Net change in credit risk RWAs 

Net change in market risk RWAs 

Net change in operational risk RWAs 

Total change in RWAs 

RWAs (Fully Phased-In) at December 31, 2018 

Advanced Approach 

Standardized Approach 

$ 

$ 

1,225,939 

(86,898) 

9,796 

28,513 

(48,589) 

1,177,350 

1,285,563 

(48,149) 

9,796 

N/A 

(38,353) 

1,247,210 

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TANGIBLE COMMON EQUITY  We also evaluate our business 
based on certain ratios that utilize tangible common equity. 
Tangible common equity is a non-GAAP financial measure and 
represents total equity less preferred equity, noncontrolling 
interests, and goodwill and certain identifiable intangible assets 
(including goodwill and intangible assets associated with certain 
of our nonmarketable equity securities, but excluding mortgage 
servicing rights), net of applicable deferred taxes. These tangible 
common equity ratios are as follows: 
• 	 Tangible book value per common share, which represents 
tangible common equity divided by common shares 
outstanding. 

• 	 Return on average tangible common equity (ROTCE), which 

represents our annualized earnings contribution as a 
percentage of tangible common equity. 

The methodology of determining tangible common equity 

may differ among companies. Management believes that 
tangible book value per common share and return on average 
tangible common equity, which utilize tangible common equity, 
are useful financial measures because they enable investors and 
others to assess the Company’s use of equity. 

Table 47 provides a reconciliation of these non-GAAP 

financial measures to GAAP financial measures. 

Table 47:  Tangible Common Equity 

(in millions, except ratios) 

Total equity	 

Adjustments: 

Preferred stock 

Additional paid-in capital on ESOP preferred stock 

Unearned ESOP shares 

Noncontrolling interests 

Balance at period end 

Average balance for the year ended 

Dec 31,
2018 

Dec 31,
2017 

Dec 31,
2016 

Dec 31,
2018 

Dec 31,
2017 

Dec 31,
2016 

$ 197,066 

208,079 

200,497 

203,356 

205,654 

200,690 

(23,214) 

(25,358) 

(24,551) 

(24,956) 

(25,592) 

(24,363) 

(95) 

1,502 

(122) 

1,678 

(900) 

(1,143) 

(126) 

1,565 

(916) 

(125) 

2,159 

(929) 

(139) 

2,143 

(948) 

(161) 

2,011 

(936) 

Total common stockholders’ equity 

(A) 

174,359 

183,134 

176,469 

179,505 

181,118 

177,241 

Adjustments: 

Goodwill 

Certain identifiable intangible assets (other than

MSRs) 

Other assets (1) 

Applicable deferred taxes (2) 

Tangible common equity	 

Common shares outstanding	 

Net income applicable to common stock 

(B) 

(C) 

(D) 

(26,418) 

(26,587) 

(26,693) 

(26,453) 

(26,629) 

(26,700) 

(559) 

(1,624) 

(2,723) 

(2,187) 

(2,155) 

(2,088) 

785 

962 

1,772 

(1,088) 

(2,197) 

866 

(2,176) 

(3,254) 

(2,184) 

(2,117) 

1,570 

1,897 

$ 145,980 

153,730 

146,737 

150,633 

151,699 

147,067 

4,581.3 

4,891.6 

5,016.1 

N/A 

N/A 

N/A 

Book value per common share 

(A)/(C) 

$ 

38.06 

Tangible book value per common share 

(B)/(C) 

31.86 

Return on average common stockholders’ equity

(ROE) 

(D)/(A) 

Return on average tangible common equity (ROTCE)  (D)/(B) 

N/A 

N/A 

N/A 

N/A 

37.44 

31.43 

N/A 

N/A 

N/A 

$  20,689 

20,554 

20,373 

35.18 

29.25 

N/A 

N/A 

N/A 

N/A 

11.53  % 

13.73 

N/A 

N/A 

11.35 

13.55 

N/A 

N/A 

11.49 

13.85 

(1) 	 Represents goodwill and other intangibles on nonmarketable equity securities, which are included in other assets. 
(2) 	 Applicable deferred taxes relate to goodwill and other intangible assets. They were determined by applying the combined federal statutory rate and composite state income 

tax rates to the difference between book and tax basis of the respective goodwill and intangible assets at period end. 

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Capital Management (continued) 

SUPPLEMENTARY LEVERAGE RATIO  In April 2014, federal 
banking regulators finalized a rule that enhances the SLR 
requirements for BHCs, like Wells Fargo, and their insured 
depository institutions. The SLR consists of Tier 1 capital divided 
by the Company’s total leverage exposure. Total leverage 
exposure consists of the total average on-balance sheet assets, 
plus off-balance sheet exposures, such as undrawn commitments 
and derivative exposures, less amounts permitted to be deducted 
from Tier 1 capital. The rule, which became effective on 
January 1, 2018, requires a covered BHC to maintain a SLR of at 
least 5.0% (comprised of the 3.0% minimum requirement plus a 
supplementary leverage buffer of 2.0%) to avoid restrictions on 
capital distributions and discretionary bonus payments. The rule 
also requires that all of our insured depository institutions 
maintain a SLR of 6.0% under applicable regulatory capital 
adequacy guidelines. In April 2018, the FRB and OCC proposed 
rules (the “Proposed SLR Rules”) that would replace the 2% 
supplementary leverage buffer with a buffer equal to one-half of 
the firm’s G-SIB capital surcharge. The Proposed SLR Rules 
would similarly tailor the current 6% SLR requirement for our 
insured depository institutions. At December 31, 2018, our SLR 
for the Company was 7.7% calculated under the Advanced 
Approach capital framework. Based on our review, our current 
leverage levels would exceed the applicable requirements for 
each of our insured depository institutions as well. See Table 48 
for information regarding the calculation and components of the 
SLR. 

Table 48:  Supplementary Leverage Ratio 

$ 

(in millions, except ratio) 

Tier 1 capital 

Total average assets 

Less: deductions from Tier 1 capital (1) 

Total adjusted average assets 

Adjustments: 

Derivative exposures (2) 

Repo-style transactions (3) 

Other off-balance sheet exposures (4) 

Total adjustments 

Quarter ended 
December 31, 2018 

167,866 

1,879,047 

28,748 

1,850,299 

68,753 

5,350 

250,162 

324,265 

Total leverage exposure 

$ 

2,174,564 

Supplementary leverage ratio 

7.7% 

(1) 	 Amounts permitted to be deducted from Tier 1 capital primarily include 

goodwill and other intangible assets, net of associated deferred tax liabilities. 

(2) 	 Represents adjustments for off balance sheet derivative exposures, and 
derivative collateral netting as defined for supplementary leverage ratio 
determination purposes. 

(3) 	 Adjustments for repo-style transactions represent counterparty credit risk for 
all repo-style transactions where Wells Fargo & Company is the principal (i.e., 
principal counterparty facing the client). 

(4) 	 Adjustments for other off-balance sheet exposures represent the notional 

amounts of all off-balance sheet exposures (excluding off balance sheet 
exposures associated with derivative and repo-style transactions) less the 
adjustments for conversion to credit equivalent amounts under the regulatory 
capital rule. 

OTHER REGULATORY CAPITAL MATTERS In December 2016, 
the FRB finalized rules to address the amount of equity and 
unsecured long-term debt a U.S. G-SIB must hold to improve its 
resolvability and resiliency, often referred to as Total Loss 
Absorbing Capacity (TLAC). Under the rules, which became 
effective on January 1, 2019, U.S. G-SIBs are required to have a 
minimum TLAC amount (consisting of CET1 capital and 
additional tier 1 capital issued directly by the top-tier or covered 
BHC plus eligible external long-term debt) equal to the greater of 
(i) 18% of RWAs and (ii) 7.5% of total leverage exposure (the 

denominator of the SLR calculation). Additionally, U.S. G-SIBs 
are required to maintain (i) a TLAC buffer equal to 2.5% of 
RWAs plus the firm’s applicable G-SIB capital surcharge 
calculated under method one plus any applicable countercyclical 
buffer to be added to the 18% minimum and (ii) an external 
TLAC leverage buffer equal to 2.0% of total leverage exposure to 
be added to the 7.5% minimum, in order to avoid restrictions on 
capital distributions and discretionary bonus payments. The 
rules also require U.S. G-SIBs to have a minimum amount of 
eligible unsecured long-term debt equal to the greater of (i) 6.0% 
of RWAs plus the firm’s applicable G-SIB capital surcharge 
calculated under method two and (ii) 4.5% of the total leverage 
exposure. In addition, the rules impose certain restrictions on 
the operations and liabilities of the top-tier or covered BHC in 
order to further facilitate an orderly resolution, including 
prohibitions on the issuance of short-term debt to external 
investors and on entering into derivatives and certain other 
types of financial contracts with external counterparties. While 
the rules permit permanent grandfathering of a significant 
portion of otherwise ineligible long-term debt that was issued 
prior to December 31, 2016, long-term debt issued after that date 
must be fully compliant with the eligibility requirements of the 
rules in order to count toward the minimum TLAC amount. As a 
result of the rules, we will need to issue additional long-term 
debt to remain compliant with the requirements. Under the 
Proposed SLR Rules, the 2% external TLAC leverage buffer 
would be replaced with a buffer equal to one-half of the firm’s G­
SIB capital surcharge. Additionally, the Proposed SLR Rules 
would modify the leverage component for calculating the 
minimum amount of eligible unsecured long-term debt from 
4.5% of total leverage exposure to 2.5% of total leverage 
exposure plus one-half of the firm’s G-SIB capital surcharge. As 
of December 31, 2018, our eligible external TLAC as a percentage 
of total risk-weighted assets was 23.35% compared with a 
required minimum of 22.0%. Similar to the risk-based capital 
requirements, we determine minimum required TLAC based on 
the greater of RWAs determined under the Standardized and 
Advanced approaches. 

In addition, as discussed in the “Risk Management – Asset/ 

Liability Management – Liquidity and Funding – Liquidity 
Standards” section in this Report, federal banking regulators 
have issued a final rule regarding the U.S. implementation of the 
Basel III LCR and a proposed rule regarding the NSFR. 

Capital Planning and Stress Testing 
Our planned long-term capital structure is designed to meet 
regulatory and market expectations. We believe that our long­
term targeted capital structure enables us to invest in and grow 
our business, satisfy our customers’ financial needs in varying 
environments, access markets, and maintain flexibility to return 
capital to our shareholders. Our long-term targeted capital 
structure also considers capital levels sufficient to exceed capital 
requirements including the G-SIB surcharge. Accordingly, based 
on the final Basel III capital rules under the lower of the 
Standardized or Advanced Approaches CET1 capital ratios, we 
currently target a long-term CET1 capital ratio at or in excess of 
10%, which includes a 2% G-SIB surcharge. Our capital targets 
are subject to change based on various factors, including changes 
to the regulatory capital framework and expectations for large 
banks promulgated by bank regulatory agencies, planned capital 
actions, changes in our risk profile and other factors.  As 
discussed above in “Regulatory Capital Guidelines”, the FRB has 
proposed including a stress capital buffer (SCB) to replace the 
current capital conservation buffer as part of the capital 
requirements for large U.S. banks. The proposal is not final, but 

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Wells Fargo & Company 

108

  
it is expected that the adoption of CECL accounting would be 
included in the SCB calculation. We expect that implementation 
of the SCB may increase the level and volatility of minimum 
capital requirements, which may cause our current 10% CET1 
long-term target ratio to increase. 

Under the FRB’s capital plan rule, large BHCs are required 

to submit capital plans annually for review to determine if the 
FRB has any objections before making any capital distributions. 
The rule requires updates to capital plans in the event of 
material changes in a BHC’s risk profile, including as a result of 
any significant acquisitions. The FRB assesses the overall 
financial condition, risk profile, and capital adequacy of BHCs 
while considering both quantitative and qualitative factors when 
evaluating capital plans. 

Our 2018 capital plan, which was submitted on April 4, 
2018, as part of CCAR, included a comprehensive capital outlook 
supported by an assessment of expected sources and uses of 
capital over a given planning horizon under a range of expected 
and stress scenarios. As part of the 2018 CCAR, the FRB also 
generated a supervisory stress test, which assumed a sharp 
decline in the economy and significant decline in asset pricing 
using the information provided by the Company to estimate 
performance. The FRB reviewed the supervisory stress results 
both as required under the Dodd-Frank Act using a common set 
of capital actions for all large BHCs and by taking into account 
the Company’s proposed capital actions. The FRB published its 
supervisory stress test results as required under the Dodd-Frank 
Act on June 21, 2018. On June 28, 2018, the FRB notified us that 
it did not object to our capital plan included in the 2018 CCAR. 
Federal banking regulators require stress tests to evaluate 

whether an institution has sufficient capital to continue to 
operate during periods of adverse economic and financial 
conditions. These stress testing requirements set forth the 
timing and type of stress test activities large BHCs and banks 
must undertake as well as rules governing stress testing controls, 
oversight and disclosure requirements. The rules also limit a 
large BHC’s ability to make capital distributions to the extent its 
actual capital issuances were less than amounts indicated in its 
capital plan. As required under the FRB’s stress testing rule, we 
must submit a mid-cycle stress test based on second quarter data 
and scenarios developed by the Company. We submitted the 
results of the mid-cycle stress test to the FRB and disclosed a 
summary of the results in October 2018. In October 2018, the 
FRB proposed a rule that would, among other things, eliminate 
the mid-cycle stress test requirement for banks beginning in 
2020. 

Securities Repurchases 
From time to time the Board authorizes the Company to 
repurchase shares of our common stock. Although we announce 
when the Board authorizes share repurchases, we typically do 
not give any public notice before we repurchase our shares. 
Future stock repurchases may be private or open-market 
repurchases, including block transactions, accelerated or delayed 
block transactions, forward repurchase transactions, and similar 
transactions. Additionally, we may enter into plans to purchase 
stock that satisfy the conditions of Rule 10b5-1 of the Securities 
Exchange Act of 1934. Various factors determine the amount of 
our share repurchases, including our capital requirements, the 
number of shares we expect to issue for employee benefit plans 
and acquisitions, market conditions (including the trading price 
of our stock), and regulatory and legal considerations, including 
the FRB’s response to our capital plan and to changes in our risk 
profile. Due to the various factors impacting the amount of our 
share repurchases and the fact that we tend to be in the market 
regularly to satisfy repurchase considerations under our capital 
plan, our repurchases occur at various price levels. We may 
suspend repurchase activity at any time. 

In January 2018, the Board authorized the repurchase of 
350 million shares of our common stock. In October 2018, the 
Board authorized the repurchase of an additional 350 million 
shares of our common stock. At December 31, 2018, we had 
remaining authority to repurchase approximately 395 million 
shares, subject to regulatory and legal conditions. For more 
information about share repurchases during fourth quarter 
2018, see Part II, Item 5 in our 2018 Form 10-K. 

Historically, our policy has been to repurchase shares under 

the “safe harbor” conditions of Rule 10b-18 of the Securities 
Exchange Act of 1934 including a limitation on the daily volume 
of repurchases. Rule 10b-18 imposes an additional daily volume 
limitation on share repurchases during a pending merger or 
acquisition in which shares of our stock will constitute some or 
all of the consideration. Our management may determine that 
during a pending stock merger or acquisition when the safe 
harbor would otherwise be available, it is in our best interest to 
repurchase shares in excess of this additional daily volume 
limitation. In such cases, we intend to repurchase shares in 
compliance with the other conditions of the safe harbor, 
including the standing daily volume limitation that applies 
whether or not there is a pending stock merger or acquisition. 

In connection with our participation in the Capital Purchase 

Program (CPP), a part of the Troubled Asset Relief Program 
(TARP), we issued to the U.S. Treasury Department warrants to 
purchase 110,261,688 shares of our common stock with an 
original exercise price of $34.01 per share. The warrants expired 
on October 29, 2018, and the holders of 110,646 unexercised 
warrants as of the expiration date are no longer entitled to 
receive any shares of our common stock. 

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109 

Regulatory Matters
 

Since the enactment of the Dodd-Frank Act in 2010, the U.S. 
financial services industry has been subject to a significant 
increase in regulation and regulatory oversight initiatives. This 
increased regulation and oversight has substantially changed 
how most U.S. financial services companies conduct business 
and has increased their regulatory compliance costs. The 
following highlights the more significant regulations and 
regulatory oversight initiatives that have affected or may affect 
our business. For additional information about the regulatory 
matters discussed below and other regulations and regulatory 
oversight matters, see Part I, Item 1 “Regulation and 
Supervision” of our 2018 Form 10-K, and the “Capital 
Management,” “Forward-Looking Statements” and “Risk 
Factors” sections and Note 28 (Regulatory and Agency Capital 
Requirements) to Financial Statements in this Report. 

Dodd-Frank Act 
The Dodd-Frank Act is the most significant financial reform 
legislation since the 1930s and is driving much of the current 
U.S. regulatory reform efforts. The Dodd-Frank Act and many of 
its provisions became effective in July 2010 and July 2011. The 
following provides additional information on the Dodd-Frank 
Act, including the current status of certain of its rulemaking 
initiatives. 
• 

Enhanced supervision and regulation of systemically 
important firms.  The Dodd-Frank Act grants broad 
authority to federal banking regulators to establish 
enhanced supervisory and regulatory requirements for 
systemically important firms. The FRB has finalized a 
number of regulations implementing enhanced prudential 
requirements for large bank holding companies (BHCs) like 
Wells Fargo regarding risk-based capital and leverage, risk 
and liquidity management, and imposing debt-to-equity 
limits on any BHC that regulators determine poses a grave 
threat to the financial stability of the United States. The FRB 
and OCC have also finalized rules implementing stress 
testing requirements for large BHCs and national banks. 
The FRB has also finalized enhanced prudential standards 
that implement single counterparty credit limits, and has 
proposed a rule to establish remediation requirements for 
large BHCs experiencing financial distress. Similarly, the 
FRB has proposed additional requirements regarding 
effective risk management practices at large BHCs, 
including its expectations for boards of directors and senior 
management. In addition to the authorization of enhanced 
supervisory and regulatory requirements for systemically 
important firms, the Dodd-Frank Act also established the 
Financial Stability Oversight Council and the Office of 
Financial Research, which may recommend new systemic 
risk management requirements and require new reporting 
of systemic risks. The OCC, under separate authority, has 
also finalized guidelines establishing heightened governance 
and risk management standards for large national banks 
such as Wells Fargo Bank, N.A. The OCC guidelines require 
covered banks to establish and adhere to a written risk 
governance framework in order to manage and control their 
risk-taking activities. The guidelines also formalize roles and 
responsibilities for risk management practices within 
covered banks and create certain risk oversight 
responsibilities for their boards of directors. 

•  Regulation of consumer financial products.  The Dodd­

Frank Act established the Consumer Financial Protection 

Bureau (CFPB) to ensure consumers receive clear and 
accurate disclosures regarding financial products and to 
protect them from hidden fees and unfair, deceptive or 
abusive practices. With respect to residential mortgage 
lending, the CFPB issued a number of final rules 
implementing new origination, notification, disclosure and 
other requirements, as well as additional limitations on the 
fees and charges that may be increased from the estimates 
provided by lenders. The CFPB finalized amendments to the 
rule implementing the Home Mortgage Disclosure Act, 
resulting in a significant expansion of the data points 
lenders are required to collect and report to the CFPB. The 
CFPB also expanded the transactions covered by the rule 
and increased the reporting frequency from annual to 
quarterly for large volume lenders, such as Wells Fargo, 
beginning January 1, 2020. With respect to other financial 
products, the CFPB finalized rules, most of which become 
effective on April 1, 2019, to make prepaid cards subject to 
similar consumer protections as those provided by more 
traditional debit and credit cards such as fraud protection 
and expanded access to account information. In addition to 
these rulemaking activities, the CFPB is continuing its on-
going supervisory examination activities of the financial 
services industry with respect to a number of consumer 
businesses and products, including mortgage lending and 
servicing, fair lending requirements, student lending 
activities, and automobile finance. 
Volcker Rule.  The Volcker Rule, with limited exceptions, 
prohibits banking entities from engaging in proprietary 
trading or owning any interest in or sponsoring or having 
certain relationships with a hedge fund, a private equity 
fund or certain structured transactions that are deemed 
covered funds. Federal banking regulators, the SEC and the 
Commodity Futures Trading Commission (CFTC) 
(collectively, the Volcker supervisory regulators) jointly 
released a final rule to implement the Volcker Rule’s 
restrictions, and the FRB has proposed further rules to 
streamline and modify compliance with the Volcker Rule’s 
requirements. As a banking entity with more than 
$50 billion in consolidated assets, we are also subject to 
enhanced compliance program requirements. 

• 

•  Regulation of swaps and other derivatives activities.  The 

Dodd-Frank Act established a comprehensive framework for 
regulating over-the-counter derivatives and authorized the 
CFTC and the SEC to regulate swaps and security-based 
swaps, respectively. The CFTC has adopted rules applicable 
to our provisionally registered swap dealer, Wells Fargo 
Bank, N.A., that require, among other things, extensive 
regulatory and public reporting of swaps, central clearing 
and trading of swaps on exchanges or other multilateral 
platforms, and compliance with comprehensive internal and 
external business conduct standards. The SEC is expected to 
implement parallel rules applicable to security-based swaps. 
In addition, federal regulators have adopted final rules 
establishing initial and variation margin requirements for 
swaps and security-based swaps not centrally cleared, rules 
placing restrictions on a party’s right to exercise default 
rights under derivatives and other qualified financial 
contracts against applicable banking organizations, and 
record-keeping requirements for qualified financial 
contracts. All of these new rules, as well as others being 
considered by regulators in other jurisdictions, may 

110 

Wells Fargo & Company 

110

negatively impact customer demand for over-the-counter 
derivatives, impact our ability to offer customers new 
derivatives or amendments to existing derivatives, and may 
increase our costs for engaging in swaps, security-based 
swaps, and other derivatives activities. 

• 	 Regulation of interchange transaction fees (the Durbin 

Amendment).  On October 1, 2011, the FRB rule enacted to 
implement the Durbin Amendment to the Dodd-Frank Act 
that limits debit card interchange transaction fees to those 
reasonable and proportional to the cost of the transaction 
became effective. The rule generally established that the 
maximum allowable interchange fee that an issuer may 
receive or charge for an electronic debit transaction is the 
sum of 21 cents per transaction and 5 basis points 
multiplied by the value of the transaction. On July 31, 2013, 
the U.S. District Court for the District of Columbia ruled 
that the approach used by the FRB in setting the maximum 
allowable interchange transaction fee impermissibly 
included costs that were specifically excluded from 
consideration under the Durbin Amendment. In August 
2013, the FRB filed a notice of appeal of the decision to the 
United States Court of Appeals for the District of Columbia. 
In March 2014, the Court of Appeals reversed the District 
Court’s decision, but did direct the FRB to provide further 
explanation regarding its treatment of the costs of 
monitoring transactions, which the FRB published in 
August 2015. The plaintiffs did not file a petition for 
rehearing with the Court of Appeals but filed a petition for 
writ of certiorari with the U.S. Supreme Court. In January 
2015, the U.S. Supreme Court denied the petition for writ of 
certiorari. 

Regulatory Capital Guidelines and Capital Plans 
During 2013, federal banking regulators issued final rules that 
substantially amended the risk-based capital rules for banking 
organizations. The rules implement the Basel III regulatory 
capital reforms in the U.S., comply with changes required by the 
Dodd-Frank Act, and replace the existing Basel I-based capital 
requirements. We were required to begin complying with the 
rules on January 1, 2014, subject to phase-in periods that are 
scheduled to be fully phased in by January 1, 2022. In 2014, 
federal banking regulators also finalized rules to impose a 
supplementary leverage ratio on large BHCs like Wells Fargo 
and our insured depository institutions and to implement the 
Basel III liquidity coverage ratio. For more information on the 
final capital, leverage and liquidity rules, and additional capital 
requirements applicable to us, see the “Capital Management” 
section in this Report. 

“Living Will” Requirements and Related Matters 
Rules adopted by the FRB and the FDIC under the Dodd-Frank 
Act require large financial institutions, including Wells Fargo, to 
prepare and periodically revise resolution plans, so-called 
“living-wills”, that would facilitate their resolution in the event of 
material distress or failure. Under the rules, resolution plans are 
required to provide strategies for resolution under the 
Bankruptcy Code and other applicable insolvency regimes that 
can be accomplished in a reasonable period of time and in a 
manner that mitigates the risk that failure would have serious 
adverse effects on the financial stability of the United States. On 
December 19, 2017, the FRB and FDIC announced that 
Wells Fargo’s 2017 resolution plan submission did not have any 
deficiencies; however, they identified a specific shortcoming that 
would need to be addressed in the Company’s next submission. 
Our national bank subsidiary, Wells Fargo Bank, N.A. (the 

“Bank”), is also required to prepare a resolution plan and 
submitted its 2018 resolution plan to the FDIC on June 29, 
2018. If the FRB or FDIC determines that our resolution plan 
has deficiencies, they may impose more stringent capital, 
leverage or liquidity requirements on us or restrict our growth, 
activities or operations until we adequately remedy the 
deficiencies. If the FRB or FDIC ultimately determines that we 
have been unable to remedy any deficiencies, they could require 
us to divest certain assets or operations. 

We must also prepare and submit to the FRB a recovery 
plan that identifies a range of options that we may consider 
during times of idiosyncratic or systemic economic stress to 
remedy any financial weaknesses and restore market confidence 
without extraordinary government support. Recovery options 
include the possible sale, transfer or disposal of assets, 
securities, loan portfolios or businesses. The Bank must also 
prepare and submit to the OCC a recovery plan that sets forth 
the bank’s plan to remain a going concern when the bank is 
experiencing considerable financial or operational stress, but has 
not yet deteriorated to the point where liquidation or resolution 
is imminent. If either the FRB or the OCC determine that our 
recovery plan is deficient, they may impose fines, restrictions on 
our business or ultimately require us to divest assets. 
If Wells Fargo were to fail, it may be resolved in a 

bankruptcy proceeding or, if certain conditions are met, under 
the resolution regime created by the Dodd-Frank Act known as 
the “orderly liquidation authority.” The orderly liquidation 
authority allows for the appointment of the FDIC as receiver for 
a systemically important financial institution that is in default or 
in danger of default if, among other things, the resolution of the 
institution under the U.S. Bankruptcy Code would have serious 
adverse effects on financial stability in the United States. If the 
FDIC is appointed as receiver for Wells Fargo & Company (the 
“Parent”), then the orderly liquidation authority, rather than the 
U.S. Bankruptcy Code, would determine the powers of the 
receiver and the rights and obligations of our security holders. 
The FDIC’s orderly liquidation authority requires that security 
holders of a company in receivership bear all losses before U.S. 
taxpayers are exposed to any losses, and allows the FDIC to 
disregard the strict priority of creditor claims under the U.S. 
Bankruptcy Code in certain circumstances. 

Whether under the U.S. Bankruptcy Code or by the FDIC 
under the orderly liquidation authority, Wells Fargo could be 
resolved using a “multiple point of entry” strategy, in which the 
Parent and one or more of its subsidiaries would each undergo 
separate resolution proceedings, or a “single point of entry” 
strategy, in which the Parent would likely be the only material 
legal entity to enter resolution proceedings. The FDIC has 
announced that a single point of entry strategy may be a 
desirable strategy under its implementation of the orderly 
liquidation authority, but not all aspects of how the FDIC might 
exercise this authority are known and additional rulemaking is 
possible. 

The strategy described in our most recent resolution plan 
submission is a multiple point of entry strategy; however, we 
have made a decision to move to a single point of entry 
strategy for our next resolution plan submission. We are not 
obligated to maintain either a single point of entry or multiple 
point of entry strategy, and the strategies reflected in our 
resolution plan submissions are not binding in the event of an 
actual resolution of Wells Fargo, whether conducted under 
the U.S. Bankruptcy Code or by the FDIC under the orderly 
liquidation authority. 

To facilitate the orderly resolution of systemically important 

financial institutions in case of material distress or failure, 

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Regulatory Matters (continued) 

federal banking regulations require that institutions, such as 
Wells Fargo, maintain a minimum amount of equity and 
unsecured debt to absorb losses and recapitalize operating 
subsidiaries. Federal banking regulators have also required 
measures to facilitate the continued operation of operating 
subsidiaries notwithstanding the failure of their parent 
companies, such as limitations on parent guarantees, and have 
issued guidance encouraging institutions to take legally binding 
measures to provide capital and liquidity resources to certain 
subsidiaries in order to facilitate an orderly resolution. In 
response to the regulators’ guidance and to facilitate the orderly 
resolution of the Company using either a single point of entry or 
multiple point of entry resolution strategy, on June 28, 2017, the 
Parent entered into a support agreement (the “Support 
Agreement”) with WFC Holdings, LLC, an intermediate holding 
company and subsidiary of the Parent (the “IHC”), and the Bank, 
Wells Fargo Securities, LLC (“WFS”), and Wells Fargo Clearing 
Services, LLC (“WFCS”), each an indirect subsidiary of the 
Parent. Pursuant to the Support Agreement, the Parent 
transferred a significant amount of its assets, including the 
majority of its cash, deposits, liquid securities and intercompany 
loans (but excluding its equity interests in its subsidiaries and 
certain other assets), to the IHC and will continue to transfer 
those types of assets to the IHC from time to time. In the event 
of our material financial distress or failure, the IHC will be 
obligated to use the transferred assets to provide capital and/or 
liquidity to the Bank pursuant to the Support Agreement and to 
WFS and WFCS through repurchase facilities entered into in 
connection with the Support Agreement. Under the Support 
Agreement, the IHC will also provide funding and liquidity to the 
Parent through subordinated notes and a committed line of 
credit, which, together with the issuance of dividends, is 
expected to provide the Parent, during business as usual 
operating conditions, with the same access to cash necessary to 
service its debts, pay dividends, repurchase its shares, and 
perform its other obligations as it would have had if it had not 
entered into these arrangements and transferred any assets. If 
certain liquidity and/or capital metrics fall below defined 
triggers, the subordinated notes would be forgiven and the 
committed line of credit would terminate, which could 
materially and adversely impact the Parent’s liquidity and its 
ability to satisfy its debts and other obligations, and could result 
in the commencement of bankruptcy proceedings by the Parent 
at an earlier time than might have otherwise occurred if the 
Support Agreement were not implemented. The Parent’s and the 
IHC’s respective obligations under the Support Agreement are 
secured pursuant to a related security agreement. 

Other Regulatory Related Matters 
• 

Broker-dealer standards of conduct.  In April 2018, the SEC 
proposed a rule that would require broker-dealers to act in 
the best interest of a retail customer when making a 
recommendation of any securities transaction or investment 
strategy involving securities. This rule may impact the 
manner in which business is conducted with customers 
seeking investment advice and may affect certain 
investment product offerings. 

•  OCC revocation of relief.  On November 18, 2016, the OCC 
revoked provisions of certain consent orders that provided 
Wells Fargo Bank, N.A. relief from specific requirements 
and limitations regarding rules, policies, and procedures for 
corporate activities; OCC approval of changes in directors 
and senior executive officers; and golden parachute 
payments. As a result, Wells Fargo Bank, N.A. is no longer 
eligible for expedited treatment for certain applications; is 

• 

• 

• 

now required to provide prior written notice to the OCC of a 
change in directors and senior executive officers; and is now 
subject to certain regulatory limitations on golden 
parachute payments. 
Community Reinvestment Act (CRA) rating.  In March 
2017, we announced that the OCC had downgraded our 
most recent CRA rating, which covers the years 2009 – 
2012, to “Needs to Improve” due to previously issued 
regulatory consent orders. A “Needs to Improve” rating 
imposes regulatory restrictions and limitations on certain of 
the Company’s nonbank activities, including its ability to 
engage in certain nonbank mergers and acquisitions or 
undertake new financial in nature activities, and CRA 
performance is taken into account by regulators in 
reviewing applications to establish bank branches and for 
approving proposed bank mergers and acquisitions. The 
rating also results in the loss of expedited processing of 
applications to undertake certain activities, and requires the 
Company to receive prior regulatory approval for certain 
activities, including to issue or prepay certain subordinated 
debt obligations, open or relocate bank branches, or make 
certain public welfare investments. In addition, a “Needs to 
Improve” rating could have an impact on the Company’s 
relationships with certain states, counties, municipalities or 
other public agencies to the extent applicable law, regulation 
or policy limits, restricts or influences whether such entity 
may do business with a company that has a below 
“Satisfactory” rating. 
FRB consent order regarding governance oversight and 
compliance and operational risk management.  On 
February 2, 2018, the Company entered into a consent order 
with the FRB. As required by the consent order, the Board 
submitted to the FRB a plan to further enhance the Board’s 
governance and oversight of the Company, and the 
Company submitted to the FRB a plan to further improve 
the Company’s compliance and operational risk 
management program. The consent order requires the 
Company, following the FRB’s acceptance and approval of 
the plans and the Company’s adoption and implementation 
of the plans, to complete third-party reviews of the 
enhancements and improvements provided for in the plans. 
Until these third-party reviews are complete and the plans 
are approved and implemented to the satisfaction of the 
FRB, the Company’s total consolidated assets will be limited 
to the level as of December 31, 2017. Compliance with this 
asset cap will be measured on a two-quarter daily average 
basis to allow for management of temporary fluctuations. 
The Company continues to have constructive dialogue with 
the FRB on an ongoing basis to clarify expectations, receive 
feedback, and assess progress under the consent order. In 
order to have enough time to incorporate this feedback into 
the Company’s plans in a thoughtful manner, adopt and 
implement the final plans as accepted by the FRB, and 
complete the required third-party reviews, the Company is 
planning to operate under the asset cap through the end of 
2019. Additionally, after removal of the asset cap, a second 
third-party review must also be conducted to assess the 
efficacy and sustainability of the enhancements and 
improvements. 
Consent orders with the CFPB and OCC regarding 
compliance risk management program, automobile 
collateral protection insurance policies, and mortgage 
interest rate lock extensions. On April 20, 2018, the 
Company entered into consent orders with the CFPB and 
OCC to pay an aggregate of $1 billion in civil money 

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112

penalties to resolve matters regarding the Company’s 
compliance risk management program and past practices 
involving certain automobile collateral protection insurance 
policies and certain mortgage interest rate lock extensions. 
As required by the consent orders, the Company submitted 
to the CFPB and OCC an enterprise-wide compliance risk 
management plan and a plan to enhance the Company’s 
internal audit program with respect to federal consumer 

Critical Accounting Policies 

Our significant accounting policies (see Note 1 (Summary of 
Significant Accounting Policies) to Financial Statements in this 
Report) are fundamental to understanding our results of 
operations and financial condition because they require that we 
use estimates and assumptions that may affect the value of our 
assets or liabilities and financial results. Five of these policies are 
critical because they require management to make difficult, 
subjective and complex judgments about matters that are 
inherently uncertain and because it is likely that materially 
different amounts would be reported under different conditions 
or using different assumptions. These policies govern: 
• 	
• 	
• 	
• 	
• 	

the allowance for credit losses; 
the valuation of residential MSRs; 
the fair value of financial instruments; 
income taxes; and 
liability for contingent litigation losses. 

Management and the Board’s Audit and Examination 

Committee have reviewed and approved these critical accounting 
policies. 

Allowance for Credit Losses 
We maintain an allowance for credit losses, which consists of the 
allowance for loan losses and the allowance for unfunded credit 
commitments, which is management’s estimate of credit losses 
inherent in the loan portfolio, including unfunded credit 
commitments, at the balance sheet date, excluding loans carried 
at fair value. For a description of our related accounting policies, 
see Note 1 (Summary of Significant Accounting Policies) to 
Financial Statements in this Report. 

Changes in the allowance for credit losses and, therefore, in 

the related provision for credit losses can materially affect net 
income. In applying the judgment and review required to 
determine the allowance for credit losses, management 
considers changes in economic conditions, customer behavior, 
and collateral value, among other influences. From time to time, 
economic factors or business decisions, such as the addition or 
liquidation of a loan product or business unit, may affect the 
loan portfolio, causing management to provide for or release 
amounts from the allowance for credit losses. While our 
methodology attributes portions of the allowance to specific 
portfolio segments (commercial and consumer), the entire 
allowance for credit losses is available to absorb credit losses 
inherent in the total loan portfolio and unfunded credit 
commitments. 

Judgment is specifically applied in: 

• 	 Credit risk ratings applied to individual commercial loans 
and unfunded credit commitments.  We estimate the 
probability of default in accordance with the borrower’s 
financial strength using a borrower quality rating and the 
severity of loss in the event of default using a collateral 
quality rating. Collectively, these ratings are referred to as 
credit risk ratings and are assigned to our commercial loans. 

financial law and the terms of the consent orders. In 
addition, as required by the consent orders, the Company 
submitted for non-objection plans to remediate customers 
affected by the automobile collateral protection insurance 
and mortgage interest rate lock matters, as well as a plan for 
the management of remediation activities conducted by the 
Company. 

Probability of default and severity at the time of default are 
statistically derived through historical observations of 
defaults and losses after default within each credit risk 
rating. Commercial loan risk ratings are evaluated based on 
each situation by experienced senior credit officers and are 
subject to periodic review by an internal team of credit 
specialists. 

• 	 Economic assumptions applied to pools of consumer loans 

• 	

(statistically modeled).  Losses are estimated using 
economic variables to represent our best estimate of 
inherent loss. Our forecasted losses are modeled using a 
range of economic scenarios. 
Selection of a credit loss estimation model that fits the 
credit risk characteristics of its portfolio.  We use both 
internally developed and vendor supplied models in this 
process. We often use expected loss, transition rate, flow 
rate, competing hazard, vintage maturation, and time series 
or statistical trend models, most with economic 
correlations. Management must use judgment in 
establishing additional input metrics for the modeling 
processes, considering further stratification into reference 
data time series, sub-product, origination channel, vintage, 
loss type, geographic location and other predictive 
characteristics. The models used to determine the allowance 
for credit losses are validated in accordance with Company 
policies by an internal model validation group. 

• 	

• 	 Assessment of limitations to credit loss estimation models. 
We apply our judgment to adjust our modeled estimates to 
reflect other risks that may be identified from current 
conditions and developments in selected portfolios. 
Identification and measurement of impaired loans, 
including loans modified in a TDR.  Our experienced senior 
credit officers may consider a loan impaired based on their 
evaluation of current information and events, including 
loans modified in a TDR. The measurement of impairment 
is typically based on an analysis of the present value of 
expected future cash flows. The development of these 
expectations requires significant management judgment 
and review. 

• 	 An amount for imprecision or uncertainty which reflects 

management’s overall estimate of the effect of quantitative 
and qualitative factors on inherent credit losses.  This 
amount represents management’s judgment of risks 
inherent in the processes and assumptions used in 
establishing the allowance for credit losses. This imprecision 
considers economic environmental factors, modeling 
assumptions and performance, process risk, and other 
subjective factors, including industry trends and emerging 
risk assessments. 

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Critical Accounting Policies (continued) 

SENSITIVITY TO CHANGES  Table 49 demonstrates the impact 
of the sensitivity of our estimates on our allowance for credit 
losses. 

operations (e.g., possible changes in future servicing costs, 
ancillary income and earnings on escrow accounts). 
• 	 The expected cost to service loans used to estimate future 

Table 49:  Allowance Sensitivity Summary 

(in billions) 

Assumption: 

Favorable (1) 

Adverse (2) 

December 31, 2018 

Estimated 

increase/(decrease) 

in allowance 

$ 

(3.2) 

6.9 

(1) 	 Represents a one risk rating upgrade throughout our commercial portfolio 

segment and a more optimistic economic outlook for modeled losses on our 
consumer portfolio segment. 

(2) 	 Represents a one risk rating downgrade throughout our commercial portfolio 

segment, a more pessimistic economic outlook for modeled losses on our 
consumer portfolio segment, and incremental deterioration for PCI loans. 

The sensitivity analyses provided in the previous table are 

hypothetical scenarios and are not considered probable. They do 
not represent management’s view of inherent losses in the 
portfolio as of the balance sheet date. Because significant 
judgment is used, it is possible that others performing similar 
analyses could reach different conclusions. See the “Risk 
Management – Credit Risk Management – Allowance for Credit 
Losses” section and Note 6 (Loans and Allowance for Credit 
Losses) to Financial Statements in this Report for further 
discussion of our allowance for credit losses. 

Valuation of Residential Mortgage Servicing 
Rights (MSRs) 
MSRs are assets that represent the rights to service mortgage 
loans for others. We recognize MSRs when we purchase 
servicing rights from third parties, or retain servicing rights in 
connection with the sale or securitization of loans we originate 
(asset transfers). We also have MSRs acquired in the past under 
co-issuer agreements that provide for us to service loans that 
were originated and securitized by third-party correspondents. 

We carry our MSRs related to residential mortgage loans 

at fair value. Periodic changes in our residential MSRs and 
the economic hedges used to hedge our residential MSRs are 
reflected in earnings. 

We use a model to estimate the fair value of our 

residential MSRs. The model is validated by an internal model 
validation group operating in accordance with Company 
policies. The model calculates the present value of estimated 
future net servicing income and incorporates inputs and 
assumptions that market participants use in estimating fair 
value. Certain significant inputs and assumptions generally 
are not observable in the market and require judgment to 
determine. If observable market indications do become 
available, these are factored into the estimates as appropriate: 
• 	 The mortgage loan prepayment speed used to estimate 

future net servicing income.  The prepayment speed is the 
annual rate at which borrowers are forecasted to repay their 
mortgage loan principal; this rate also includes estimated 
borrower defaults. We use models to estimate prepayment 
speeds and borrower defaults which are influenced by 
changes in mortgage interest rates and borrower behavior. 

• 	 The discount rate used to present value estimated future 

net servicing income.  The discount rate is the required rate 
of return investors in the market would expect for an asset 
with similar risk. To determine the discount rate, we 
consider the risk premium for uncertainties from servicing 

net servicing income.  The cost to service loans includes 
estimates for unreimbursed expenses, such as delinquency 
and foreclosure costs, which considers the number of 
defaulted loans as well as changes in servicing processes 
associated with default and foreclosure management. 

Both prepayment speed and discount rate assumptions can, 

and generally will, change quarterly as market conditions and 
mortgage interest rates change. For example, an increase in 
either the prepayment speed or discount rate assumption results 
in a decrease in the fair value of the MSRs, while a decrease in 
either assumption would result in an increase in the fair value of 
the MSRs. In recent years, there have been significant market-
driven fluctuations in loan prepayment speeds and the discount 
rate. These fluctuations can be rapid and may be significant in 
the future. Additionally, while our current valuation reflects our 
best estimate of servicing costs, future regulatory or investor 
changes in servicing standards, as well as changes in individual 
state foreclosure legislation or additional market participant 
information regarding servicing cost assumptions, may have an 
impact on our servicing cost assumption and our MSR valuation 
in future periods. 

For a description of our valuation and sensitivity of MSRs, 

see Note 1 (Summary of Significant Accounting Policies), Note 9 
(Securitizations and Variable Interest Entities), Note 10 
(Mortgage Banking Activities) and Note 18 (Fair Values of Assets 
and Liabilities) to Financial Statements in this Report. 

Fair Value of Financial Instruments 
Fair value represents the price that would be received to sell the 
financial asset or paid to transfer the financial liability in an 
orderly transaction between market participants at the 
measurement date. 

We use fair value measurements to record fair value 
adjustments to certain financial instruments and to determine 
fair value disclosures. For example, assets and liabilities held for 
trading purposes, marketable equity securities not held for 
trading purposes, debt securities available for sale, derivatives 
and substantially all of our residential MLHFS are carried at fair 
value each period. Other financial instruments, such as certain 
MLHFS, nonmarketable equity securities and substantially all 
of our loans held for investment, are not carried at fair value 
each period but may require nonrecurring fair value 
adjustments due to application of lower-of-cost-or-market 
accounting, measurement alternative accounting or write-
downs of individual assets. We also disclose our estimate of fair 
value for financial instruments not recorded at fair value, such 
as loans held for investment or issuances of long-term debt. 
The accounting provisions for fair value measurements 

include a three-level hierarchy for disclosure of assets and 
liabilities recorded at fair value. The classification of assets and 
liabilities within the hierarchy is based on whether the inputs to 
the valuation methodology used for measurement are observable 
or unobservable. Observable inputs reflect market-derived or 
market-based information obtained from independent sources, 
while unobservable inputs reflect our estimates about market 
data. For additional information on fair value levels, see Note 18 
(Fair Values of Assets and Liabilities) to Financial Statements in 
this Report. 

When developing fair value measurements, we maximize 

the use of observable inputs and minimize the use of 
unobservable inputs. When available, we use quoted prices in 

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active markets to measure fair value. If quoted prices in active 
markets are not available, fair value measurement is based upon 
models that use primarily market-based or independently 
sourced market parameters, including interest rate yield curves, 
prepayment speeds, option volatilities and currency rates. 
However, when observable market data is limited or not 
available, fair value estimates are typically determined using 
internally-developed models based on unobservable inputs. In 
these instances, management judgment is necessary as we are 
required to make judgments about significant assumptions 
market participants would use to estimate fair value. 
Determination of these assumptions includes consideration of 
market conditions and liquidity levels. Changes in the market 
conditions, such as reduced liquidity in the capital markets or 
changes in secondary market activities, may reduce the 
availability and reliability of quoted prices or observable data 
used to determine fair value. In such cases, it may be appropriate 
to adjust available quoted prices or observable market data. 
When significant adjustments are required to price quotes or 
other observable market data, it may be appropriate to utilize an 
estimate of fair value based primarily on unobservable inputs. 
Internal models used to determine fair value are validated in 
accordance with company policies by an internal model 
validation group. Additionally, we use third-party pricing 
services to obtain fair values, which are used to either record the 
price of an instrument or to corroborate internally developed 
prices. Third-party price validation procedures are performed 
over the reasonableness of the fair value measurements. For 
additional information on our use of pricing services, see Note 1 
(Summary of Significant Accounting Policies) and Note 18 (Fair 
Value of Assets and Liabilities) to Financial Statements in this 
Report. 

Significant judgment is also required to determine whether 
certain assets measured at fair value are classified as Level 2 or 
Level 3 of the fair value hierarchy as described in Note 18 (Fair 
Value of Assets and Liabilities) to Financial Statements in this 
Report. When making this judgment, we consider available 
information, including observable market data, indications of 
market liquidity and orderliness, and our understanding of the 
valuation techniques and significant inputs used. The 
classification of Level 2 or Level 3 is based upon the specific facts 
and circumstances of each instrument or instrument category 
and judgments are made regarding the significance of the Level 
3 inputs to the instruments’ fair value measurement in its 
entirety. If Level 3 inputs are considered significant, the 
instrument is classified as Level 3. 

Table 50 presents the summary of the fair value of financial 
instruments recorded at fair value on a recurring basis, and the 
amounts of Level 3 assets and liabilities (before derivative 
netting adjustments). The fair value of the remaining assets and 
liabilities were measured using valuation methodologies 
involving market-based or market-derived information 
(collectively Level 1 and 2 measurements). 

Table 50:  Fair Value Level 3 Summary 

($ in billions) 

Assets carried 
at fair value 

As a percentage

of total assets 

Liabilities carried 
at fair value 

As a percentage of
total liabilities 

December 31, 2018 

December 31, 2017 

Total  Level 3 
(1) 

balance 

Total 
balance 

Level 3 
(1) 

$  408.4 

25.3 

416.6 

24.9 

22% 

1 

21 

1 

$  28.2 

1.6 

27.3 

2.0 

2% 

* 

2

* 

Less than 1%. 

* 
(1)  Before derivative netting adjustments. 

See Note 18 (Fair Values of Assets and Liabilities) to 

Financial Statements in this Report for a complete discussion on 
our fair value of financial instruments, our related measurement 
techniques and the impact to our financial statements. 

Income Taxes 
We file consolidated and separate company U.S. federal income 
tax returns, foreign tax returns and various combined and 
separate company state tax returns. We evaluate two 
components of income tax expense: current and deferred income 
tax expense. Current income tax expense represents our 
estimated taxes to be paid or refunded for the current period and 
includes income tax expense related to our uncertain tax 
positions. Deferred income tax expense results from changes in 
deferred tax assets and liabilities between periods. We determine 
deferred income taxes using the balance sheet method. Under 
this method, the net deferred tax asset or liability is based on the 
tax effects of the differences between the book and tax bases of 
assets and liabilities, and recognizes enacted changes in tax rates 
and laws in the period in which they occur. Deferred tax assets 
are recognized subject to management’s judgment that 
realization is “more likely than not.” Uncertain tax positions that 
meet the more likely than not recognition threshold are 
measured to determine the amount of benefit to recognize. An 
uncertain tax position is measured at the largest amount of 
benefit that management believes has a greater than 50% 
likelihood of realization upon settlement. Tax benefits not 
meeting our realization criteria represent unrecognized tax 
benefits. We account for interest and penalties as a component 
of income tax expense. In 2018, we finalized the recognition of 
the U.S. tax expense associated with a deemed repatriation of 
undistributed earnings of certain non-U.S. subsidiaries as 
required under the 2017 Tax Act. We do not intend to distribute 
these earnings in a taxable manner, and therefore intend to limit 
distributions of foreign earnings previously taxed in the U.S., 
that would qualify for the 100% dividends received deduction, 
and that would not result in any significant state or foreign taxes. 
All other undistributed foreign earnings will continue to be 
permanently reinvested outside the U.S. 

The income tax laws of the jurisdictions in which 

we operate are complex and subject to different interpretations 
by the taxpayer and the relevant government taxing authorities. 
In establishing a provision for income tax expense, we must 
make judgments and interpretations about the application of 
these inherently complex tax laws. We must also make estimates 
about when in the future certain items will affect taxable income 
in the various tax jurisdictions, both domestic and foreign. Our 
interpretations may be subjected to review during examination 
by taxing authorities and disputes may arise over the respective 
tax positions. We attempt to resolve these disputes during the 

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Critical Accounting Policies (continued) 

tax examination and audit process and ultimately through the 
court systems when applicable. 

We monitor relevant tax authorities and revise our estimate 

of accrued income taxes due to changes in income tax laws and 
their interpretation by the courts and regulatory authorities on a 
quarterly basis. Revisions of our estimate of accrued income 
taxes also may result from our own income tax planning and 
from the resolution of income tax controversies. Such revisions 
in our estimates may be material to our operating results for any 
given quarter. 

See Note 23 (Income Taxes) to Financial Statements in this 

Report for a further description of our provision for income 
taxes and related income tax assets and liabilities. 

Liability for Contingent Litigation Losses 
The Company is involved in a number of judicial, regulatory, 
arbitration and other proceedings concerning matters arising 
from the conduct of its business activities, and many of those 
proceedings expose the Company to potential financial loss. We 
establish accruals for these legal actions when potential losses 
associated with the actions become probable and the costs can 
be reasonably estimated. For such accruals, we record the 
amount we consider to be the best estimate within a range of 
potential losses that are both probable and estimable; however, 
if we cannot determine a best estimate, then we record the low 
end of the range of those potential losses. The actual costs of 
resolving legal actions may be substantially higher or lower than 
the amounts accrued for those actions. 

We apply judgment when establishing an accrual for 
potential losses associated with legal actions and in establishing 
the range of reasonably possible losses in excess of the accrual. 
Our judgment in establishing accruals and the range of 
reasonably possible losses in excess of the Company’s accrual for 
probable and estimable losses is influenced by our 
understanding of information currently available related to the 
legal evaluation and potential outcome of actions, including 
input and advice on these matters from our internal counsel, 
external counsel and senior management. These matters may be 
in various stages of investigation, discovery or proceedings. They 
may also involve a wide variety of claims across our businesses, 
legal entities and jurisdictions. The eventual outcome may be a 
scenario that was not considered or was considered remote in 
anticipated occurrence. Accordingly, our estimate of potential 
losses will change over time and the actual losses may vary 
significantly. 

The outcomes of legal actions are unpredictable and subject 

to significant uncertainties, and it is inherently difficult to 
determine whether any loss is probable or even possible. It is 
also inherently difficult to estimate the amount of any loss and 
there may be matters for which a loss is probable or reasonably 
possible but not currently estimable. Accordingly, actual losses 
may be in excess of the established accrual or the range of 
reasonably possible loss. 

See Note 16 (Legal Actions) to Financial Statements in this 

Report for further information. 

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Current Accounting Developments
 

Table 51 provides the significant accounting updates applicable 
to us that have been issued by the FASB but are not yet effective. 

Table 51:  Current Accounting Developments – Issued Standards 

Standard 

Description 

Effective date and financial statement impact 

Accounting Standard Update 
(ASU or Update) 2018-16 -
Derivatives and Hedging 
(Topic 815): Inclusion of the 
Secured Overnight Financing 
Rate (SOFR) Overnight 
Index Swap (OIS) Rate as a 
Benchmark Interest Rate for 
Hedge Accounting Purposes 

ASU 2018-12 – Financial 
Services – Insurance (Topic 
944): Targeted 
Improvements to the 
Accounting for Long-
Duration Contracts 

ASU 2017-08 – Receivables 
– Nonrefundable Fees and 
Other Costs (Subtopic 
310-20): Premium 
Amortization on Purchased 
Callable Debt Securities 

The Update expands the list of U.S. 
benchmark interest rates permitted in 
the application of hedge accounting. The 
Update adds the OIS rate based on 
SOFR as a U.S. benchmark interest rate 
to facilitate the LIBOR to SOFR transition 
and provide sufficient lead time for 
entities to prepare for changes to 
interest rate risk hedging strategies for 
both risk management and hedge 
accounting purposes. 

The Update requires all features in long-
duration insurance contracts that meet 
the definition of a market risk benefit to 
be measured at fair value through 
earnings with changes in fair value 
attributable to our own credit risk 
recognized in other comprehensive 
income. Currently, two measurement 
models exist for these features, fair 
value and insurance accrual. The Update 
requires the use of a standardized 
discount rate and routine updates for 
insurance assumptions used in valuing 
the liability for future policy benefits for 
traditional long-duration contracts. The 
Update also simplifies the amortization 
of deferred acquisition costs. 

The Update changes the accounting for 
certain purchased callable debt 
securities held at a premium to shorten 
the amortization period for the premium 
to the earliest call date rather than to 
the maturity date. Accounting for 
purchased callable debt securities held 
at a discount does not change. The 
discount would continue to amortize to 
the maturity date. 

We adopted the guidance in first quarter 2019. The adoption did not 
impact existing hedges, but may impact new hedge relationships if we 
designate the SOFR OIS rate as the designated hedged benchmark 
interest rate for the Company’s fixed-rate financial instruments and 
forecasted issuances or purchases of fixed-rate financial instruments. 

The guidance becomes effective on January 1, 2021. Certain of our 
variable annuity reinsurance products meet the definition of market risk 
benefits and will be measured at fair value as of the earliest period 
presented. The cumulative effect of changes attributable to the market 
risk benefit of the liability’s instrument-specific credit risk (i.e., the 
Company’s own credit risk) will be recognized in the beginning balance 
of accumulated other comprehensive income. The cumulative effect of 
the difference between fair value and carrying value, excluding the 
effect of our own credit, will be recognized in the opening balance of 
retained earnings. Changes to the liability for future policy benefits for 
traditional long-duration contracts and deferred acquisition costs will be 
applied to all outstanding contracts on the basis of their existing carrying 
amounts at the beginning of the earliest period presented. The impact of 
the Update on our consolidated financial statements is still being 
evaluated. 

We adopted the guidance in first quarter 2019 and recorded a 
cumulative-effect adjustment as of January 1, 2019, that reduced 
retained earnings by $592 million and increased other comprehensive 
income by $481 million. The guidance impacted our investments in 
purchased callable debt securities held at a premium classified as 
available-for-sale (AFS) and held-to-maturity (HTM), which primarily 
consist of obligations of U.S. states and political subdivisions. In future 
periods, interest income recognized prior to the call date will be reduced 
because the premium will be amortized over a shorter time period. 

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Current Accounting Developments (continued) 

Standard 

Description	 

Effective date and financial statement impact 

ASU 2016-13 – Financial 
Instruments – Credit Losses 
(Topic 326): Measurement of 
Credit Losses on Financial 
Instruments 

The Update changes the accounting for 
credit losses measurement on loans and 
debt securities. For loans and held-to­
maturity debt securities, the Update 
requires a current expected credit loss 
(CECL) measurement to estimate the 
allowance for credit losses (ACL) for the 
remaining estimated life of the financial 
asset (including off-balance sheet credit 
exposures) using historical experience, 
current conditions, and reasonable and 
supportable forecasts. The Update 
eliminates the existing guidance for PCI 
loans, but requires an allowance for 
purchased financial assets with more 
than insignificant deterioration since 
origination. In addition, the Update 
modifies the other-than-temporary 
impairment model for available-for-sale 
debt securities to require an allowance 
for credit impairment instead of a direct 
write-down, which allows for reversal of 
credit impairments in future periods 
based on improvements in credit. 

We expect to adopt the guidance in first quarter 2020. Our 
implementation process includes loss forecasting model development, 
evaluation of technical accounting topics, updates to our allowance 
documentation, reporting processes and related internal controls, and 
overall operational readiness for our adoption of the Update, which will 
continue throughout 2019, including parallel runs for CECL alongside our 
current allowance process. 

We are in the process of developing, validating, and implementing 

models used to estimate credit losses under CECL. We have substantially 
completed a significant majority of our loss forecasting models, and we 
expect to complete the validation process for our loan models during 
2019. 

Our current planned approach for estimating expected life-time 
credit losses for loans and debt securities includes the following key 
components: 
• 	 An initial forecast period of one year for all portfolio segments and 
classes of financing receivables and off-balance-sheet credit 
exposures. This period reflects management’s expectation of losses 
based on forward-looking economic scenarios over that time. 
• 	 A historical loss forecast period covering the remaining contractual 

life, adjusted for prepayments, by portfolio segment and class of 
financing receivables based on the change in key historic economic 
variables during representative historical expansionary and 
recessionary periods. 

• 	 A reversion period of up to 2 years connecting the initial loss 
forecast to the historical loss forecast based on economic 
conditions at the measurement date. 

• 	 We will utilize discounted cash flow (DCF) methods to measure 
credit impairment for loans modified in a TDR, unless they are 
collateral dependent and measured at the fair value of collateral. 
The DCF methods would obtain estimated life-time credit losses 
using the conceptual components described above. 
For available-for-sale debt securities and certain beneficial interests 
classified as held-to-maturity, we plan to utilize the DCF methods 
to measure the ACL, which will incorporate expected credit losses 
using the conceptual components described above.  

• 	

We expect an overall increase in the ACL for loans, with an 

expected increase for longer duration consumer portfolios and an 
expected decrease for commercial loans given short contractual 
maturities with conditional renewal options. The expected impact on our 
ACL does not include the impact of the FASB’s recently proposed change 
to consider recoveries of previously charged off loans or subsequent 
increases in fair value of collateral for collateral dependent loans in the 
ACL measurement. If finalized, the proposed changes would reduce the 
expected change in our ACL. We continue to evaluate the results of our 
modeled loss estimates and will continue to make refinements to our 
approach, including evaluating an amount for imprecision or uncertainty, 
based on management’s judgment of the risk inherent in the processes 
and assumptions used in estimating the ACL. 

We will recognize an ACL for held-to-maturity and available-for-sale 

debt securities. The ACL on available-for-sale debt securities will be 
subject to a limitation based on the fair value of the security. Based on 
the credit quality of our existing debt securities portfolio, we do not 
expect the ACL for held-to-maturity and available-for-sale debt 
securities to be significant. 

The amount of the change in our ACL will be impacted by our 
portfolio composition and credit quality at the adoption date as well as 
economic conditions and forecasts at that time. At adoption, we expect 
to have a cumulative-effect adjustment to retained earnings for our 
change in the ACL, which will impact our capital. Federal banking 
regulatory agencies have agreed to limit the initial capital impact of the 
Update by allowing a phased adoption over three years, on a straight-
line basis. An increase in our ACL will result in a reduction to our 
regulatory capital amounts and ratios; however, at this point in 
implementation, we are not able to provide a more precise estimate of 
the impact. 

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Standard 

Description 

Effective date and financial statement impact 

ASU 2016-02 – Leases 
(Topic 842) and subsequent 
related Updates 

The Update requires lessees to recognize 
operating leases on the balance sheet 
with lease liabilities and related right-of­
use assets based on the present value of 
future lease payments. Lessor 
accounting activities are largely 
unchanged from existing lease 
accounting. The Update also eliminates 
leveraged lease accounting but allows 
existing leveraged leases to continue 
their current accounting until maturity, 
termination or modification. 

We adopted the guidance in first quarter 2019 and have elected not to 
provide a comparative presentation for 2018 and 2017 financial 
statements. At adoption, we recognized a cumulative effect adjustment 
of approximately $100 million that increased retained earnings related 
to deferred gains on our prior sale-leaseback transactions. Our operating 
lease right-of-use assets and liabilities, for approximately 7,000 leases, 
were $5 billion and $5.6 billion, respectively. There were no material 
changes to the timing of expense recognition on these operating leases 
or in the recognition and measurement of our lessor accounting. While 
the increase to our consolidated total assets related to operating lease 
right-of-use assets increases our risk-weighted assets and decreases our 
capital ratios, we do not expect these changes to be material. 

In addition to the list above, the following Updates are 
applicable to us but are not expected to have a material impact 
on our consolidated financial statements: 
• 	 ASU 2018-17 – Consolidation (Topic 810): Targeted 

Improvements to Related Party Guidance for Variable 
Interest Entities 

• 	 ASU 2018-15 – Intangibles – Goodwill and Other – 

Internal-Use Software (Subtopic 350-40): Customer’s 
Accounting for Implementation Costs Incurred in a Cloud 
Computing Arrangement That Is a Service Contract (a 
consensus of the FASB Emerging Issues Task Force) 

Forward-Looking Statements 

This document contains “forward-looking statements” within the 
meaning of the Private Securities Litigation Reform Act of 1995. 
In addition, we may make forward-looking statements in our 
other documents filed or furnished with the SEC, and our 
management may make forward-looking statements orally to 
analysts, investors, representatives of the media and others. 
Forward-looking statements can be identified by words such as 
“anticipates,” “intends,” “plans,” “seeks,” “believes,” “estimates,” 
“expects,” “target,” “projects,” “outlook,” “forecast,” “will,” 
“may,” “could,” “should,” “can” and similar references to future 
periods. In particular, forward-looking statements include, but 
are not limited to, statements we make about: (i) the future 
operating or financial performance of the Company, including 
our outlook for future growth; (ii) our noninterest expense and 
efficiency ratio; (iii) future credit quality and performance, 
including our expectations regarding future loan losses and 
allowance levels; (iv) the appropriateness of the allowance for 
credit losses; (v) our expectations regarding net interest income 
and net interest margin; (vi) loan growth or the reduction or 
mitigation of risk in our loan portfolios; (vii) future capital or 
liquidity levels or targets and our estimated Common Equity Tier 
1 ratio under Basel III capital standards; (viii) the performance 
of our mortgage business and any related exposures; (ix) the 
expected outcome and impact of legal, regulatory and legislative 
developments, as well as our expectations regarding compliance 
therewith; (x) future common stock dividends, common share 
repurchases and other uses of capital; (xi) our targeted range for 
return on assets, return on equity, and return on tangible 
common equity; (xii) the outcome of contingencies, such as legal 
proceedings; and (xiii) the Company’s plans, objectives and 
strategies. 

Forward-looking statements are not based on historical 

facts but instead represent our current expectations and 
assumptions regarding our business, the economy and other 
future conditions. Because forward-looking statements relate to 
the future, they are subject to inherent uncertainties, risks and 

• 	 ASU 2018-13 – Fair Value Measurement (Topic 820): 

Disclosure Framework – Changes to the Disclosure 
Requirements for Fair Value Measurement 
• 	 ASU 2018-09 – Codification Improvements 
• 	 ASU 2018-03 – Technical Corrections and Improvements to 

Financial Instruments – Overall (Subtopic 825-10): 
Financial Instruments – Overall 

• 	 ASU 2017-04 – Intangibles – Goodwill and Other (Topic 
350): Simplifying the Test for Goodwill Impairment 

changes in circumstances that are difficult to predict. Our actual 
results may differ materially from those contemplated by the 
forward-looking statements. We caution you, therefore, against 
relying on any of these forward-looking statements. They are 
neither statements of historical fact nor guarantees or 
assurances of future performance. While there is no assurance 
that any list of risks and uncertainties or risk factors is complete, 
important factors that could cause actual results to differ 
materially from those in the forward-looking statements include 
the following, without limitation: 
• 	

current and future economic and market conditions, 
including the effects of declines in housing prices, high 
unemployment rates, U.S. fiscal debt, budget and tax 
matters, geopolitical matters, and any slowdown in global 
economic growth; 
our capital and liquidity requirements (including under 
regulatory capital standards, such as the Basel III capital 
standards) and our ability to generate capital internally or 
raise capital on favorable terms; 
financial services reform and other current, pending or 
future legislation or regulation that could have a negative 
effect on our revenue and businesses, including the Dodd-
Frank Act and other legislation and regulation relating to 
bank products and services; 

• 	

• 	

• 	 developments in our mortgage banking business, including 
the extent of the success of our mortgage loan modification 
efforts, the amount of mortgage loan repurchase demands 
that we receive, any negative effects relating to our 
mortgage servicing, loan modification or foreclosure 
practices, and the effects of regulatory or judicial 
requirements or guidance impacting our mortgage banking 
business and any changes in industry standards; 
our ability to realize any efficiency ratio or expense target as 
part of our expense management initiatives, including as a 
result of business and economic cyclicality, seasonality, 
changes in our business composition and operating 

• 	

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Forward-Looking Statements (continued) 

environment, growth in our businesses and/or acquisitions, 
and unexpected expenses relating to, among other things, 
litigation and regulatory matters; 
the effect of the current interest rate environment or 
changes in interest rates on our net interest income, net 
interest margin and our mortgage originations, mortgage 
servicing rights and mortgage loans held for sale; 
significant turbulence or a disruption in the capital or 
financial markets, which could result in, among other 
things, reduced investor demand for mortgage loans, a 
reduction in the availability of funding or increased funding 
costs, and declines in asset values and/or recognition of 
other-than-temporary impairment on securities held in our 
debt securities and equity securities portfolios; 
the effect of a fall in stock market prices on our investment 
banking business and our fee income from our brokerage, 
asset and wealth management businesses; 

• 	

• 	

• 	

In addition to the above factors, we also caution that the 
amount and timing of any future common stock dividends or 
repurchases will depend on the earnings, cash requirements and 
financial condition of the Company, market conditions, capital 
requirements (including under Basel capital standards), 
common stock issuance requirements, applicable law and 
regulations (including federal securities laws and federal 
banking regulations), and other factors deemed relevant by the 
Company’s Board of Directors, and may be subject to regulatory 
approval or conditions. 

For more information about factors that could cause actual 

results to differ materially from our expectations, refer to our 
reports filed with the Securities and Exchange Commission, 
including the discussion under “Risk Factors” in this Report, as 
filed with the Securities and Exchange Commission and available 
on its website at www.sec.gov. 

• 	 negative effects from the retail banking sales practices 

Any forward-looking statement made by us speaks only as of 

matter and from other instances where customers may have 
experienced financial harm, including on our legal, 
operational and compliance costs, our ability to engage in 
certain business activities or offer certain products or 
services, our ability to keep and attract customers, our 
ability to attract and retain qualified team members, and 
our reputation; 
resolution of regulatory matters, litigation, or other legal 
actions, which may result in, among other things, additional 
costs, fines, penalties, restrictions on our business activities, 
reputational harm, or other adverse consequences; 
a failure in or breach of our operational or security systems 
or infrastructure, or those of our third-party vendors or 
other service providers, including as a result of cyber 
attacks; 
the effect of changes in the level of checking or savings 
account deposits on our funding costs and net interest 
margin; 
fiscal and monetary policies of the Federal Reserve Board; 
and 
the other risk factors and uncertainties described under 
“Risk Factors” in this Report. 

• 	

• 	

• 	

• 	

• 	

Risk Factors 

An investment in the Company involves risk, including the 
possibility that the value of the investment could fall 
substantially and that dividends or other distributions on the 
investment could be reduced or eliminated. We discuss below 
risk factors that could adversely affect our financial results and 
condition, and the value of, and return on, an investment in the 
Company. 

RISKS RELATED TO THE ECONOMY, FINANCIAL 
MARKETS, INTEREST RATES AND LIQUIDITY 

As one of the largest lenders in the U.S. and a provider 
of financial products and services to consumers and 
businesses across the U.S. and internationally, our 
financial results have been, and will continue to be, 
materially affected by general economic conditions, 
and a deterioration in economic conditions or in the 
financial markets may materially adversely affect our 
lending and other businesses and our financial results 
and condition.  We generate revenue from the interest and 
fees we charge on the loans and other products and services we 

the date on which it is made. Factors or events that could cause 
our actual results to differ may emerge from time to time, and it 
is not possible for us to predict all of them. We undertake no 
obligation to publicly update any forward-looking statement, 
whether as a result of new information, future developments or 
otherwise, except as may be required by law. 

Forward-looking Non-GAAP Financial Measures. From time 
to time management may discuss forward-looking non-GAAP 
financial measures, such as forward-looking estimates or 
targets for return on average tangible common equity. We 
are unable to provide a reconciliation of forward-looking 
non-GAAP financial measures to their most directly 
comparable GAAP financial measures because we are unable 
to provide, without unreasonable effort, a meaningful or 
accurate calculation or estimation of amounts that would be 
necessary for the reconciliation due to the complexity and 
inherent difficulty in forecasting and quantifying future 
amounts or when they may occur. Such unavailable 
information could be significant to future results. 

sell, and a substantial amount of our revenue and earnings 
comes from the net interest income and fee income that we earn 
from our consumer and commercial lending and banking 
businesses, including our mortgage banking business. These 
businesses have been, and will continue to be, materially affected 
by the state of the U.S. economy, particularly unemployment 
levels and home prices. Although the U.S. economy has 
continued to gradually improve from the depressed levels of 
2008 and early 2009, economic growth has at times been slow 
and uneven. In addition, the negative effects and continued 
uncertainty stemming from U.S. fiscal and political matters, 
including concerns about deficit levels, taxes and U.S. debt 
ratings, have impacted and may continue to impact the global 
economic recovery. Moreover, geopolitical matters, including 
international political unrest or disturbances, Britain’s vote to 
withdraw from the European Union, as well as continued 
concerns over commodity prices, restrictions on international 
trade, and global economic difficulties, may impact the stability 
of financial markets and the global economy. In particular, 
Britain’s vote to withdraw from the European Union, including 
the terms of its exit, could increase economic barriers between 

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Britain and the European Union, limit our ability to conduct 
business in the European Union, impose additional costs on us, 
subject us to different laws, regulations and/or regulatory 
authorities, or adversely impact our business, financial results 
and operating model. For example, certain operations of our 
broker-dealer in London may be impacted by the terms and 
conditions of Britain’s withdrawal. Although we are transitioning 
certain of these operations to other European countries, there is 
no guarantee that we will be able to operate or conduct business 
in the European Union in the same manner following Britain’s 
withdrawal. A prolonged period of slow growth in the global 
economy, particularly in the U.S., or any deterioration in general 
economic conditions and/or the financial markets resulting from 
the above matters or any other events or factors that may disrupt 
or dampen the global economic recovery, could materially 
adversely affect our financial results and condition. 

A weakening in business or economic conditions, including 
higher unemployment levels or declines in home prices, can also 
adversely affect our borrowers’ ability to repay their loans, which 
can negatively impact our credit performance. If unemployment 
levels worsen or if home prices fall we would expect to incur 
elevated charge-offs and provision expense from increases in our 
allowance for credit losses. These conditions may adversely 
affect not only consumer loan performance but also commercial 
and CRE loans, especially for those business borrowers that rely 
on the health of industries that may experience deteriorating 
economic conditions. The ability of these and other borrowers to 
repay their loans may deteriorate, causing us, as one of the 
largest commercial and CRE lenders in the U.S., to incur 
significantly higher credit losses. In addition, weak or 
deteriorating economic conditions make it more challenging for 
us to increase our consumer and commercial loan portfolios by 
making loans to creditworthy borrowers at attractive yields. 
Furthermore, weak economic conditions, as well as competition 
and/or increases in interest rates, could soften demand for our 
loans resulting in our retaining a much higher amount of lower 
yielding liquid assets on our balance sheet. If economic 
conditions do not continue to improve or if the economy worsens 
and unemployment rises, which also would likely result in a 
decrease in consumer and business confidence and spending, the 
demand for our credit products, including our mortgages, may 
fall, reducing our interest and noninterest income and our 
earnings. 

A deterioration in business and economic conditions, which 

may erode consumer and investor confidence levels, and/or 
increased volatility of financial markets, also could adversely 
affect financial results for our fee-based businesses, including 
our investment advisory, mutual fund, securities brokerage, 
wealth management, and investment banking businesses. In 
2018, approximately 25% of our revenue was fee income, which 
included trust and investment fees, card fees and other fees. We 
earn fee income from managing assets for others and providing 
brokerage and other investment advisory and wealth 
management services. Because investment management fees are 
often based on the value of assets under management, a fall in 
the market prices of those assets could reduce our fee income. 
Changes in stock market prices could affect the trading activity 
of investors, reducing commissions and other fees we earn from 
our brokerage business. In addition, adverse market conditions 
may negatively affect the performance of products we have 
provided to customers, which may expose us to legal actions or 
additional costs. The U.S. stock market experienced all-time 
highs in 2018, but also experienced significant volatility and 
there is no guarantee that high price levels will continue or that 
price levels will stabilize. Poor economic conditions and volatile 

or unstable financial markets also can negatively affect our debt 
and equity underwriting and advisory businesses, as well as our 
trading activities and venture capital businesses. Any 
deterioration in global financial markets and economies, 
including as a result of any international political unrest or 
disturbances, may adversely affect the revenues and earnings of 
our international operations, particularly our global financial 
institution and correspondent banking services. 

For more information, refer to the “Risk Management – 
Asset/Liability Management” and “– Credit Risk Management” 
sections in this Report. 

Changes in interest rates and financial market values 
could reduce our net interest income and earnings, as 
well as our other comprehensive income, including as a 
result of recognizing losses on the debt and equity 
securities that we hold in our portfolio or trade for our 
customers.  Our net interest income is the interest we earn on 
loans, debt securities and other assets we hold less 
the interest we pay on our deposits, long-term and short-term 
debt, and other liabilities. Net interest income is a measure of 
both our net interest margin – the difference between the yield 
we earn on our assets and the interest rate we pay for deposits 
and our other sources of funding – and the amount of earning 
assets we hold. Changes in either our net interest margin or the 
amount or mix of earning assets we hold could affect our net 
interest income and our earnings. Changes in interest rates can 
affect our net interest margin. Although the yield we earn on our 
assets and our funding costs tend to move in the same direction 
in response to changes in interest rates, one can rise or fall faster 
than the other, causing our net interest margin to expand or 
contract. If our funding costs rise faster than the yield we earn 
on our assets or if the yield we earn on our assets falls faster than 
our funding costs, our net interest margin could contract. 

The amount and type of earning assets we hold can affect 

our yield and net interest margin. We hold earning assets in the 
form of loans and debt and equity securities, among other assets. 
As noted above, if the economy worsens we may see lower 
demand for loans by creditworthy customers, reducing our net 
interest income and yield. In addition, our net interest income 
and net interest margin can be negatively affected by a 
prolonged low interest rate environment as it may result in us 
holding lower yielding loans and securities on our balance sheet, 
particularly if we are unable to replace the maturing higher 
yielding assets with similar higher yielding assets. Increases in 
interest rates, however, may negatively affect loan demand and 
could result in higher credit losses as borrowers may have more 
difficulty making higher interest payments. As described below, 
changes in interest rates also affect our mortgage business, 
including the value of our MSRs. 

Changes in the slope of the “yield curve” – or the spread 
between short-term and long-term interest rates – could also 
reduce our net interest margin. Normally, the yield curve is 
upward sloping, meaning short-term rates are lower than long­
term rates. When the yield curve flattens, or even inverts, our net 
interest margin could decrease if the cost of our short-term 
funding increases relative to the yield we can earn on our long­
term assets. 

The interest we earn on our loans may be tied to U.S.­
denominated interest rates such as the federal funds rate while 
the interest we pay on our debt may be based on international 
rates such as LIBOR. If the federal funds rate were to fall without 
a corresponding decrease in LIBOR, we might earn less on our 
loans without any offsetting decrease in our funding costs. This 
could lower our net interest margin and our net interest income. 

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Risk Factors (continued) 

In addition, our floating rate funding, certain hedging 
transactions, and certain of the products that we offer, such as 
floating rate loans and derivatives in connection with customer 
accommodation activities, reference a benchmark rate, such as 
LIBOR, or other financial metric in order to determine the 
applicable interest rate or payment amount. In the event any 
such benchmark rate or other referenced financial metric is 
significantly changed, replaced or discontinued, or ceases to be 
recognized as an acceptable market benchmark rate or financial 
metric (for example, if LIBOR is discontinued after 2021 as 
contemplated by the U.K. Financial Conduct Authority), there 
may be uncertainty or differences in the calculation of the 
applicable interest rate or payment amount depending on the 
terms of the governing instrument and there may be significant 
work required to transition to using any new benchmark rate or 
other financial metric. This could result in different financial 
performance for previously booked transactions, require 
different hedging strategies, require renegotiation of previously 
booked transactions, or affect our capital and liquidity planning 
and management. In addition, the transition to using any new 
benchmark rate or other financial metric may impact our 
existing transaction data, products, systems, models, operations 
and pricing processes, and could result in significant 
operational, systems, or other practical challenges, increased 
compliance, legal and operational costs, losses on financial 
instruments we hold, or other adverse consequences. 
Furthermore, the transition from a widely-used benchmark rate 
like LIBOR to any new benchmark rate could have a significant 
impact on the overall interest rate environment and could result 
in customers challenging the determination of their interest 
payments or entering into fewer transactions or postponing their 
financing needs, which could reduce our revenue and adversely 
affect our business. Moreover, to the extent borrowers with loans 
referenced to LIBOR, such as adjustable rate mortgage loans, 
experience higher interest payments as a result of the transition 
to a new benchmark rate, our customers’ ability to repay their 
loans may be adversely affected, which can negatively impact our 
credit performance. 

We assess our interest rate risk by estimating the effect on 

our earnings under various scenarios that differ based on 
assumptions about the direction, magnitude and speed of 
interest rate changes and the slope of the yield curve. We hedge 
some of that interest rate risk with interest rate derivatives. We 
also rely on the “natural hedge” that our mortgage loan 
originations and servicing rights can provide. 

We generally do not hedge all of our interest rate risk. There 
is always the risk that changes in interest rates, credit spreads or 
option volatility could reduce our net interest income and 
earnings, as well as our other comprehensive income, in material 
amounts, especially if actual conditions turn out to be materially 
different than what we assumed. For example, if interest rates 
rise or fall faster than we assumed or the slope of the yield curve 
changes, we may incur significant losses on debt securities we 
hold as investments. To reduce our interest rate risk, we may 
rebalance our portfolios of debt securities, equity securities and 
loans, refinance our debt and take other strategic actions. We 
may incur losses when we take such actions. 

We hold debt and equity securities, including U.S. Treasury 
and federal agency securities and federal agency MBS, securities 
of U.S. states and political subdivisions, residential and 
commercial MBS, corporate debt securities, other asset-backed 
securities and marketable equity securities, including securities 
relating to our venture capital activities. Because of changing 
economic and market conditions, as well as credit ratings, 
affecting issuers and the performance of any collateral 

underlying the securities, we may be required to recognize OTTI 
in future periods on the securities we hold. In particular, 
economic difficulties in the oil and gas industry resulting from 
volatile or prolonged low energy prices may further impact our 
energy sector investments and require us to recognize OTTI in 
these investments in future periods. Furthermore, the value of 
the debt securities we hold can fluctuate due to changes in 
interest rates, issuer creditworthiness, and other factors. Our net 
income also is exposed to changes in interest rates, credit 
spreads, foreign exchange rates, and equity and commodity 
prices in connection with our trading activities, which are 
conducted primarily to accommodate the investment and risk 
management activities of our customers, as well as when we 
execute economic hedging to manage certain balance sheet risks. 
Trading debt securities and equity securities held for trading are 
carried at fair value with realized and unrealized gains and losses 
recorded in noninterest income. As part of our business to 
support our customers, we trade public debt and equity 
securities that are subject to market fluctuations with gains and 
losses recognized in net income. In addition, although high 
market volatility can increase our exposure to trading-related 
losses, periods of low volatility may have an adverse effect on our 
businesses as a result of reduced customer activity levels. 
Although we have processes in place to measure and monitor the 
risks associated with our trading activities, including stress 
testing and hedging strategies, there can be no assurance that 
our processes and strategies will be effective in avoiding losses 
that could have a material adverse effect on our financial results. 
The value of our marketable and nonmarketable equity 
securities can fluctuate from quarter to quarter. Marketable 
equity securities are carried at fair value with unrealized gains 
and losses reflected in earnings. Nonmarketable equity securities 
are carried under the cost method, equity method, or 
measurement alternative, while others are carried at fair value 
with unrealized gains and losses reflected in earnings. Earnings 
from our equity securities portfolio may be volatile and hard to 
predict, and may have a significant effect on our earnings from 
period to period. When, and if, we recognize gains may depend 
on a number of factors, including general economic and market 
conditions, the prospects of the companies in which we invest, 
when a company goes public, the size of our position relative to 
the public float, and whether we are subject to any resale 
restrictions. 

Nonmarketable equity securities include our private equity 
and venture capital investments that could result in significant 
OTTI losses for those investments carried under the 
measurement alternative or equity method. If we determine 
there is OTTI for an investment, we write-down the carrying 
value of the investment, resulting in a charge to earnings, which 
could be significant. 

For more information, refer to the “Risk Management – 
Asset/Liability Management – Interest Rate Risk”, “– Mortgage 
Banking Interest Rate and Market Risk”, “– Market Risk – 
Trading Activities”, and “– Market Risk – Equity Securities” and 
the “Balance Sheet Analysis – Available-for-Sale and Held-to-
Maturity Debt Securities” sections in this Report and Note 4 
(Trading Activities), Note 5 (Available-for-Sale and Held-to-
Maturity Debt Securities) and Note 8 (Equity Securities) to 
Financial Statements in this Report. 

Effective liquidity management, which ensures that we 
can meet customer loan requests, customer deposit 
maturities/withdrawals and other cash commitments, 
including principal and interest payments on our debt, 
efficiently under both normal operating conditions and 

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other unpredictable circumstances of industry or 
financial market stress, is essential for the operation of 
our business, and our financial results and condition 
could be materially adversely affected if we do not 
effectively manage our liquidity.  Our liquidity is essential 
for the operation of our business. We primarily rely on bank 
deposits to be a low cost and stable source of funding for the 
loans we make and the operation of our business. Customer 
deposits, which include noninterest-bearing deposits, interest-
bearing checking, savings certificates, certain market rate and 
other savings, and certain foreign deposits, have historically 
provided us with a sizable source of relatively stable and low-cost 
funds. In addition to customer deposits, our sources of liquidity 
include certain debt and equity securities, our ability to sell or 
securitize loans in secondary markets and to pledge loans to 
access secured borrowing facilities through the FHLB and the 
FRB, and our ability to raise funds in domestic and international 
money through capital markets. 

Our liquidity and our ability to fund and run our business 

could be materially adversely affected by a variety of conditions 
and factors, including financial and credit market disruption and 
volatility or a lack of market or customer confidence in financial 
markets in general similar to what occurred during the financial 
crisis in 2008 and early 2009, which may result in a loss of 
customer deposits or outflows of cash or collateral and/or our 
inability to access capital markets on favorable terms. Market 
disruption and volatility could impact our credit spreads, which 
are the amount in excess of the interest rate of U.S. Treasury 
securities, or other benchmark securities, of the same maturity 
that we need to pay to our funding providers. Increases in 
interest rates and our credit spreads could significantly increase 
our funding costs. Other conditions and factors that could 
materially adversely affect our liquidity and funding include a 
lack of market or customer confidence in the Company or 
negative news about the Company or the financial services 
industry generally which also may result in a loss of deposits 
and/or negatively affect our ability to access the capital markets; 
our inability to sell or securitize loans or other assets; and, as 
described below, reductions in one or more of our credit ratings. 
Many of the above conditions and factors may be caused by 
events over which we have little or no control. While market 
conditions have improved since the financial crisis, there can be 
no assurance that significant disruption and volatility in the 
financial markets will not occur in the future. For example, 
concerns over geopolitical issues, commodity and currency 
prices, as well as global economic conditions, may cause 
financial market volatility. 

In addition, concerns regarding U.S. government debt levels 

and any associated downgrade of U.S. government debt ratings 
may cause uncertainty and volatility as well. A downgrade of the 
sovereign debt ratings of the U.S. government or the debt ratings 
of related institutions, agencies or instrumentalities, as well as 
other fiscal or political events could, in addition to causing 
economic and financial market disruptions, materially adversely 
affect the market value of the U.S. government securities that we 
hold, the availability of those securities as collateral for 
borrowing, and our ability to access capital markets on favorable 
terms, as well as have other material adverse effects on the 
operation of our business and our financial results and 
condition. 

As noted above, we rely heavily on bank deposits for our 

funding and liquidity. We compete with banks and other 
financial services companies for deposits. If our competitors 
raise the rates they pay on deposits our funding costs may 
increase, either because we raise our rates to avoid losing 

deposits or because we lose deposits and must rely on more 
expensive sources of funding. Higher funding costs reduce our 
net interest margin and net interest income. Checking and 
savings account balances and other forms of customer deposits 
may decrease when customers perceive alternative investments, 
such as the stock market, as providing a better risk/return 
tradeoff. When customers move money out of bank deposits and 
into other investments, we may lose a relatively low-cost source 
of funds, increasing our funding costs and negatively affecting 
our liquidity. 

If we are unable to continue to fund our assets through 
customer bank deposits or access capital markets on favorable 
terms or if we suffer an increase in our borrowing costs or 
otherwise fail to manage our liquidity effectively (including on 
an intraday basis), our liquidity, net interest margin, financial 
results and condition may be materially adversely affected. As we 
did during the financial crisis, we may also need, or be required 
by our regulators, to raise additional capital through the 
issuance of common stock, which could dilute the ownership of 
existing stockholders, or reduce or even eliminate our common 
stock dividend to preserve capital or in order to raise additional 
capital. 

For more information, refer to the “Risk Management – 

Asset/Liability Management” section in this Report. 

Adverse changes in our credit ratings could have a 
material adverse effect on our liquidity, cash flows, 
financial results and condition.  Our borrowing costs and 
ability to obtain funding are influenced by our credit ratings. 
Reductions in one or more of our credit ratings could adversely 
affect our ability to borrow funds and raise the costs of our 
borrowings substantially and could cause creditors and business 
counterparties to raise collateral requirements or take other 
actions that could adversely affect our ability to raise funding. 
Credit ratings and credit ratings agencies’ outlooks are based on 
the ratings agencies’ analysis of many quantitative and 
qualitative factors, such as our capital adequacy, liquidity, asset 
quality, business mix, the level and quality of our earnings, 
rating agency assumptions regarding the probability and extent 
of federal financial assistance or support, and other rating 
agency specific criteria. In addition to credit ratings, our 
borrowing costs are affected by various other external factors, 
including market volatility and concerns or perceptions about 
the financial services industry generally. There can be no 
assurance that we will maintain our credit ratings and outlooks 
and that credit ratings downgrades in the future would not 
materially affect our ability to borrow funds and borrowing 
costs. 

Downgrades in our credit ratings also may trigger additional 

collateral or funding obligations which could negatively affect 
our liquidity, including as a result of credit-related contingent 
features in certain of our derivative contracts. Although a one or 
two notch downgrade in our current credit ratings would not be 
expected to trigger a material increase in our collateral or 
funding obligations, a more severe credit rating downgrade of 
our long-term and short-term credit ratings could increase our 
collateral or funding obligations and the effect on our liquidity 
could be material. 

For information on our credit ratings, see the “Risk 
Management – Asset/Liability Management – Liquidity and 
Funding – Credit Ratings” section and for information regarding 
additional collateral and funding obligations required of certain 
derivative instruments in the event our credit ratings were to fall 
below investment grade, see Note 17 (Derivatives) to Financial 
Statements in this Report. 

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Risk Factors (continued) 

We rely on dividends from our subsidiaries for 
liquidity, and federal and state law, as well as certain 
contractual arrangements, can limit those dividends. 
Wells Fargo & Company, the parent holding company (the 
“Parent”), is a separate and distinct legal entity from its 
subsidiaries. It receives substantially all of its funding and 
liquidity from dividends and other distributions from its 
subsidiaries. We generally use these dividends and distributions, 
among other things, to pay dividends on our common and 
preferred stock and interest and principal on our debt. Federal 
and state laws limit the amount of dividends and distributions 
that our bank and some of our nonbank subsidiaries, including 
our broker-dealer subsidiaries, may pay to the Parent. In 
addition, under a Support Agreement (the “Support Agreement”) 
dated June 28, 2017 among the Parent, WFC Holdings, LLC, an 
intermediate holding company and subsidiary of the Parent (the 
“IHC”), and Wells Fargo Bank, N.A., Wells Fargo Securities, 
LLC, and Wells Fargo Clearing Services, LLC, each an indirect 
subsidiary of the Parent, the IHC may be restricted from making 
dividend payments to the Parent if certain liquidity and/or 
capital metrics fall below defined triggers. Also, our right to 
participate in a distribution of assets upon a subsidiary’s 
liquidation or reorganization is subject to the prior claims of the 
subsidiary’s creditors. 

For more information, refer to the “Regulation and 

Supervision – Dividend Restrictions” and “– Holding Company 
Structure” sections in our 2018 Form 10-K and to Note 3 (Cash, 
Loan and Dividend Restrictions) and Note 28 (Regulatory and 
Agency Capital Requirements) to Financial Statements in this 
Report. 

RISKS RELATED TO FINANCIAL REGULATORY 
REFORM AND OTHER LEGISLATION AND 
REGULATIONS 

Enacted legislation and regulation, including the Dodd-
Frank Act, as well as future legislation and/or 
regulation, could require us to change certain of our 
business practices, reduce our revenue and earnings, 
impose additional costs on us or otherwise adversely 
affect our business operations and/or competitive 
position.  Our parent company, our subsidiary banks and many 
of our nonbank subsidiaries such as those related to our 
brokerage and mutual fund businesses, are subject to significant 
and extensive regulation under state and federal laws in the U.S., 
as well as the applicable laws of the various jurisdictions outside 
of the U.S. where we conduct business. These regulations protect 
depositors, federal deposit insurance funds, consumers, 
investors, team members, and the banking and financial system 
as a whole, not necessarily our security holders. Economic, 
market and political conditions during the past few years have 
led to a significant amount of legislation and regulation in the 
U.S. and abroad affecting the financial services industry, as well 
as heightened expectations and scrutiny of financial services 
companies from banking regulators. These laws and regulations 
may affect the manner in which we do business and the products 
and services that we provide, affect or restrict our ability to 
compete in our current businesses or our ability to enter into or 
acquire new businesses, reduce or limit our revenue in 
businesses or impose additional fees, assessments or taxes on us, 
intensify the regulatory supervision of us and the financial 
services industry, and adversely affect our business operations or 
have other negative consequences. Our businesses and revenues 
in non-U.S. jurisdictions are also subject to risks from political, 
economic and social developments in those jurisdictions, 

including sanctions or business restrictions, asset freezes or 
confiscation, unfavorable political or diplomatic developments, 
or financial or social instability. In addition, greater government 
oversight and scrutiny of financial services companies has 
increased our operational and compliance costs as we must 
continue to devote substantial resources to enhancing our 
procedures and controls and meeting heightened regulatory 
standards and expectations. Any failure to meet regulatory 
requirements, standards or expectations, either in the U.S. or in 
foreign jurisdictions, could result in fees, penalties, restrictions 
on our ability to engage in certain business activities, or other 
adverse consequences. 

On July 21, 2010, the Dodd-Frank Act, the most significant 

financial reform legislation since the 1930s, became law. The 
Dodd-Frank Act, among other things, imposes significant 
requirements and restrictions impacting the financial services 
industry. The Dodd-Frank Act, including current and future 
rules implementing its provisions and the interpretation of those 
rules, could result in a loss of revenue, require us to change 
certain of our business practices, limit our ability to pursue 
certain business opportunities, increase our capital requirements 
and impose additional assessments and costs on us and 
otherwise adversely affect our business operations and have 
other negative consequences. 

Our consumer businesses, including our mortgage, 
automobile, credit card and other consumer lending and non-
lending businesses, are subject to numerous and, in many cases, 
highly complex consumer protection laws and regulations, as 
well as enhanced regulatory scrutiny and more and expanded 
regulatory examinations and/or investigations. In particular, we 
may be negatively affected by the activities of the Consumer 
Financial Protection Bureau (CFPB), which has broad 
rulemaking powers and supervisory authority over consumer 
financial products and services. The CFPB’s activities may 
increase our compliance costs and require changes in our 
business practices as a result of regulations and requirements 
which could limit or negatively affect the products and services 
that we offer our customers. For example, the CFPB has issued a 
number of rules impacting residential mortgage lending 
practices and prepaid cards. If we fail to meet enhanced 
regulatory requirements and expectations with respect to our 
consumer businesses, we may be subject to increased costs, 
fines, penalties, restrictions on our business activities including 
the products and services we can provide, and/or harm to our 
reputation. 

The Dodd-Frank Act’s proposed prohibitions or limitations 

on proprietary trading and private fund investment activities, 
known as the “Volcker Rule,” also may reduce our revenue. Final 
rules to implement the requirements of the Volcker Rule were 
issued in December 2013. The FRB has proposed further rules to 
streamline and modify compliance with the Volcker Rule’s 
requirements. Wells Fargo is also subject to enhanced 
compliance program requirements. 

In addition, the Dodd-Frank Act established a 

comprehensive framework for regulating over-the-counter 
derivatives and authorized the CFTC and SEC to regulate swaps 
and security-based swaps, respectively. The CFTC has adopted 
rules applicable to our provisionally registered swap dealer, 
Wells Fargo Bank, N.A., that require, among other things, 
extensive regulatory and public reporting of swaps, central 
clearing and trading of swaps on exchanges or other multilateral 
platforms, and compliance with comprehensive internal and 
external business conduct standards. The SEC is expected to 
implement parallel rules applicable to security-based swaps. In 
addition, federal regulators have adopted final rules establishing 

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initial and variation margin requirements for swaps and 
security-based swaps not centrally cleared, rules placing 
restrictions on a party’s right to exercise default rights under 
derivatives and other qualified financial contracts against 
applicable banking organizations, and record-keeping 
requirements for qualified financial contracts. All of these new 
rules, as well as others being considered by regulators in other 
jurisdictions, may negatively impact customer demand for over­
the-counter derivatives, impact our ability to offer customers 
new derivatives or amendments to existing derivatives, and may 
increase our costs for engaging in swaps, security-based swaps, 
and other derivatives activities. 

We are also subject to various rules and regulations related 
to the prevention of financial crimes and combating terrorism, 
including the U.S. Patriot Act of 2001. These rules and 
regulations require us to, among other things, implement 
policies and procedures related to anti-money laundering, anti-
bribery and corruption, fraud, compliance, suspicious activities, 
currency transaction reporting and due diligence on customers. 
Although we have policies and procedures designed to comply 
with these rules and regulations, to the extent they are not fully 
effective or do not meet heightened regulatory standards or 
expectations, we may be subject to fines, penalties, restrictions 
on certain activities, reputational harm, or other adverse 
consequences. 

Our businesses are also subject to laws and regulations 
enacted by U.S. and non-U.S. regulators and governmental 
authorities relating to the privacy of the information of 
customers, team members and others. These laws and 
regulations, among other things, increase our compliance 
obligations; have a significant impact on our businesses’ 
collection, processing, sharing, use, and retention of personal 
data and reporting of data breaches; and provide for significantly 
increased penalties for non-compliance. 

In April 2018, the SEC proposed a rule that would require 

broker-dealers to act in the best interest of a retail customer 
when making a recommendation of any securities transaction or 
investment strategy involving securities. This rule may impact 
the manner in which business is conducted with customers 
seeking investment advice and may affect certain investment 
product offerings. 

On November 18, 2016, the OCC revoked provisions of 

certain consent orders that provided Wells Fargo Bank, N.A. 
relief from specific requirements and limitations regarding rules, 
policies, and procedures for corporate activities; OCC approval 
of changes in directors and senior executive officers; and golden 
parachute payments. As a result, Wells Fargo Bank, N.A. is no 
longer eligible for expedited treatment for certain applications; 
is now required to provide prior written notice to the OCC of a 
change in directors and senior executive officers; and is now 
subject to certain regulatory limitations on golden parachute 
payments. 

In March 2017, we announced that the OCC had 

downgraded our most recent Community Reinvestment Act 
(CRA) rating, which covers the years 2009-2012, to “Needs to 
Improve” due to previously issued regulatory consent orders. A 
“Needs to Improve” rating imposes regulatory restrictions and 
limitations on certain of the Company’s nonbank activities, 
including its ability to engage in certain nonbank mergers and 
acquisitions or undertake new financial in nature activities, and 
CRA performance is taken into account by regulators in 
reviewing applications to establish bank branches and for 
approving proposed bank mergers and acquisitions. The rating 
also results in the loss of expedited processing of applications to 
undertake certain activities, and requires the Company to receive 

prior regulatory approval for certain activities, including to issue 
or prepay certain subordinated debt obligations, open or relocate 
bank branches, or make certain public welfare investments. In 
addition, a “Needs to Improve” rating could have an impact on 
the Company’s relationships with certain states, counties, 
municipalities or other public agencies to the extent applicable 
law, regulation or policy limits, restricts or influences whether 
such entity may do business with a company that has a below 
“Satisfactory” rating. 

On February 2, 2018, the Company entered into a consent 

order with the FRB. As required by the consent order, the Board 
submitted to the FRB a plan to further enhance the Board’s 
governance and oversight of the Company, and the Company 
submitted to the FRB a plan to further improve the Company’s 
compliance and operational risk management program. The 
consent order requires the Company, following the FRB’s 
acceptance and approval of the plans and the Company’s 
adoption and implementation of the plans, to complete third-
party reviews of the enhancements and improvements provided 
for in the plans. Until these third-party reviews are complete and 
the plans are approved and implemented to the satisfaction of 
the FRB, the Company’s total consolidated assets will be limited 
to the level as of December 31, 2017, which could adversely affect 
our results of operations or financial condition. Compliance with 
this asset cap will be measured on a two-quarter daily average 
basis to allow for management of temporary fluctuations. 
Additionally, after removal of the asset cap, a second third-party 
review must also be conducted to assess the efficacy and 
sustainability of the enhancements and improvements. 

On April 20, 2018, the Company entered into consent 
orders with the CFPB and OCC to pay an aggregate of $1 billion 
in civil money penalties to resolve matters regarding the 
Company’s compliance risk management program and past 
practices involving certain automobile collateral protection 
insurance policies and certain mortgage interest rate lock 
extensions. As required by the consent orders, the Company 
submitted to the CFPB and OCC an enterprise-wide compliance 
risk management plan and a plan to enhance the Company’s 
internal audit program with respect to federal consumer 
financial law and the terms of the consent orders. In addition, as 
required by the consent orders, the Company submitted for non-
objection plans to remediate customers affected by the 
automobile collateral protection insurance and mortgage 
interest rate lock matters, as well as a plan for the management 
of remediation activities conducted by the Company. 

The Company may be subject to further actions, including 

the imposition of consent orders or similar regulatory 
agreements or civil money penalties, by other federal regulators 
regarding similar issues, including the Company’s risk 
management policies and procedures. Compliance with the FRB 
consent order, the CFPB and OCC consent orders, and any other 
consent orders or regulatory actions, as well as the 
implementation of their requirements, may increase the 
Company’s costs and require the Company to undergo 
significant changes to its business, products and services. 

Other future regulatory initiatives that could significantly 

affect our business include proposals to reform the housing 
finance market in the United States. These proposals, among 
other things, consider winding down the GSEs and reducing or 
eliminating over time the role of the GSEs in guaranteeing 
mortgages and providing funding for mortgage loans, as well as 
the implementation of reforms relating to borrowers, lenders, 
and investors in the mortgage market, including reducing the 
maximum size of a loan that the GSEs can guarantee, phasing in 
a minimum down payment requirement for borrowers, 

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Risk Factors (continued) 

improving underwriting standards, and increasing 
accountability and transparency in the securitization process. 
Congress also may consider the adoption of legislation to reform 
the mortgage financing market in an effort to assist borrowers 
experiencing difficulty in making mortgage payments or 
refinancing their mortgages. The extent and timing of any 
regulatory reform or the adoption of any legislation regarding 
the GSEs and/or the home mortgage market, as well as any 
effect on the Company’s business and financial results, are 
uncertain. 

Any other future legislation and/or regulation, if adopted, 
also could significantly change our regulatory environment and 
increase our cost of doing business, limit the activities we may 
pursue or affect the competitive balance among banks, savings 
associations, credit unions, and other financial services 
companies, and have a material adverse effect on our financial 
results and condition. 

For more information, refer to the “Regulatory Matters” 
section in this Report and the “Regulation and Supervision” 
section in our 2018 Form 10-K. 

We could be subject to more stringent capital, leverage 
or liquidity requirements or restrictions on our growth, 
activities or operations if regulators determine that our 
resolution or recovery plan is deficient.  Pursuant to rules 
adopted by the FRB and the FDIC, Wells Fargo has prepared and 
filed a resolution plan, a so-called “living will,” that is designed 
to facilitate our resolution in the event of material distress or 
failure. There can be no assurance that the FRB or FDIC will 
respond favorably to the Company’s resolution plans. If the FRB 
or FDIC determines that our resolution plan has deficiencies, 
they may impose more stringent capital, leverage or liquidity 
requirements on us or restrict our growth, activities or 
operations until we adequately remedy the deficiencies. If the 
FRB or FDIC ultimately determines that we have been unable to 
remedy any deficiencies, they could require us to divest certain 
assets or operations. 

We must also prepare and submit to the FRB a recovery 
plan that identifies a range of options that we may consider 
during times of idiosyncratic or systemic economic stress to 
remedy any financial weaknesses and restore market confidence 
without extraordinary government support. Recovery options 
include the possible sale, transfer or disposal of assets, 
securities, loan portfolios or businesses. Our insured national 
bank subsidiary, Wells Fargo Bank, N.A. (the “Bank”), must also 
prepare and submit to the OCC a recovery plan that sets forth 
the Bank’s plan to remain a going concern when the Bank is 
experiencing considerable financial or operational stress, but has 
not yet deteriorated to the point where liquidation or resolution 
is imminent. If the FRB or the OCC determines that our recovery 
plan is deficient, they may impose fines, restrictions on our 
business or ultimately require us to divest assets. 

Our security holders may suffer losses in a resolution 
of Wells Fargo, whether in a bankruptcy proceeding or 
under the orderly liquidation authority of the FDIC, 
even if creditors of our subsidiaries are paid in full.  If 
Wells Fargo were to fail, it may be resolved in a bankruptcy 
proceeding or, if certain conditions are met, under the resolution 
regime created by the Dodd-Frank Act known as the “orderly 
liquidation authority.” The orderly liquidation authority allows 
for the appointment of the FDIC as receiver for a systemically 
important financial institution that is in default or in danger of 
default if, among other things, the resolution of the institution 
under the U.S. Bankruptcy Code would have serious adverse 

effects on financial stability in the United States. If the FDIC is 
appointed as receiver for Wells Fargo & Company (the “Parent”), 
then the orderly liquidation authority, rather than the U.S. 
Bankruptcy Code, would determine the powers of the receiver 
and the rights and obligations of our security holders. The 
FDIC’s orderly liquidation authority requires that security 
holders of a company in receivership bear all losses before U.S. 
taxpayers are exposed to any losses, and allows the FDIC to 
disregard the strict priority of creditor claims under the U.S. 
Bankruptcy Code in certain circumstances. 

Whether under the U.S. Bankruptcy Code or by the FDIC 
under the orderly liquidation authority, Wells Fargo could be 
resolved using a “multiple point of entry” strategy, in which the 
Parent and one or more of its subsidiaries would each undergo 
separate resolution proceedings, or a “single point of entry” 
strategy, in which the Parent would likely be the only material 
legal entity to enter resolution proceedings. The FDIC has 
announced that a single point of entry strategy may be a 
desirable strategy under its implementation of the orderly 
liquidation authority, but not all aspects of how the FDIC might 
exercise this authority are known and additional rulemaking is 
possible. 

The strategy described in our most recent resolution plan 
submission is a multiple point of entry strategy; however, we 
have made a decision to move to a single point of entry strategy 
for our next resolution plan submission. We are not obligated to 
maintain either a single point of entry or multiple point of entry 
strategy, and the strategies reflected in our resolution plan 
submissions are not binding in the event of an actual resolution 
of Wells Fargo, whether conducted under the U.S. Bankruptcy 
Code or by the FDIC under the orderly liquidation authority. 

To facilitate the orderly resolution of systemically important 

financial institutions in case of material distress or failure, 
federal banking regulations require that institutions, such as 
Wells Fargo, maintain a minimum amount of equity and 
unsecured debt to absorb losses and recapitalize operating 
subsidiaries. Federal banking regulators have also required 
measures to facilitate the continued operation of operating 
subsidiaries notwithstanding the failure of their parent 
companies, such as limitations on parent guarantees, and have 
issued guidance encouraging institutions to take legally binding 
measures to provide capital and liquidity resources to certain 
subsidiaries in order to facilitate an orderly resolution. In 
response to the regulators’ guidance and to facilitate the orderly 
resolution of the Company using either a single point of entry or 
multiple point of entry resolution strategy, on June 28, 2017, the 
Parent entered into the Support Agreement with WFC Holdings, 
LLC, an intermediate holding company and subsidiary of the 
Parent (the “IHC”), and the Bank, Wells Fargo Securities, LLC 
(“WFS”), and Wells Fargo Clearing Services, LLC (“WFCS”), 
each an indirect subsidiary of the Parent. Pursuant to the 
Support Agreement, the Parent transferred a significant amount 
of its assets, including the majority of its cash, deposits, liquid 
securities and intercompany loans (but excluding its equity 
interests in its subsidiaries and certain other assets), to the IHC 
and will continue to transfer those types of assets to the IHC 
from time to time. In the event of our material financial distress 
or failure, the IHC will be obligated to use the transferred assets 
to provide capital and/or liquidity to the Bank pursuant to the 
Support Agreement and to WFS and WFCS through repurchase 
facilities entered into in connection with the Support Agreement. 
Under the Support Agreement, the IHC will also provide funding 
and liquidity to the Parent through subordinated notes and a 
committed line of credit, which, together with the issuance of 
dividends, is expected to provide the Parent, during business as 

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Wells Fargo & Company 

126

usual operating conditions, with the same access to cash 
necessary to service its debts, pay dividends, repurchase its 
shares, and perform its other obligations as it would have had if 
it had not entered into these arrangements and transferred any 
assets. If certain liquidity and/or capital metrics fall below 
defined triggers, the subordinated notes would be forgiven and 
the committed line of credit would terminate, which could 
materially and adversely impact the Parent’s liquidity and its 
ability to satisfy its debts and other obligations, and could result 
in the commencement of bankruptcy proceedings by the Parent 
at an earlier time than might have otherwise occurred if the 
Support Agreement were not implemented. The Parent’s and the 
IHC’s respective obligations under the Support Agreement are 
secured pursuant to a related security agreement. 

Any resolution of the Company will likely impose losses on 
shareholders, unsecured debt holders and other creditors of the 
Parent, while the Parent’s subsidiaries may continue to operate. 
Creditors of some or all of our subsidiaries may receive 
significant or full recoveries on their claims, while the Parent’s 
security holders could face significant or complete losses. This 
outcome may arise whether the Company is resolved under the 
U.S. Bankruptcy Code or by the FDIC under the orderly 
liquidation authority, and whether the resolution is conducted 
using a multiple point of entry or a single point of entry strategy. 
Furthermore, in a multiple point of entry or single point of entry 
strategy, losses at some or all of our subsidiaries could be 
transferred to the Parent and borne by the Parent’s security 
holders. Moreover, if either resolution strategy proved to be 
unsuccessful, our security holders could face greater losses than 
if the strategy had not been implemented. 

Bank regulations, including Basel capital and liquidity 
standards and FRB guidelines and rules, may require 
higher capital and liquidity levels, limiting our ability to 
pay common stock dividends, repurchase our common 
stock, invest in our business, or provide loans or other 
products and services to our customers.  The Company 
and each of our insured depository institutions are subject to 
various regulatory capital adequacy requirements administered 
by federal banking regulators. In particular, the Company is 
subject to final and interim final rules issued by federal banking 
regulators to implement Basel III capital requirements for U.S. 
banking organizations. These rules are based on international 
guidelines for determining regulatory capital issued by the Basel 
Committee on Banking Supervision (BCBS). The federal banking 
regulators’ capital rules, among other things, require on a fully 
phased-in basis: 
• 	

a minimum Common Equity Tier 1 (CET1) ratio of 9.0%, 
comprised of a 4.5% minimum requirement plus a capital 
conservation buffer of 2.5% and for us, as a global 
systemically important bank (G-SIB), a capital surcharge to 
be calculated annually, which is 2.0% based on our year-end 
2017 data; 
a minimum tier 1 capital ratio of 10.5%, comprised of a 6.0% 
minimum requirement plus the capital conservation buffer 
of 2.5% and the G-SIB capital surcharge of 2.0%; 
a minimum total capital ratio of 12.5%, comprised of a 8.0% 
minimum requirement plus the capital conservation buffer 
of 2.5% and the G-SIB capital surcharge of 2.0%; 
a potential countercyclical buffer of up to 2.5% to be added 
to the minimum capital ratios, which is currently not in 
effect but could be imposed by regulators at their discretion 
if it is determined that a period of excessive credit growth is 
contributing to an increase in systemic risk; 
a minimum tier 1 leverage ratio of 4.0%; and 

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a minimum supplementary leverage ratio (SLR) of 5.0% 
(comprised of a 3.0% minimum requirement plus a 
supplementary leverage buffer of 2.0%) for large and 
internationally active bank holding companies (BHCs). 

We were required to comply with the final Basel III capital 
rules beginning January 2014, with certain provisions subject to 
phase-in periods. Beginning January 1, 2018, the requirements 
for calculating CET1 and tier 1 capital, along with RWAs, became 
fully phased-in. However, the requirements for calculating tier 2 
and total capital are still in accordance with Transition 
Requirements. The entire Basel III capital rules are scheduled to 
be fully phased in by the end of 2021. 

On April 10, 2018, the FRB issued a proposed rule that 
would add a stress capital buffer and a stress leverage buffer to 
the minimum capital and tier 1 leverage ratio requirements. The 
buffers would be calculated based on the decrease in a financial 
institution’s risk-based capital and tier 1 leverage ratios under 
the supervisory severely adverse scenario in CCAR, plus four 
quarters of planned common stock dividends. The stress capital 
buffer would replace the 2.5% capital conservation buffer under 
the Standardized Approach, whereas the stress leverage buffer 
would be added to the current 4% minimum tier 1 leverage ratio. 
Because the Company has been designated as a G-SIB, we 
are also subject to the FRB’s rule implementing the additional 
capital surcharge of between 1.0-4.5% on G-SIBs. Under the 
rule, we must annually calculate our surcharge under two 
prescribed methods and use the higher of the two surcharges. 
The G-SIB surcharge became fully effective on January 1, 2019. 
Based on year-end 2017 data, our 2019 G-SIB surcharge is 2.0% 
of the Company’s RWAs. However, because the G-SIB surcharge 
is calculated annually based on data that can differ over time, the 
amount of the surcharge is subject to change in future years. 
In April 2014, federal banking regulators finalized a rule 
that enhances the SLR requirements for BHCs, like Wells Fargo, 
and their insured depository institutions. The SLR consists of 
tier 1 capital under Basel III divided by the Company’s total 
leverage exposure. Total leverage exposure consists of the total 
average on-balance sheet assets, plus off-balance sheet 
exposures, such as undrawn commitments and derivative 
exposures, less amounts permitted to be deducted from tier 1 
capital. The rule, which became effective on January 1, 2018, 
requires a covered BHC to maintain a SLR of at least 5.0% 
(comprised of the 3.0% minimum requirement plus a 
supplementary leverage buffer of 2.0%) to avoid restrictions on 
capital distributions and discretionary bonus payments. The rule 
also requires that all of our insured depository institutions 
maintain a SLR of 6.0% under applicable regulatory capital 
adequacy guidelines. In April 2018, the FRB and OCC proposed 
rules (the “Proposed SLR Rules”) that would replace the 2% 
supplementary leverage buffer with a buffer equal to one-half of 
the firm’s G-SIB capital surcharge. The Proposed SLR Rules 
would similarly tailor the current 6% SLR requirement for our 
insured depository institutions. 

In December 2016, the FRB finalized rules to address the 
amount of equity and unsecured long-term debt a U.S. G-SIB 
must hold to improve its resolvability and resiliency, often 
referred to as Total Loss Absorbing Capacity (TLAC). Under the 
rules, which became effective on January 1, 2019, U.S. G-SIBs 
are required to have a minimum TLAC amount (consisting of 
CET1 capital and additional tier 1 capital issued directly by the 
top-tier or covered BHC plus eligible external long-term debt) 
equal to the greater of (i) 18% of RWAs and (ii) 7.5% of total 
leverage exposure (the denominator of the SLR calculation). 
Additionally, U.S. G-SIBs are required to maintain (i) a TLAC 

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Risk Factors (continued) 

buffer equal to 2.5% of RWAs plus the firm’s applicable G-SIB 
capital surcharge calculated under method one of the G-SIB 
calculation plus any applicable countercyclical buffer to be added 
to the 18% minimum and (ii) an external TLAC leverage buffer 
equal to 2.0% of total leverage exposure to be added to the 7.5% 
minimum, in order to avoid restrictions on capital distributions 
and discretionary bonus payments. The rules also require U.S. 
G-SIBs to have a minimum amount of eligible unsecured long­
term debt equal to the greater of (i) 6.0% of RWAs plus the 
firm’s applicable G-SIB capital surcharge calculated under 
method two of the G-SIB calculation and (ii) 4.5% of the total 
leverage exposure. In addition, the rules impose certain 
restrictions on the operations and liabilities of the top-tier or 
covered BHC in order to further facilitate an orderly resolution, 
including prohibitions on the issuance of short-term debt to 
external investors and on entering into derivatives and certain 
other types of financial contracts with external counterparties. 
While the rules permit permanent grandfathering of a significant 
portion of otherwise ineligible long-term debt that was issued 
prior to December 31, 2016, long-term debt issued after that date 
must be fully compliant with the eligibility requirements of the 
rules in order to count toward the minimum TLAC amount. As a 
result of the rules, we will need to issue additional long-term 
debt to remain compliant with the requirements. Under the 
Proposed SLR Rules, the 2% external TLAC leverage buffer 
would be replaced with a buffer equal to one-half of the firm’s G­
SIB capital surcharge. Additionally, the Proposed SLR Rules 
would modify the leverage component for calculating the 
minimum amount of eligible unsecured long-term debt from 
4.5% of total leverage exposure to 2.5% of total leverage 
exposure plus one-half of the firm’s G-SIB capital surcharge. 

In September 2014, federal banking regulators issued a final 

rule that implements a quantitative liquidity requirement 
consistent with the liquidity coverage ratio (LCR) established by 
the BCBS. The rule requires banking institutions, such as 
Wells Fargo, to hold high-quality liquid assets, such as central 
bank reserves and government and corporate debt that can be 
converted easily and quickly into cash, in an amount equal to or 
greater than its projected net cash outflows during a 30-day 
stress period. The FRB also finalized rules imposing enhanced 
liquidity management standards on large BHCs such as Wells 
Fargo, and has finalized a rule that requires large bank holding 
companies to publicly disclose on a quarterly basis certain 
quantitative and qualitative information regarding their LCR 
calculations. 

As part of its obligation to impose enhanced capital and 
risk-management standards on large financial firms pursuant to 
the Dodd-Frank Act, the FRB issued a final capital plan rule that 
requires large BHCs, including the Company, to submit annual 
capital plans for review and to obtain regulatory approval before 
making capital distributions. There can be no assurance that the 
FRB would respond favorably to the Company’s future capital 
plans. The FRB has also finalized a number of regulations 
implementing enhanced prudential requirements for large BHCs 
like Wells Fargo regarding risk-based capital and leverage, risk 
and liquidity management, and imposing debt-to-equity limits 
on any BHC that regulators determine poses a grave threat to the 
financial stability of the United States. The FRB and OCC have 
also finalized rules implementing stress testing requirements for 
large BHCs and national banks. The FRB has also finalized 
enhanced prudential standards that implement single 
counterparty credit limits, and has proposed a rule to establish 
remediation requirements for large BHCs experiencing financial 
distress. The OCC, under separate authority, has also established 

heightened governance and risk management standards for large 
national banks, such as Wells Fargo Bank, N.A. 

The Basel standards and federal regulatory capital and 
liquidity requirements may limit or otherwise restrict how we 
utilize our capital, including common stock dividends and stock 
repurchases, and may require us to increase our capital and/or 
liquidity. Any requirement that we increase our regulatory 
capital, regulatory capital ratios or liquidity, including as a result 
of business growth, acquisitions or a change in our risk profile, 
could require us to liquidate assets or otherwise change our 
business, product offerings and/or investment plans, which may 
negatively affect our financial results. Although not currently 
anticipated, proposed capital requirements and/or our 
regulators may require us to raise additional capital in the 
future. Issuing additional common stock may dilute the 
ownership of existing stockholders. In addition, federal banking 
regulations may increase our compliance costs as well as limit 
our ability to invest in our business or provide loans or other 
products and services to our customers. 

For more information, refer to the “Capital Management” 

and “Regulatory Matters” sections in this Report and the 
“Regulation and Supervision” section of our 2018 Form 10-K. 

FRB policies, including policies on interest rates, can 
significantly affect business and economic conditions 
and our financial results and condition.  The FRB 
regulates the supply of money in the United States. Its policies 
determine in large part our cost of funds for lending and 
investing and the return we earn on those loans and 
investments, both of which affect our net interest income and 
net interest margin. The FRB’s interest rate policies also can 
materially affect the value of financial instruments we hold, such 
as debt securities and MSRs. In addition, its policies can affect 
our borrowers, potentially increasing the risk that they may fail 
to repay their loans. Changes in FRB policies are beyond our 
control and can be hard to predict. The FRB has stated that in 
determining the timing and size of any adjustments to the target 
range for the federal funds rate, the FRB will assess realized and 
expected economic conditions relative to its objectives of 
maximum employment and 2% inflation. As noted above, a 
declining or low interest rate environment and a flattening yield 
curve which may result from the FRB’s actions could negatively 
affect our net interest income and net interest margin as it may 
result in us holding lower yielding loans and debt securities on 
our balance sheet. 

CREDIT RISK 

As one of the largest lenders in the U.S., increased 
credit risk, including as a result of a deterioration in 
economic conditions or changes in market conditions, 
could require us to increase our provision for credit 
losses and allowance for credit losses and could have a 
material adverse effect on our results of operations and 
financial condition.  When we loan money or commit to loan 
money we incur credit risk, or the risk of losses if our borrowers 
do not repay their loans. As one of the largest lenders in the U.S., 
the credit performance of our loan portfolios significantly affects 
our financial results and condition. As noted above, if the 
current economic environment were to deteriorate, more of our 
customers may have difficulty in repaying their loans or other 
obligations which could result in a higher level of credit losses 
and provision for credit losses. We reserve for credit losses by 
establishing an allowance through a charge to earnings. The 
amount of this allowance is based on our assessment of credit 

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losses inherent in our loan portfolio (including unfunded credit 
commitments). The process for determining the amount of the 
allowance is critical to our financial results and condition. It 
requires difficult, subjective and complex judgments about the 
future, including forecasts of economic or market conditions that 
might impair the ability of our borrowers to repay their loans. 
We might increase the allowance because of changing economic 
conditions, including falling home prices and higher 
unemployment, significant loan growth, changes in consumer 
behavior or other market conditions that adversely affect 
borrowers, or other factors. Additionally, the regulatory 
environment or external factors, such as natural disasters, also 
can influence recognition of credit losses in our loan portfolios 
and impact our allowance for credit losses. 

Our provision for credit losses was $1.0 billion less than net 
charge-offs in 2018, which had a positive effect on our earnings. 
Future allowance levels may increase or decrease based on a 
variety of factors, including loan growth, portfolio performance 
and general economic conditions. While we believe that our 
allowance for credit losses was appropriate at December 31, 
2018, there is no assurance that it will be sufficient to cover 
future credit losses, especially if housing and employment 
conditions worsen. In the event of significant deterioration in 
economic conditions or if we experience significant loan growth, 
we may be required to build reserves in future periods, which 
would reduce our earnings. 

For more information, refer to the “Risk Management – 
Credit Risk Management” and “Critical Accounting Policies – 
Allowance for Credit Losses” sections in this Report. 

We may have more credit risk and higher credit losses 
to the extent our loans are concentrated by loan type, 
industry segment, borrower type, or location of the 
borrower or collateral.  Our credit risk and credit losses can 
increase if our loans are concentrated to borrowers engaged in 
the same or similar activities or to borrowers who individually or 
as a group may be uniquely or disproportionately affected by 
economic or market conditions. Similarly, challenging economic 
or market conditions, or trade policies, affecting a particular 
industry or geography may also impact related or dependent 
industries or the ability of borrowers living in such affected areas 
or working in such industries to meet their financial obligations. 
We experienced the effect of concentration risk in 2009 and 
2010 when we incurred greater than expected losses in our 
residential real estate loan portfolio due to a housing slowdown 
and greater than expected deterioration in residential real estate 
values in many markets, including the Central Valley California 
market and several Southern California metropolitan statistical 
areas. As California is our largest banking state in terms of loans 
and deposits, deterioration in real estate values and underlying 
economic conditions in those markets or elsewhere in California 
could result in materially higher credit losses. In addition, 
deterioration in macro-economic conditions generally across the 
country could result in materially higher credit losses, including 
for our residential real estate loan portfolio, which includes 
nonconforming mortgage loans we retain on our balance sheet. 
We may experience higher delinquencies and higher loss rates as 
our consumer real estate secured lines of credit reach their 
contractual end of draw period and begin to amortize or our 
consumer Pick-a-Pay loans reach their recast trigger. 

We are currently one of the largest CRE lenders in the U.S. 

A deterioration in economic conditions that negatively affects 
the business performance of our CRE borrowers, including 
increases in interest rates, declines in commercial property 
values, and/or changes in consumer behavior or other market 

conditions, could result in materially higher credit losses and 
have a material adverse effect on our financial results and 
condition. 

Challenges and/or changes in foreign economic conditions 
may increase our foreign credit risk. Our foreign loan exposure 
represented approximately 8% of our total consolidated 
outstanding loans and 4% of our total assets at December 31, 
2018. Economic difficulties in foreign jurisdictions could also 
indirectly have a material adverse effect on our credit 
performance and results of operations and financial condition to 
the extent they negatively affect the U.S. economy and/or our 
borrowers who have foreign operations. 

In order to reduce credit risk and obtain additional funding, 

from time to time we may securitize or sell similar types or 
categories of loans that we originate, such as mortgage loans and 
automobile loans. The agreements under which we do this 
generally contain various representations and warranties 
regarding the origination and characteristics of the loans. We 
may be required to repurchase the loans, reimburse investors 
and others, or incur other losses, including regulatory fines and 
penalties, as a result of any breaches in these contractual 
representations and warranties. For more information about our 
repurchase obligations with respect to mortgage loans, refer to 
the “Risk Factors – Risks Related to Our Mortgage Business” 
section in this Report. 

For more information regarding credit risk, refer to the 
“Risk Management – Credit Risk Management” section and Note 
6 (Loans and Allowance for Credit Losses) to Financial 
Statements in this Report. 

We may incur losses on loans, securities and other 
acquired assets of Wachovia that are materially greater 
than reflected in our fair value adjustments.  We 
accounted for the Wachovia merger under the purchase method 
of accounting, recording the acquired assets and liabilities of 
Wachovia at fair value. All PCI loans acquired in the merger were 
recorded at fair value based on the present value of their 
expected cash flows. We estimated cash flows using internal 
credit, interest rate and prepayment risk models using 
assumptions about matters that are inherently uncertain. We 
may not realize the estimated cash flows or fair value of these 
loans. In addition, although the difference between the pre­
merger carrying value of the credit-impaired loans and their 
expected cash flows – the “nonaccretable difference” – is 
available to absorb future charge-offs, we may be required to 
increase our allowance for credit losses and related provision 
expense because of subsequent additional credit deterioration in 
these loans. 

For more information, refer to the “Risk Management – 

Credit Risk Management” section in this Report. 

OPERATIONAL AND LEGAL RISK 

A failure in or breach of our operational or security 
systems, controls or infrastructure, or those of our 
third-party vendors and other service providers, could 
disrupt our businesses, damage our reputation, 
increase our costs and cause losses.  As a large financial 
institution that serves customers through numerous 
physical locations, ATMs, the internet, mobile banking and other 
distribution channels across the U.S. and internationally, we 
depend on our ability to process, record and monitor a large 
number of customer transactions on a continuous basis. As our 
customer base and locations have expanded throughout the U.S. 
and internationally, as we have increasingly used the internet 

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Risk Factors (continued) 

and mobile banking to provide products and services to our 
customers, and as customer, public, legislative and regulatory 
expectations regarding operational and information security 
have increased, our operational systems, controls and 
infrastructure must continue to be safeguarded and monitored 
for potential failures, disruptions and breakdowns. Our business, 
financial, accounting, data processing systems or other operating 
systems and facilities may stop operating properly, become 
insufficient based on our evolving business needs, or become 
disabled or damaged as a result of a number of factors including 
events that are wholly or partially beyond our control. For 
example, there could be sudden increases in customer 
transaction volume; electrical or telecommunications outages; 
degradation or loss of internet, website or mobile banking 
availability; climate change related impacts and natural disasters 
such as earthquakes, tornados, and hurricanes; disease 
pandemics; events arising from local or larger scale political or 
social matters, including terrorist acts; and, as described below, 
cyber attacks or other information security breaches. 
Furthermore, enhancements and upgrades to our infrastructure 
or operating systems may be time-consuming, entail significant 
costs, and create risks associated with implementing new 
systems and integrating them with existing ones. Due to the 
complexity and interconnectedness of our systems, the process 
of enhancing our infrastructure and operating systems, including 
their security measures and controls, can itself create a risk of 
system disruptions and security issues. Although we have 
business continuity plans and other safeguards in place, our 
business operations may be adversely affected by significant and 
widespread disruption to our physical infrastructure or 
operating systems that support our businesses and customers. 
For example, on February 7, 2019, we experienced system issues 
caused by an automatic power shutdown at one of our main data 
center facilities, which was triggered by a smoke alarm that 
resulted from a steam condition created by routine maintenance 
activities in the building. Although applications and related 
workloads were systematically re-routed to back-up data centers 
throughout the day, certain of our services experienced 
disruptions that delayed service to our customers. For instance, 
our online and mobile banking systems and certain ATM 
functions experienced disruptions for several hours, and certain 
critical mortgage origination systems experienced disruptions 
for several days. 

As a result of financial institutions and technology systems 

becoming more interconnected and complex, any operational 
incident at a third party may increase the risk of loss or material 
impact to us or the financial industry as a whole. Furthermore, 
third parties on which we rely, including those that facilitate our 
business activities or to which we outsource operations, such as 
exchanges, clearing houses, financial intermediaries or vendors 
that provide services or security solutions for our operations, 
could also be sources of operational risk to us, including from 
information breaches or loss, breakdowns, disruptions or 
failures of their own systems or infrastructure, or any 
deficiencies in the performance of their responsibilities. We are 
also exposed to the risk that a disruption or other operational 
incident at a common service provider to those third parties 
could impede their ability to provide services or perform their 
responsibilities for us. In addition, we must meet regulatory 
requirements and expectations regarding our use of third-party 
service providers, and any failure by our third-party service 
providers to meet their obligations to us or to comply with 
applicable laws, rules, regulations, or Wells Fargo policies could 
result in fines, penalties, restrictions on our business, or other 
negative consequences. 

Disruptions or failures in the physical infrastructure, 
controls or operating systems that support our businesses and 
customers, failures of the third parties on which we rely to 
adequately or appropriately provide their services or perform 
their responsibilities, or our failure to effectively manage or 
oversee our third-party relationships, could result in business 
disruptions, loss of revenue or customers, legal or regulatory 
proceedings, compliance and other costs, violations of applicable 
privacy and other laws, reputational damage, or other adverse 
consequences, any of which could materially adversely affect our 
results of operations or financial condition. 

A cyber attack or other information security breach of 
our technologies, computer systems or networks, or 
those of our third-party vendors and other service 
providers, could disrupt our businesses, result in the 
disclosure or misuse of confidential or proprietary 
information, damage our reputation, increase our costs 
and cause losses.  Information security risks for large 
financial institutions such as Wells Fargo have generally 
increased in recent years in part because of the proliferation of 
new technologies, the use of the internet, mobile devices, and 
cloud technologies to conduct financial transactions, and the 
increased sophistication and activities of organized crime, 
hackers, terrorists, activists, and other external parties, 
including foreign state-sponsored parties. Those parties also 
may attempt to misrepresent personal or financial information 
to obtain loans or other financial products from us or attempt to 
fraudulently induce employees, customers, or other users of our 
systems to disclose confidential information in order to gain 
access to our data or that of our customers. As noted above, our 
operations rely on the secure processing, transmission and 
storage of confidential information in our computer systems and 
networks. Our banking, brokerage, investment advisory, and 
capital markets businesses rely on our digital technologies, 
computer and email systems, software, hardware, and networks 
to conduct their operations. In addition, to access our products 
and services, our customers may use personal smartphones, 
tablets, and other mobile devices that are beyond our control 
systems. Although we believe we have robust information 
security procedures and controls, our technologies, systems, 
networks, and our customers’ devices may become the target of 
cyber attacks or other information security breaches that could 
result in the unauthorized release, gathering, monitoring, 
misuse, loss or destruction of Wells Fargo’s or our customers’ 
confidential, proprietary and other information, or otherwise 
disrupt Wells Fargo’s or its customers’ or other third parties’ 
business operations. For example, various retailers have 
reported they were victims of cyber attacks in which large 
amounts of their customers’ data, including debit and credit card 
information, was obtained. In these situations, we generally 
incur costs to replace compromised cards and address 
fraudulent transaction activity affecting our customers. We are 
also exposed to the risk that a team member or other person 
acting on behalf of the Company fails to comply with applicable 
policies and procedures and inappropriately circumvents 
controls for personal gain or other improper purposes. 

Due to the increasing interconnectedness and complexity of 

financial institutions and technology systems, an information 
security incident at a third party may increase the risk of loss or 
material impact to us or the financial industry as a whole. In 
addition, third parties on which we rely, including those that 
facilitate our business activities or to which we outsource 
operations, such as internet, mobile technology and cloud 
service providers, could be sources of information security risk 

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to us. If those third parties fail to adequately or appropriately 
safeguard their technologies, systems, and networks, we may 
suffer material harm, including business disruptions, losses or 
remediation costs, reputational damage, legal or regulatory 
proceedings, or other adverse consequences. 

To date we have not experienced any material losses relating 
to cyber attacks or other information security breaches, but there 
can be no assurance that we will not suffer such losses in the 
future. Our risk and exposure to these matters remains 
heightened because of, among other things, the evolving nature 
of these threats, the prominent size and scale of Wells Fargo and 
its role in the financial services industry, our plans to continue to 
implement our digital and mobile banking channel strategies 
and develop additional remote connectivity solutions to serve 
our customers when and how they want to be served, our 
expanded geographic footprint and international presence, the 
outsourcing of some of our business operations, and the current 
global economic and political environment. For example, 
Wells Fargo and other financial institutions continue to be the 
target of various evolving and adaptive cyber attacks, including 
malware and denial-of-service, as part of an effort to disrupt the 
operations of financial institutions, potentially test their 
cybersecurity capabilities, commit fraud, or obtain confidential, 
proprietary or other information. Cyber attacks have also 
focused on targeting online applications and services, such as 
online banking, as well as cloud-based services provided by third 
parties, and have targeted the infrastructure of the internet, 
causing the widespread unavailability of websites and degrading 
website performance. As a result, information security and the 
continued development and enhancement of our controls, 
processes and systems designed to protect our networks, 
computers, software and data from attack, damage or 
unauthorized access remain a priority for Wells Fargo. We are 
also proactively involved in industry cybersecurity efforts and 
working with other parties, including our third-party service 
providers and governmental agencies, to continue to enhance 
defenses and improve resiliency to cybersecurity and other 
information security threats. As these threats continue to evolve, 
we may be required to expend significant additional resources to 
continue to modify or enhance our protective measures or to 
investigate and remediate any information security 
vulnerabilities or incidents. Because the investigation of any 
information security breach is inherently unpredictable and 
would require time to complete, we may not be able to 
immediately address the consequences of a breach, which may 
further increase any associated costs and consequences. 
Moreover, to the extent our insurance covers aspects of 
information security risk, such insurance may not be sufficient to 
cover all losses associated with an information security breach. 
Cyber attacks or other information security breaches 

affecting us or third parties on which we rely, including those 
that facilitate our business activities or to which we outsource 
operations, or security breaches of the networks, systems or 
devices that our customers use to access our products and 
services, could result in business disruptions, loss of revenue or 
customers, legal or regulatory proceedings, compliance and 
other costs, violations of applicable privacy and other laws, 
reputational damage, or other adverse consequences, any of 
which could materially adversely affect our results of operations 
or financial condition. 

Our framework for managing risks may not be fully 
effective in mitigating risk and loss to us.  Our risk 
management framework seeks to mitigate risk and loss to us. We 
have established processes and procedures intended to identify, 

measure, monitor, report and analyze the types of risk to which 
we are subject, including liquidity risk, credit risk, market risk, 
interest rate risk, operational risk, legal and compliance risk, and 
reputational risk, among others. However, as with any risk 
management framework, there are inherent limitations to our 
risk management strategies as there may exist, or develop in the 
future, risks that we have not appropriately anticipated, 
identified or managed. Our risk management framework is also 
dependent on ensuring that effective operational controls and a 
sound culture exist throughout the Company. The inability to 
develop effective operational controls or to foster the 
appropriate culture in each of our lines of business, including the 
inability to align performance management and compensation to 
achieve the desired culture, could adversely impact the 
effectiveness of our risk management framework. Similarly, if we 
are unable to effectively manage our business or operations, we 
may be exposed to increased risks or unexpected losses. We are 
also exposed to risks if we do not accurately or completely 
execute a process or transaction, whether due to human error or 
otherwise. In certain instances, we rely on models to measure, 
monitor and predict risks, such as market and interest rate risks, 
as well as to help inform business decisions; however, there is no 
assurance that these models will appropriately or sufficiently 
capture all relevant risks or accurately predict future events or 
exposures. In addition, we rely on data to aggregate and assess 
our various risk exposures and business activities, and any issues 
with the quality or effectiveness of our data, including our 
aggregation, management, and validation procedures, could 
result in ineffective risk management practices, business 
decisions or customer service, inefficient use of resources, or 
inaccurate regulatory or other risk reporting. We also use 
artificial intelligence to help further inform our business 
decisions and risk management practices, but there is no 
assurance that artificial intelligence will appropriately or 
sufficiently replicate certain outcomes or accurately predict 
future events or exposures. The recent financial and credit crisis 
and resulting regulatory reform highlighted both the importance 
and some of the limitations of managing unanticipated risks, and 
our regulators remain focused on ensuring that financial 
institutions build and maintain robust risk management policies 
and practices. If our risk management framework proves 
ineffective, we could suffer unexpected losses which could 
materially adversely affect our results of operations or financial 
condition. 

Risks related to sales practices and other instances 
where customers may have experienced financial harm. 
Various government entities and offices have undertaken formal 
or informal inquiries, investigations or examinations arising out 
of certain sales practices of the Company that were the subject of 
settlements with the CFPB, the Office of the Comptroller of the 
Currency, and the Office of the Los Angeles City Attorney 
announced by the Company on September 8, 2016. In addition 
to imposing monetary penalties and other sanctions, regulatory 
authorities may require admissions of wrongdoing and 
compliance with other conditions in connection with such 
matters, which can lead to restrictions on our ability to engage in 
certain business activities or offer certain products or services, 
limitations on our ability to access capital markets, limitations 
on capital distributions, the loss of customers, and/or other 
direct and indirect adverse consequences. A number of lawsuits 
have also been filed by non-governmental parties seeking 
damages or other remedies related to these sales practices. The 
ultimate resolution of any of these pending legal proceedings or 
government investigations, depending on the sanctions and 

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Risk Factors (continued) 

remedy sought and granted, could materially adversely affect our 
results of operations and financial condition. We may also incur 
additional costs and expenses in order to address and defend 
these pending legal proceedings and government investigations, 
and we may have increased compliance and other costs related 
to these matters. Furthermore, negative publicity or public 
opinion resulting from these matters may increase the risk of 
reputational harm to our business, which can impact our ability 
to keep and attract customers, affect our ability to attract and 
retain qualified team members, result in the loss of revenue, or 
have other material adverse effects on our results of operations 
and financial condition. In addition, the ultimate results and 
conclusions of our company-wide review of sales practices issues 
are still pending and could lead to an increase in the identified 
number of potentially impacted customers, additional legal or 
regulatory proceedings, compliance and other costs, reputational 
damage, the identification of issues in our practices or 
methodologies that were used to identify, prevent or remediate 
sales practices related matters, the loss of additional team 
members, or further changes in policies and procedures that 
may impact our business. 

Furthermore, our priority of rebuilding trust has included 

an ongoing effort to identify other areas or instances where 
customers may have experienced financial harm. For example, 
we have identified certain issues related to historical practices 
concerning the origination, servicing, and/or collection of 
consumer automobile loans, including matters related to certain 
insurance products. The identification of such other areas or 
instances where customers may have experienced financial harm 
could lead to, and in some cases has already resulted in, 
additional remediation costs, loss of revenue or customers, legal 
or regulatory proceedings, compliance and other costs, 
reputational damage, or other adverse consequences. 

For more information, refer to the “Overview – Retail Sales 

Practices Matters” and “– Additional Efforts to Rebuild Trust” 
sections and Note 16 (Legal Actions) to Financial Statements in 
this Report. 

We may incur fines, penalties and other negative 
consequences from regulatory violations, possibly even 
inadvertent or unintentional violations, or from any 
failure to meet regulatory standards or expectations. 
We maintain systems and procedures designed to ensure that we 
comply with applicable laws and regulations. However, we are 
subject to heightened compliance and regulatory oversight and 
expectations, particularly due to the evolving and increasing 
regulatory landscape we operate in. We are also subject to 
consent orders with regulators that subject us to various 
conditions and restrictions. In addition, a single event or issue 
may give rise to numerous and overlapping investigations and 
proceedings, either by multiple federal and state agencies in the 
U.S. or by multiple regulators and other governmental entities in 
different jurisdictions. Also, the laws and regulations in 
jurisdictions in which we operate may be different or even 
conflict with each other, such as differences between U.S. federal 
and state law or differences between U.S. and foreign laws as to 
the products and services we may offer or other business 
activities we may engage in, which can lead to compliance 
difficulties or issues. Furthermore, many legal and regulatory 
regimes require us to report transactions and other information 
to regulators and other governmental authorities, self-regulatory 
organizations, exchanges, clearing houses and customers. We 
are also required to withhold funds and make various tax-related 
payments, relating to our own tax obligations and those of our 
customers. We may be subject to fines, penalties, restrictions on 

our business, or other negative consequences if we do not timely, 
completely, or accurately provide regulatory reports, customer 
notices or disclosures, or make tax-related withholdings or 
payments, on behalf of ourselves or our customers. Moreover, 
some legal/regulatory frameworks provide for the imposition of 
fines or penalties for noncompliance even though the 
noncompliance was inadvertent or unintentional and even 
though there was in place at the time systems and procedures 
designed to ensure compliance. For example, we are subject to 
regulations issued by the Office of Foreign Assets Control 
(OFAC) that prohibit financial institutions from participating in 
the transfer of property belonging to the governments of certain 
foreign countries and designated nationals of those countries. 
OFAC may impose penalties or restrictions on certain activities 
for inadvertent or unintentional violations even if reasonable 
processes are in place to prevent the violations. Any violation of 
these or other applicable laws or regulatory requirements, even if 
inadvertent or unintentional, or any failure to meet regulatory 
standards or expectations, including any failure to satisfy the 
conditions of any consent orders, could result in fees, penalties, 
restrictions on our ability to engage in certain business activities, 
reputational harm, loss of customers or other negative 
consequences. 

Negative publicity, including as a result of our actual or 
alleged conduct or public opinion of the financial 
services industry generally, could damage our 
reputation and business.  Reputation risk, or the risk to our 
business, earnings and capital from negative public opinion, is 
inherent in our business and has increased substantially because 
of the financial crisis, our size and profile in the financial 
services industry, and sales practices related matters and other 
instances where customers may have experienced financial 
harm. Negative public opinion about the financial services 
industry generally or Wells Fargo specifically could adversely 
affect our ability to keep and attract customers. Negative public 
opinion could result from our actual or alleged conduct in any 
number of activities, including sales practices; mortgage, 
automobile or other consumer lending practices; loan 
origination or servicing activities; mortgage foreclosure actions; 
management of client accounts or investments; lending, 
investing or other business relationships; identification and 
management of potential conflicts of interest from transactions, 
obligations and interests with and among our customers; 
corporate governance; regulatory compliance; risk management; 
incentive compensation practices; and disclosure, sharing or 
inadequate protection or improper use of customer information, 
and from actions taken by government regulators and 
community or other organizations in response to that conduct. 
Although we have policies and procedures in place intended to 
detect and prevent conduct by team members and third-party 
service providers that could potentially harm customers or our 
reputation, there is no assurance that such policies and 
procedures will be fully effective in preventing such conduct. 
Furthermore, our actual or perceived failure to address or 
prevent any such conduct or otherwise to effectively manage our 
business or operations could result in significant reputational 
harm. In addition, because we conduct most of our businesses 
under the “Wells Fargo” brand, negative public opinion about 
one business also could affect our other businesses. Moreover, 
actions by the financial services industry generally or by certain 
members or individuals in the industry also can adversely affect 
our reputation. The proliferation of social media websites 
utilized by Wells Fargo and other third parties, as well as the 
personal use of social media by our team members and others, 

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including personal blogs and social network profiles, also may 
increase the risk that negative, inappropriate or unauthorized 
information may be posted or released publicly that could harm 
our reputation or have other negative consequences, including as 
a result of our team members interacting with our customers in 
an unauthorized manner in various social media outlets. 

Wells Fargo and other financial institutions have been 
targeted from time to time by protests and demonstrations, 
which have included disrupting the operation of our retail 
banking locations and have resulted in negative public 
commentary about financial institutions, including the fees 
charged for various products and services. Wells Fargo and other 
financial institutions have also been subject to negative publicity 
as a result of providing financial services to or making 
investments in industries or organizations subject to stakeholder 
concerns. There can be no assurance that continued protests or 
negative publicity for the Company specifically or large financial 
institutions generally will not harm our reputation and adversely 
affect our business and financial results. 

Risks related to legal actions.  Wells Fargo and some of its 
subsidiaries are involved in judicial, regulatory, arbitration, and 
other proceedings or investigations concerning matters arising 
from the conduct of our business activities. Although we believe 
we have a meritorious defense in all significant legal actions 
pending against us, there can be no assurance as to the ultimate 
outcome. We establish accruals for legal actions when potential 
losses associated with the actions become probable and the costs 
can be reasonably estimated. We may still incur costs for a legal 
action even if we have not established an accrual. In addition, 
the actual cost of resolving a legal action may be substantially 
higher than any amounts accrued for that action. The ultimate 
resolution of a pending legal proceeding or investigation, 
depending on the remedy sought and granted, could materially 
adversely affect our results of operations and financial condition. 
As noted above, we are subject to heightened regulatory 

oversight and scrutiny, which may lead to regulatory 
investigations, proceedings or enforcement actions. In addition 
to imposing monetary penalties and other sanctions, regulatory 
authorities may require criminal pleas or other admissions of 
wrongdoing and compliance with other conditions in connection 
with settling such matters, which can lead to reputational harm, 
loss of customers, restrictions on the ability to access capital 
markets, limitations on capital distributions, the inability to 
engage in certain business activities or offer certain products or 
services, and/or other direct and indirect adverse effects. 

For more information, refer to Note 16 (Legal Actions) to 

Financial Statements in this Report. 

RISKS RELATED TO OUR MORTGAGE BUSINESS 

Our mortgage banking revenue can be volatile from 
quarter to quarter, including from the impact of 
changes in interest rates on our origination activity and 
on the value of our MSRs, MLHFS and associated 
economic hedges, and we rely on the GSEs to purchase 
our conforming loans to reduce our credit risk and 
provide liquidity to fund new mortgage loans.  We are 
one of the largest mortgage originators and residential mortgage 
servicers in the U.S., and we earn revenue from fees we receive 
for originating mortgage loans and for servicing mortgage loans. 
As a result of our mortgage servicing business, we have a sizable 
portfolio of MSRs. An MSR is the right to service a mortgage 
loan – collect principal, interest and escrow amounts – for a fee. 
We acquire MSRs when we retain the servicing rights after we 

sell or securitize the loans we have originated or when we 
purchase the servicing rights to mortgage loans originated by 
other lenders. We initially measure and carry all our residential 
MSRs using the fair value measurement method. Fair value is 
the present value of estimated future net servicing income, 
calculated based on a number of variables, including 
assumptions about the likelihood of prepayment by borrowers. 
Changes in interest rates can affect prepayment assumptions 
and thus fair value. When interest rates fall, borrowers are 
usually more likely to prepay their mortgage loans by refinancing 
them at a lower rate. As the likelihood of prepayment increases, 
the fair value of our MSRs can decrease. Each quarter we 
evaluate the fair value of our MSRs, and any decrease in fair 
value reduces earnings in the period in which the decrease 
occurs. We also measure at fair value MLHFS for which an active 
secondary market and readily available market prices exist. In 
addition, we measure at fair value certain other interests we hold 
related to residential loan sales and securitizations. Similar to 
other interest-bearing securities, the value of these MLHFS and 
other interests may be negatively affected by changes in interest 
rates. For example, if market interest rates increase relative to 
the yield on these MLHFS and other interests, their fair value 
may fall. 

When rates rise, the demand for mortgage loans usually 

tends to fall, reducing the revenue we receive from loan 
originations. Under the same conditions, revenue from our 
MSRs can increase through increases in fair value. When rates 
fall, mortgage originations usually tend to increase and the value 
of our MSRs usually tends to decline, also with some offsetting 
revenue effect. Even though they can act as a “natural hedge,” 
the hedge is not perfect, either in amount or timing. For 
example, the negative effect on revenue from a decrease in the 
fair value of residential MSRs is generally immediate, but any 
offsetting revenue benefit from more originations and the MSRs 
relating to the new loans would generally accrue over time. It is 
also possible that, because of economic conditions and/or a weak 
or deteriorating housing market, even if interest rates were to 
fall or remain low, mortgage originations may also fall or any 
increase in mortgage originations may not be enough to offset 
the decrease in the MSRs value caused by the lower rates. 

We typically use derivatives and other instruments to hedge 
our mortgage banking interest rate risk. We may not hedge all of 
our risk, and we may not be successful in hedging any of the risk. 
Hedging is a complex process, requiring sophisticated models 
and constant monitoring, and is not a perfect science. We may 
use hedging instruments tied to U.S. Treasury rates, LIBOR or 
Eurodollars that may not perfectly correlate with the value or 
income being hedged. We could incur significant losses from our 
hedging activities. There may be periods where we elect not to 
use derivatives and other instruments to hedge mortgage 
banking interest rate risk. 

We rely on GSEs to purchase mortgage loans that meet their 

conforming loan requirements and on the Federal Housing 
Authority (FHA) to insure loans that meet their policy 
requirements. These loans are then securitized into either GSE 
or GNMA securities that are sold to investors. In order to meet 
customer needs, we also originate loans that do not conform to 
either GSE or FHA standards, which are referred to as 
“nonconforming” loans. We generally retain these 
nonconforming loans on our balance sheet. When we retain a 
loan on our balance sheet not only do we forgo fee revenue and 
keep the credit risk of the loan but we also do not receive any 
sale proceeds that could be used to generate new loans. If we 
were unable or unwilling to continue retaining nonconforming 
loans on our balance sheet, whether due to regulatory, business 

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Risk Factors (continued) 

or other reasons, our ability to originate new nonconforming 
loans may be reduced, thereby reducing the interest income we 
earn from originating these loans. Similarly, if the GSEs or the 
FHA were to limit or reduce their purchases or insuring of loans, 
our ability to fund, and thus originate new mortgage loans, could 
also be reduced. We cannot assure that the GSEs or the FHA will 
not materially limit their purchases or insuring of conforming 
loans or change their criteria for what constitutes a conforming 
loan (e.g., maximum loan amount or borrower eligibility). Each 
of the GSEs is currently in conservatorship, with its primary 
regulator, the Federal Housing Finance Agency acting as 
conservator. We cannot predict if, when or how the 
conservatorship will end, or any associated changes to the GSEs 
business structure and operations that could result. As noted 
above, there are various proposals to reform the housing finance 
market in the U.S., including the role of the GSEs in the housing 
finance market. The impact of any such regulatory reform 
regarding the housing finance market and the GSEs, including 
whether the GSEs will continue to exist in their current form, as 
well as any effect on the Company’s business and financial 
results, are uncertain. 

For more information, refer to the “Risk Management – 
Asset/Liability Management – Mortgage Banking Interest Rate 
and Market Risk” and “Critical Accounting Policies” sections in 
this Report. 

We may be required to repurchase mortgage loans or 
reimburse investors and others as a result of breaches 
in contractual representations and warranties, and we 
may incur other losses as a result of real or alleged 
violations of statutes or regulations applicable to the 
origination of our residential mortgage loans.  The 
origination of residential mortgage loans is governed by a variety 
of federal and state laws and regulations, including the Truth in 
Lending Act of 1968 and various anti-fraud and consumer 
protection statutes, which are complex and frequently changing. 
We often sell residential mortgage loans that we originate to 
various parties, including GSEs, SPEs that issue private label 
MBS, and other financial institutions that purchase mortgage 
loans for investment or private label securitization. We may also 
pool FHA-insured and VA-guaranteed mortgage loans which 
back securities guaranteed by GNMA. The agreements under 
which we sell mortgage loans and the insurance or guaranty 
agreements with the FHA and VA contain various 
representations and warranties regarding the origination and 
characteristics of the mortgage loans. We may be required to 
repurchase mortgage loans, indemnify the securitization trust, 
investor or insurer, or reimburse the securitization trust, 
investor or insurer for credit losses incurred on loans in the 
event of a breach of contractual representations or warranties 
that is not remedied within a period (usually 90 days or less) 
after we receive notice of the breach. We establish a mortgage 
repurchase liability related to the various representations and 
warranties that reflect management’s estimate of losses for loans 
which we have a repurchase obligation. Because the level of 
mortgage loan repurchase losses depends upon economic 
factors, investor demand strategies and other external 
conditions that may change over the life of the underlying loans, 
the level of the liability for mortgage loan repurchase losses is 
difficult to estimate, requires considerable management 
judgment, and is subject to change. If economic conditions or 
the housing market worsen or future investor repurchase 
demand and our success at appealing repurchase requests differ 
from past experience, we could have increased repurchase 

obligations and increased loss severity on repurchases, requiring 
significant additions to the repurchase liability. 

Additionally, for residential mortgage loans that we 

originate, borrowers may allege that the origination of the loans 
did not comply with applicable laws or regulations in one or 
more respects and assert such violation as an affirmative defense 
to payment or to the exercise by us of our remedies, including 
foreclosure proceedings, or in an action seeking statutory and 
other damages in connection with such violation. If we are not 
successful in demonstrating that the loans in dispute were 
originated in accordance with applicable statutes and 
regulations, we could become subject to monetary damages and 
other civil penalties, including the loss of certain contractual 
payments or the inability to exercise certain remedies under the 
loans. 

For more information, refer to the “Risk Management – 

Credit Risk Management – Liability for Mortgage Loan 
Repurchase Losses” section in this Report. 

We may be terminated as a servicer or master servicer, 
be required to repurchase a mortgage loan or 
reimburse investors for credit losses on a mortgage 
loan, or incur costs, liabilities, fines and other 
sanctions if we fail to satisfy our servicing obligations, 
including our obligations with respect to mortgage loan 
foreclosure actions.  We act as servicer and/or master 
servicer for mortgage loans included in securitizations and for 
unsecuritized mortgage loans owned by investors. As a servicer 
or master servicer for those loans we have certain contractual 
obligations to the securitization trusts, investors or other third 
parties, including, in our capacity as a servicer, foreclosing on 
defaulted mortgage loans or, to the extent consistent with the 
applicable securitization or other investor agreement, 
considering alternatives to foreclosure such as loan 
modifications or short sales and, in our capacity as a master 
servicer, overseeing the servicing of mortgage loans by the 
servicer. In addition, we may have certain servicing obligations 
for properties that fall within a flood zone. If we commit a 
material breach of our obligations as servicer or master servicer, 
we may be subject to termination if the breach is not cured 
within a specified period of time following notice, which can 
generally be given by the securitization trustee or a specified 
percentage of security holders, causing us to lose servicing 
income. In addition, we may be required to indemnify the 
securitization trustee against losses from any failure by us, as a 
servicer or master servicer, to perform our servicing obligations 
or any act or omission on our part that involves willful 
misfeasance, bad faith or gross negligence. Furthermore, if any 
of the companies that insure the mortgage loans in our servicing 
portfolio experience financial difficulties or credit downgrades, 
we may incur additional costs to obtain replacement insurance 
coverage with another provider, possibly at a higher cost than 
the coverage we would replace. In some cases, if we do not 
satisfy our servicing obligations, we may be contractually 
obligated to repurchase a mortgage loan or reimburse the 
investor for credit losses, which could significantly reduce our 
net servicing income. 

We may incur costs, liabilities to borrowers, title insurers 

and/or securitization investors, legal proceedings, or other 
adverse consequences if we fail to meet our obligations with 
respect to mortgage foreclosure actions or we experience delays 
in the foreclosure process. The fair value of our MSRs may be 
negatively affected to the extent our servicing costs increase 
because of higher foreclosure or other servicing related costs. We 
may be subject to fines and other sanctions imposed by federal 

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or state regulators as a result of actual or perceived deficiencies 
in our mortgage servicing practices, including with respect to our 
foreclosure practices or our servicing of flood zone properties. 
Any of these actions may harm our reputation, negatively affect 
our residential mortgage origination or servicing business, or 
result in material fines, penalties, equitable remedies, or other 
enforcement actions. 

For more information, refer to the “Risk Management – 

Credit Risk Management – Liability for Mortgage Loan 
Repurchase Losses” and “– Risks Relating to Servicing 
Activities,” and “Critical Accounting Policies – Valuation of 
Residential Mortgage Servicing Rights” sections and Note 15 
(Guarantees, Pledged Assets and Collateral, and Other 
Commitments) and Note 16 (Legal Actions) to Financial 
Statements in this Report. 

RISKS RELATED TO OUR INDUSTRY’S COMPETITIVE 
OPERATING ENVIRONMENT 

We face significant and increasing competition in the 
rapidly evolving financial services industry.  We compete 
with other financial institutions in a highly competitive industry 
that is undergoing significant changes as a result of financial 
regulatory reform, technological advances, increased public 
scrutiny stemming from the financial crisis, and current 
economic conditions. Our success depends on our ability to 
develop and maintain deep and enduring relationships with our 
customers based on the quality of our customer service, the wide 
variety of products and services that we can offer our customers 
and the ability of those products and services to satisfy our 
customers’ needs, the pricing of our products and services, the 
extensive distribution channels available for our customers, our 
innovation, and our reputation. Continued or increased 
competition in any one or all of these areas may negatively affect 
our customer relationships, market share and results of 
operations and/or cause us to increase our capital investment in 
our businesses in order to remain competitive. In addition, our 
ability to reposition or reprice our products and services from 
time to time may be limited and could be influenced significantly 
by the current economic, regulatory and political environment 
for large financial institutions as well as by the actions of our 
competitors. Furthermore, any changes in the types of products 
and services that we offer our customers and/or the pricing for 
those products and services could result in a loss of customer 
relationships and market share and could materially adversely 
affect our results of operations. 

Continued technological advances and the growth of 

e-commerce have made it possible for non-depository 
institutions to offer products and services that traditionally were 
banking products, and for financial institutions and other 
companies to provide electronic and internet-based financial 
solutions, including electronic securities trading, lending and 
payment solutions. In addition, technological advances, 
including digital currencies, may diminish the importance of 
depository institutions and other financial intermediaries in the 
transfer of funds between parties. We may not respond 
effectively to these and other competitive threats from existing 
and new competitors and may be forced to sell products at lower 
prices, increase our investment in our business to modify or 
adapt our existing products and services, and/or develop new 
products and services to respond to our customers’ needs. To the 
extent we are not successful in developing and introducing new 
products and services or responding or adapting to the 
competitive landscape or to changes in customer preferences, we 

may lose customer relationships and our revenue growth and 
results of operations may be materially adversely affected. 

Our ability to attract and retain qualified team 
members is critical to the success of our business and 
failure to do so could adversely affect our business 
performance, competitive position and future 
prospects.  The success of Wells Fargo is heavily dependent on 
the talents and efforts of our team members, including our 
senior leaders, and in many areas of our business, including 
commercial banking, brokerage, investment advisory, capital 
markets, risk management and technology, the competition for 
highly qualified personnel is intense. We also seek to retain a 
pipeline of team members to provide continuity of succession for 
our senior leadership positions. In order to attract and retain 
highly qualified team members, we must provide competitive 
compensation and effectively manage team member 
performance and development. As a large financial institution 
and additionally to the extent we remain subject to consent 
orders we may be subject to limitations on compensation by our 
regulators that may adversely affect our ability to attract and 
retain these qualified team members, especially if some of our 
competitors may not be subject to these same compensation 
limitations. If we are unable to continue to attract and retain 
qualified team members, including successors for senior 
leadership positions, our business performance, competitive 
position and future prospects may be adversely affected. 

RISKS RELATED TO OUR FINANCIAL STATEMENTS 

Changes in accounting policies or accounting 
standards, and changes in how accounting standards 
are interpreted or applied, could materially affect how 
we report our financial results and condition.  Our 
accounting policies are fundamental to determining and 
understanding our financial results and condition. As described 
below, some of these policies require use of estimates and 
assumptions that may affect the value of our assets or liabilities 
and financial results. Any changes in our accounting policies 
could materially affect our financial statements. 

From time to time the FASB and the SEC change the 
financial accounting and reporting standards that govern the 
preparation of our external financial statements. For example, 
Accounting Standards Update 2016-13 - Financial Instruments-
Credit Losses (Topic 326), which becomes effective in first 
quarter 2020, will replace the current “incurred loss” model for 
the allowance for credit losses with an “expected loss” model 
referred to as the Current Expected Credit Loss model, or CECL. 
CECL could materially affect how we determine our allowance 
and report our financial results and condition. 

In addition, accounting standard setters and those who 
interpret the accounting standards (such as the FASB, SEC, 
banking regulators and our outside auditors) may change or 
even reverse their previous interpretations or positions on how 
these standards should be applied. Changes in financial 
accounting and reporting standards and changes in current 
interpretations may be beyond our control, can be hard to 
predict and could materially affect how we report our financial 
results and condition. We may be required to apply a new or 
revised standard retroactively or apply an existing standard 
differently, also retroactively, in each case potentially resulting 
in our restating prior period financial statements in material 
amounts. 

For more information, refer to the “Current Accounting 

Developments” section in this Report. 

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Risk Factors (continued) 

Our financial statements are based in part on 
assumptions and estimates which, if wrong, could 
cause unexpected losses in the future, and our financial 
statements depend on our internal controls over 
financial reporting.  Pursuant to U.S. GAAP, we are required 
to use certain assumptions and estimates in preparing our 
financial statements, including in determining credit loss 
reserves, reserves for mortgage repurchases, reserves related to 
litigation and the fair value of certain assets and liabilities, 
among other items. Several of our accounting policies are critical 
because they require management to make difficult, subjective 
and complex judgments about matters that are inherently 
uncertain and because it is likely that materially different 
amounts would be reported under different conditions or using 
different assumptions. For a description of these policies, refer 
to the “Critical Accounting Policies” section in this Report. If 
assumptions or estimates underlying our financial statements 
are incorrect, we may experience material losses. 

and face intense competition for customers, sources of revenue, 
capital, services, qualified team members, and other essential 
business resources. In order to meet these challenges, we may 
undertake business plans or strategies related to, among other 
things, our organizational structure and risk management 
framework, our expenses and efficiency, the types of products 
and services we offer, the geographies in which we operate, the 
manner in which we serve our clients and customers, the third 
parties with which we do business, and the methods and 
distribution channels by which we offer our products and 
services. Accomplishing these business plans or strategies may 
be complex, time intensive, and require significant financial, 
technological, management and other resources, and there is no 
guarantee that any business plans or strategies will ultimately be 
successful. To the extent we are unable to develop or execute 
effective business plans or strategies, our competitive position, 
reputation, prospects for growth, and results of operations may 
be adversely affected. 

Certain of our financial instruments, including derivative 

In addition, we regularly explore opportunities to expand 

assets and liabilities, debt securities, certain loans, MSRs, 
private equity investments, structured notes and certain 
repurchase and resale agreements, among other items, require a 
determination of their fair value in order to prepare our financial 
statements. Where quoted market prices are not available, we 
may make fair value determinations based on internally 
developed models or other means which ultimately rely to some 
degree on management judgment, and there is no assurance that 
our models will capture or appropriately reflect all relevant 
inputs required to accurately determine fair value. Some of these 
and other assets and liabilities may have no direct observable 
price levels, making their valuation particularly subjective, being 
based on significant estimation and judgment. In addition, 
sudden illiquidity in markets or declines in prices of certain 
loans and securities may make it more difficult to value certain 
balance sheet items, which may lead to the possibility that such 
valuations will be subject to further change or adjustment and 
could lead to declines in our earnings. 

The Sarbanes-Oxley Act of 2002 (Sarbanes-Oxley) requires 
our management to evaluate the Company’s disclosure controls 
and procedures and its internal control over financial reporting 
and requires our auditors to issue a report on our internal 
control over financial reporting. We are required to disclose, in 
our annual report on Form 10-K, the existence of any “material 
weaknesses” in our internal controls. We cannot assure that we 
will not identify one or more material weaknesses as of the end 
of any given quarter or year, nor can we predict the effect on our 
stock price of disclosure of a material weakness. In addition, our 
customers may rely on the effectiveness of our internal controls 
as a service provider, and any deficiency in those controls could 
affect our customers and damage our reputation or business. 
Sarbanes-Oxley also limits the types of non-audit services our 
outside auditors may provide to us in order to preserve their 
independence from us. If our auditors were found not to be 
“independent” of us under SEC rules, we could be required to 
engage new auditors and re-file financial statements and audit 
reports with the SEC. We could be out of compliance with SEC 
rules until new financial statements and audit reports were filed, 
limiting our ability to raise capital and resulting in other adverse 
consequences. 

RISKS RELATED TO STRATEGIC DECISIONS 
If we are unable to develop and execute effective 
business plans or strategies, our competitive standing 
and results of operations could suffer.  We are subject to 
rapid changes in technology, regulation, and product innovation, 

our products, services, and assets through strategic acquisitions 
of companies or businesses in the financial services industry. We 
generally must receive federal regulatory approvals before we 
can acquire a bank, bank holding company, or certain other 
financial services businesses. We cannot be certain when or if, or 
on what terms and conditions, any required regulatory approvals 
will be granted. We might be required to sell banks, branches 
and/or business units or assets or issue additional equity as a 
condition to receiving regulatory approval for an acquisition. 
When we do announce an acquisition, our stock price may fall 
depending on the size of the acquisition, the type of business to 
be acquired, the purchase price, and the potential dilution to 
existing stockholders or our earnings per share if we issue 
common stock in connection with the acquisition. Furthermore, 
difficulty in integrating an acquired company or business may 
cause us not to realize expected revenue increases, cost savings, 
increases in geographic or product presence, and other projected 
benefits from the acquisition. The integration could result in 
higher than expected deposit attrition, loss of key team 
members, an increase in our compliance costs or risk profile, 
disruption of our business or the acquired business, or otherwise 
harm our ability to retain customers and team members or 
achieve the anticipated benefits of the acquisition. Time and 
resources spent on integration may also impair our ability to 
grow our existing businesses. Many of the foregoing risks may be 
increased if the acquired company or business operates 
internationally or in a geographic location where we do not 
already have significant business operations and/or team 
members. 

*  *  * 

Any factor described in this Report or in any of our other SEC 

filings could by itself, or together with other factors, adversely 
affect our financial results and condition. Refer to our quarterly 
reports on Form 10-Q filed with the SEC in 2019 for material 
changes to the above discussion of risk factors. There are factors 
not discussed above or elsewhere in this Report that could 
adversely affect our financial results and condition. 

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Controls and Procedures 

Disclosure Controls and Procedures 

The Company’s management evaluated the effectiveness, as of December 31, 2018, of the Company’s disclosure controls and 
procedures. The Company’s chief executive officer and chief financial officer participated in the evaluation. Based on this evaluation, the 
Company’s chief executive officer and chief financial officer concluded that the Company’s disclosure controls and procedures were 
effective as of December 31, 2018. 

Internal Control Over Financial Reporting 

Internal control over financial reporting is defined in Rule 13a-15(f) promulgated under the Securities Exchange Act of 1934 as a process 
designed by, or under the supervision of, the Company’s principal executive and principal financial officers and effected by the 
Company’s Board, management and other personnel, to provide reasonable assurance regarding the reliability of financial reporting 
and the preparation of financial statements for external purposes in accordance with U.S. generally accepted accounting principles 
(GAAP) and includes those policies and procedures that: 
• 	 pertain to the maintenance of records that in reasonable detail accurately and fairly reflect the transactions and dispositions of 

assets of the Company; 

• 	 provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in 

accordance with GAAP, and that receipts and expenditures of the Company are being made only in accordance with authorizations 
of management and directors of the Company; and 

• 	 provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the 

Company’s assets that could have a material effect on the financial statements. 

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Projections of 

any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in 
conditions, or that the degree of compliance with the policies or procedures may deteriorate. No change occurred during any quarter in 
2018 that has materially affected, or is reasonably likely to materially affect, the Company’s internal control over financial reporting. 
Management’s report on internal control over financial reporting is set forth below and should be read with these limitations in mind. 

Management’s Report on Internal Control over Financial Reporting 
The Company’s management is responsible for establishing and maintaining adequate internal control over financial reporting for the 
Company. Management assessed the effectiveness of the Company’s internal control over financial reporting as of December 31, 2018, 
using the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) in Internal Control – 
Integrated Framework (2013). Based on this assessment, management concluded that as of December 31, 2018, the Company’s 
internal control over financial reporting was effective. 

KPMG LLP, the independent registered public accounting firm that audited the Company’s financial statements included in this 
Annual Report, issued an audit report on the Company’s internal control over financial reporting. KPMG’s audit report appears on the 
following page. 

137

Wells Fargo & Company 

137 

 
 
 
Report of Independent Registered Public Accounting Firm 

The Stockholders and Board of Directors 
Wells Fargo & Company: 

Opinion on Internal Control Over Financial Reporting 

We have audited Wells Fargo & Company and Subsidiaries’ (the Company) internal control over financial reporting as of December 31, 
2018, based on criteria established in Internal Control – Integrated Framework (2013) issued by the Committee of Sponsoring 
Organizations of the Treadway Commission. In our opinion, the Company maintained, in all material respects, effective internal control 
over financial reporting as of December 31, 2018, based on criteria established in Internal Control – Integrated Framework (2013) 
issued by the Committee of Sponsoring Organizations of the Treadway Commission. 

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), 
the consolidated balance sheets of the Company as of December 31, 2018 and 2017, the related consolidated statements of income, 
comprehensive income, changes in equity, and cash flows for each of the years in the three-year period ended December 31, 2018, and 
the related notes (collectively, the consolidated financial statements), and our report dated February 27, 2019 expressed an unqualified 
opinion on those consolidated financial statements. 

Basis for Opinion 

The Company’s management is responsible for maintaining effective internal control over financial reporting and for its assessment of 
the effectiveness of internal control over financial reporting, included in the accompanying Management’s Report on Internal Control 
over Financial Reporting. Our responsibility is to express an opinion on the Company’s internal control over financial reporting based 
on our audit. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the 
Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange 
Commission and the PCAOB. 

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to 
obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all material respects. 
Our audit of internal control over financial reporting included obtaining an understanding of internal control over financial reporting, 
assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control 
based on the assessed risk. Our audit also included performing such other procedures as we considered necessary in the circumstances. 
We believe that our audit provides a reasonable basis for our opinion. 

Definition and Limitations of Internal Control Over Financial Reporting 

A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of 
financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting 
principles. A company’s internal control over financial reporting includes those policies and procedures that (1) pertain to the 
maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the 
company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in 
accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in 
accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding 
prevention or timely detection of unauthorized acquisition, use, or disposition of the company’s assets that could have a material effect 
on the financial statements. 

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections 
of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in 
conditions, or that the degree of compliance with the policies or procedures may deteriorate 

San Francisco, California 
February 27, 2019 

138 

Wells Fargo & Company 

138

 
 
Financial Statements 

Wells Fargo & Company and Subsidiaries 

Consolidated Statement of Income 

(in millions, except per share amounts) 

Interest income 

Debt securities (1) 

Mortgage loans held for sale 

Loans held for sale (1) 

Loans 

Equity securities (1) 

Other interest income (1) 

Total interest income 

Interest expense 

Deposits 

Short-term borrowings 

Long-term debt 

Other interest expense 

Total interest expense 

Net interest income 

Provision for credit losses 

Net interest income after provision for credit losses 

Noninterest income 

Service charges on deposit accounts 

Trust and investment fees 

Card fees 

Other fees 

Mortgage banking 

Insurance 

Net gains from trading activities (1) 

Net gains on debt securities (2) 

Net gains from equity securities (1)(3) 

Lease income 

Other 

Total noninterest income 

Noninterest expense 

Salaries 

Commission and incentive compensation 

Employee benefits 

Equipment 

Net occupancy 

Core deposit and other intangibles 

FDIC and other deposit assessments 

Other 

Total noninterest expense 

Income before income tax expense 

Income tax expense 

Net income before noncontrolling interests 

Less: Net income from noncontrolling interests 

Wells Fargo net income 

Less: Preferred stock dividends and other 

Wells Fargo net income applicable to common stock 

Per share information 

Earnings per common share 

Diluted earnings per common share 

Average common shares outstanding 

Diluted average common shares outstanding 

Year ended December 31, 

2018 

2017 

2016 

$ 

14,406 

12,946 

11,244 

777 

140 

786 

50 

784 

38 

43,974 

41,388 

39,505 

992 

4,358 

799 

2,940 

635 

1,457 

64,647 

58,909 

53,663 

5,622 

1,717 

6,703 

610 

14,652 

49,995 

1,744 

48,251 

4,716 

14,509 

3,907 

3,384 

3,017 

429 

602 

108 

1,515 

1,753 

2,473 

3,013 

758 

5,157 

424 

9,352 

49,557 

2,528 

47,029 

1,395 

330 

3,830 

354 

5,909 

47,754 

3,770 

43,984 

5,111 

14,495 

5,372 

14,243 

3,960 

3,557 

4,350 

1,049 

542 

479 

1,779 

1,907 

1,603 

3,936 

3,727 

6,096 

1,268 

610 

942 

1,103 

1,927 

1,289 

36,413 

38,832 

40,513 

17,834 

10,264 

4,926 

2,444 

2,888 

1,058 

1,110 

15,602 

56,126 

28,538 

5,662 

22,876 

483 

$ 

22,393 

1,704 

$ 

20,689 

$

 4.31

4.28 

4,799.7 

4,838.4 

17,363 

10,442 

5,566 

2,237 

2,849 

1,152 

1,287 

17,588 

58,484 

27,377 

4,917 

22,460 

277 

22,183 

1,629 

20,554 

16,552 

10,247 

5,094 

2,154 

2,855 

1,192 

1,168 

13,115 

52,377 

32,120 

10,075 

22,045 

107 

21,938 

1,565 

20,373 

  4.14 

4.10 

4,964.6 

5,017.3 

4.03 

3.99 

5,052.8 

5,108.3 

(1) 	 Financial information for the prior periods has been revised to reflect presentation changes made in connection with our adoption in first quarter 2018 of Accounting 

Standards Update (ASU) 2016-01 – Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities. See 
Note 1 (Summary of Significant Accounting Policies) for more information. 

(2) 	 Total other-than-temporary impairment (OTTI) losses were $17 million, $205 million and $207 million for the years ended December 31, 2018, 2017 and 2016, 

respectively. Of total OTTI, losses of $28 million, $262 million and $189 million were recognized in earnings, and losses (reversal of losses) of $(11) million, $(57) million 
and $18 million were recognized as non-credit-related OTTI in other comprehensive income for the years ended December 31, 2018, 2017 and 2016, respectively. 

(3) 	 Includes OTTI losses of $352 million, $344 million and $453 million for the years ended December 31, 2018, 2017 and 2016, respectively. 

The accompanying notes are an integral part of these statements. 

139

Wells Fargo & Company 

139 

 
Wells Fargo & Company and Subsidiaries 

Consolidated Statement of Comprehensive Income 

(in millions) 

Wells Fargo net income 

Other comprehensive income (loss), before tax: 

Debt securities (1): 

Net unrealized gains (losses) arising during the period 

Reclassification of net (gains) losses to net income 

Derivatives and hedging activities: 

Net unrealized gains (losses) arising during the period 

Reclassification of net (gains) losses on cash flow hedges to net income 

Defined benefit plans adjustments: 

Net actuarial and prior service gains (losses) arising during the period 

Amortization of net actuarial loss, settlements and other to net income 

Foreign currency translation adjustments: 

Net unrealized gains (losses) arising during the period 

Other comprehensive income (loss), before tax 

Income tax benefit (expense) related to other comprehensive income 

Other comprehensive income (loss), net of tax 

Less: Other comprehensive loss from noncontrolling interests 

Wells Fargo other comprehensive income (loss), net of tax 

Wells Fargo comprehensive income 

Comprehensive income from noncontrolling interests 

Total comprehensive income 

Year ended December 31, 

2018 

2017 

2016 

$ 

22,393 

22,183 

21,938 

(4,493) 

248 

2,719 

(737) 

(532) 

294 

(434) 

253 

(156) 

(4,820) 

1,144 

(3,676) 

(2) 

(3,674) 

(540) 

(543) 

49 

153 

96 

1,197 

(434) 

763 

(62) 

825 

(3,458) 

(1,240) 

177 

(1,029) 

(52) 

158 

(3) 

(5,447) 

1,996 

(3,451) 

(17) 

(3,434) 

18,719 

23,008 

18,504 

481 

215 

90 

$ 

19,200 

23,223 

18,594 

(1) 	 The year ended December 31, 2017, and December 31, 2016, includes net unrealized gains (losses) arising during the period from equity securities of $81 million and 

$259 million and reclassification of net (gains) losses to net income related to equity securities of $(456) million and $(300) million, respectively. In connection with our 
adoption in first quarter 2018 of ASU 2016-01, the year ended December 31, 2018, reflects net unrealized gains (losses) arising during the period and reclassification of 
net (gains) losses to net income from only debt securities. 

The accompanying notes are an integral part of these statements. 

140 

Wells Fargo & Company 

140

Wells Fargo & Company and Subsidiaries 

Consolidated Balance Sheet 

(in millions, except shares) 

Assets 

Cash and due from banks 

Interest-earning deposits with banks (1) 

Total cash, cash equivalents, and restricted cash (1) 

Federal funds sold and securities purchased under resale agreements (1) 

Debt securities: 

Trading, at fair value (2) 

Available-for-sale, at fair value (2) 

Held-to-maturity, at cost (fair value $142,115 and $138,985) 

Mortgage loans held for sale (includes $11,771 and $16,116 carried at fair value) (3) 

Loans held for sale (includes $1,469 and $1,023 carried at fair value) (2)(3) 

Loans (includes $244 and $376 carried at fair value) (3) 

Allowance for loan losses 

Net loans 

Mortgage servicing rights: 

Measured at fair value 

Amortized 

Premises and equipment, net 

Goodwill 

Derivative assets 

Equity securities (includes $29,556 and $39,227 carried at fair value) (2)(3) 

Other assets (2) 

Total assets (4) 

Liabilities 

Noninterest-bearing deposits 

Interest-bearing deposits 

Total deposits 

Short-term borrowings 

Derivative liabilities 

Accrued expenses and other liabilities 

Long-term debt 

Total liabilities (5) 

Equity 

Wells Fargo stockholders’ equity: 

Preferred stock 

Common stock – $1-2/3 par value, authorized 9,000,000,000 shares; issued 5,481,811,474 shares 

Additional paid-in capital 

Retained earnings 

Cumulative other comprehensive income (loss) 

Treasury stock – 900,557,866 shares and 590,194,846 shares 

Unearned ESOP shares 

Total Wells Fargo stockholders’ equity 

Noncontrolling interests 

Total equity 

Total liabilities and equity 

Dec 31, 

2018 

$ 

23,551 

149,736 

173,287 

80,207 

69,989 

269,912 

144,788 

15,126 

2,041 

953,110 

(9,775) 

943,335 

14,649 

1,443 

8,920 

26,418 

10,770 

55,148 

79,850 

Dec 31, 

2017 

23,367 

192,580 

215,947 

80,025 

57,624 

276,407 

139,335 

20,070 

1,131 

956,770 

(11,004) 

945,766 

13,625 

1,424 

8,847 

26,587 

12,228 

62,497 

90,244 

$ 

1,895,883 

1,951,757 

$ 

349,534 

936,636 

373,722 

962,269 

1,286,170 

1,335,991 

105,787 

8,499 

69,317 

229,044 

103,256 

8,796 

70,615 

225,020 

1,698,817 

1,743,678 

23,214 

9,136 

60,685 

158,163 

(6,336) 

(47,194) 

(1,502) 

196,166 

900 

197,066 

25,358 

9,136 

60,893 

145,263 

(2,144) 

(29,892) 

(1,678) 

206,936 

1,143 

208,079 

$ 

1,895,883 

1,951,757 

(1) 	 Financial information has been revised to reflect the impact of our adoption in first quarter 2018 of ASU 2016-18 – Statement of Cash Flows (Topic 230): Restricted Cash in 

which we changed the presentation of our cash and cash equivalents to include both cash and due from banks as well as interest-earning deposits with banks, which are 
inclusive of any restricted cash. See Note 1 (Summary of Significant Accounting Policies) for more information. 

(2) 	 Financial information for the prior period has been revised to reflect presentation changes in connection with our adoption in first quarter 2018 of ASU 2016-01 – Financial 
Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities. See Note 1 (Summary of Significant Accounting 
Policies) for more information. 

(3) 	 Parenthetical amounts represent assets and liabilities that we are required to carry at fair value or have elected the fair value option. 
(4) 	 Our consolidated assets at December 31, 2018 and 2017, include the following assets of certain variable interest entities (VIEs) that can only be used to settle the liabilities 
of those VIEs: Cash and due from banks, $139 million and $116 million; Interest-bearing deposits with banks, $8 million and $371 million; Debt securities, $45 million and 
$0 million; Net loans, $13.6 billion and $12.5 billion; Derivative assets, $0 million and $0 million; Equity securities, $85 million and $306 million; Other assets, $221 million 
and $342 million; and Total assets, $14.1 billion and $13.6 billion, respectively. 

(5) 	 Our consolidated liabilities at December 31, 2018 and 2017, include the following VIE liabilities for which the VIE creditors do not have recourse to Wells Fargo: Derivative 
liabilities, $0 million and $5 million; Accrued expenses and other liabilities, $191 million and $132 million; Long-term debt, $816 million and $1.5 billion; and Total 
liabilities, $1.0 billion and $1.6 billion, respectively. 

The accompanying notes are an integral part of these statements. 

141

Wells Fargo & Company 

141 

Wells Fargo & Company and Subsidiaries 

Consolidated Statement of Changes in Equity 

(in millions, except shares) 

Balance December 31, 2015 

Cumulative effect from change in consolidation accounting (1) 

Balance January 1, 2016 

Net income 

Other comprehensive income (loss), net of tax 

Noncontrolling interests 

Common stock issued 

Common stock repurchased (2) 

Preferred stock issued to ESOP 

Preferred stock released by ESOP 

Preferred stock converted to common shares 

Common stock warrants repurchased/exercised 

Preferred stock issued 

Common stock dividends 

Preferred stock dividends 

Tax benefit from stock incentive compensation 

Stock incentive compensation expense 

Net change in deferred compensation and related plans 

Net change 

Balance December 31, 2016 

Cumulative effect from change in hedge accounting (3) 

Balance January 1, 2017 

Net income 

Other comprehensive income (loss), net of tax 

Noncontrolling interests 

Common stock issued 

Common stock repurchased (2) 

Preferred stock issued to ESOP 

Preferred stock released by ESOP 

Preferred stock converted to common shares 

Common stock warrants repurchased/exercised 

Preferred stock issued 

Common stock dividends 

Preferred stock dividends 

Tax benefit from stock incentive compensation (4) 

Stock incentive compensation expense 

Net change in deferred compensation and related plans 

Net change 

Balance December 31, 2017 

Preferred stock 

Common stock 

Shares 

Amount 

Shares 

Amount 

11,259,917  $ 

22,214 

5,092,128,810  $ 

9,136 

11,259,917 

22,214 

5,092,128,810 

9,136 

63,441,805 

(159,647,152) 

1,150,000 

1,150 

(963,205) 

(963) 

20,185,863 

86,000 

2,150 

272,795 

2,337 

(76,019,484) 

— 

11,532,712  $ 

24,551 

5,016,109,326  $ 

9,136 

11,532,712 

24,551 

5,016,109,326 

9,136 

57,257,564 

(196,519,707) 

950,000 

950 

(833,077) 

(833) 

14,769,445 

27,600 

690 

144,523 

807 

(124,492,698) 

— 

11,677,235  $ 

25,358 

4,891,616,628  $ 

9,136 

(1) 	 Effective January 1, 2016, we adopted changes in consolidation accounting pursuant to Accounting Standards Update (ASU) 2015-02: Amendments to the Consolidation 

Analysis. Accordingly, we recorded a $121 million net increase to beginning noncontrolling interests as a cumulative-effect adjustment. 

(2) 	 For the year ended December 31, 2016, includes $750 million related to a private forward repurchase transaction that settled in first quarter 2017 for 14.7 million shares of 

common stock. See Note 1 (Summary of Significant Accounting Policies) for additional information. 

(3) 	 Effective January 1, 2017, we adopted changes in hedge accounting pursuant to ASU 2017-12 – Derivatives and Hedging (Topic 815): Targeted Improvements to 

Accounting for Hedging Activities. 

(4) 	 Effective January 1, 2017, we adopted Accounting Standards Update 2016-09 (Improvements to Employee Share-Based Payment Accounting). Accordingly, tax benefit 

from stock incentive compensation is reported in income tax expense in the consolidated statement of income.

 The accompanying notes are an integral part of these statements. 

(continued on following pages) 

142 

Wells Fargo & Company 

142

  
  
 
Retained 
earnings 

120,866 

120,866 

21,938 

(451) 

(7,712) 

(1,566) 

12,209 

133,075 

(381) 

132,694 

22,183 

(277) 

(7,708) 

(1,629) 

Additional 
paid-in
capital 

60,714 

60,714 

2 

(203) 

(250) 

99 

(83) 

(11) 

(17) 

(49) 

51 

277 

779 

(1,075) 

(480) 

60,234 

60,234 

— 

(133) 

750 

31 

(35) 

97 

(133) 

(13) 

50 

— 

875 

(830) 

659 

60,893 

Wells Fargo stockholders’ equity 

Cumulative 
other 
comprehensive 
income (loss) 

Treasury
stock 

Unearned 
ESOP 
shares 

Total 
Wells Fargo 
stockholders’ 
equity 

297 

(18,867) 

(1,362) 

192,998 

Noncontrolling
interests 

893 

121 

Total 
equity 

193,891 

121 

297 

(18,867) 

(1,362) 

192,998 

1,014 

194,012 

(3,434) 

3,040 

(7,866) 

974 

(1,249) 

1,046 

6 

(3,846) 

(22,713) 

(203) 

(1,565) 

(3,434) 

(3,137) 

168 

(2,969) 

(22,713) 

(1,565) 

825 

2,758 

(10,658) 

736 

(981) 

868 

21,938 

(3,434) 

2 

2,386 

(8,116) 

— 

963 

— 

(17) 

2,101 

(7,661) 

(1,566) 

277 

779 

(1,069) 

6,583 

199,581 

(213) 

199,368 

22,183 

825 

—

2,348 

(9,908) 

— 

833 

— 

(133) 

677 

(7,658) 

(1,629) 

— 

875 

(845) 

7,568 

206,936 

107 

(17) 

(188) 

(98) 

916 

916 

277 

(62) 

 12

227 

1,143 

22,045 

(3,451) 

(186) 

2,386 

(8,116) 

— 

963 

— 

(17) 

2,101 

(7,661) 

(1,566) 

277 

779 

(1,069) 

6,485 

200,497 

(213) 

200,284 

22,460 

763 

 12 

2,348 

(9,908) 

— 

833 

— 

(133) 

677 

(7,658) 

(1,629) 

— 

875 

(845) 

7,795 

208,079 

12,569 

145,263 

825 

(2,144) 

(15) 

(7,179) 

(29,892) 

(113) 

(1,678) 

143

Wells Fargo & Company 

143 

(continued from previous pages) 

Wells Fargo & Company and Subsidiaries 

Consolidated Statement of Changes in Equity 

(in millions, except shares) 

Balance December 31, 2017 

Cumulative effect from change in accounting policies (1) 

Preferred stock 

Common stock 

Shares 

Amount 

Shares 

Amount 

11,677,235  $ 

25,358 

4,891,616,628  $ 

9,136 

Balance January 1, 2018 

11,677,235 

25,358 

4,891,616,628 

9,136 

Adoption of accounting standard related to certain tax effects

stranded in accumulated other comprehensive income (loss)(2) 

Net income 

Other comprehensive income (loss), net of tax 

Noncontrolling interests 

Common stock issued 

Common stock repurchased 

Preferred stock redeemed (3) 

Preferred stock issued to ESOP 

Preferred stock released by ESOP 

Preferred stock converted to common shares 

Common stock warrants repurchased/exercised 

Preferred stock issued 

Common stock dividends 

Preferred stock dividends 

Stock incentive compensation expense 

Net change in deferred compensation and related plans 

Net change 

Balance December 31, 2018 

41,082,047 
(375,477,998) 

(2,150,375) 
1,100,000 

(1,995) 

1,100 

(1,249,644) 

(1,249) 

24,032,931 

— 

— 

(2,300,019) 

(2,144) 

(310,363,020) 

— 

9,377,216  $ 

23,214 

4,581,253,608  $ 

9,136 

(1) 	 Effective January 1, 2018, we adopted ASU 2016-04 – Liabilities – Extinguishments of Liabilities (Subtopic 405-20): Recognition of Breakage for Certain Prepaid Stored-
Value Products, ASU 2016-01 – Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities, and ASU 
2014-09 – Revenue from Contracts With Customers (Topic 606) and subsequent related Updates. See Note 1 (Summary of Significant Accounting Policies) in this Report for 
more information. 

(2) 	 Represents the reclassification from other comprehensive income to retained earnings as a result of our adoption of ASU 2018-02 – Reclassification of Certain Tax Effects 

from Accumulated Other Comprehensive Income, in the third quarter of 2018. For additional information, see Note 1. 

(3) 	 Represents the impact of the redemption of preferred stock, series J, in third quarter 2018. 

The accompanying notes are an integral part of these statements. 

144 

Wells Fargo & Company 

144

 
 
Wells Fargo stockholders’ equity 

Additional
 paid-in
capital 

Retained 
earnings 

Cumulative 
other 
comprehensive
income (loss) 

Treasury
stock 

Unearned 
ESOP 
shares 

Total 
Wells Fargo 
stockholders’ 
equity 

Noncontrolling
interests 

Total 
equity 

60,893 

145,263 

(2,144) 

(29,892) 

(1,678) 

206,936 

1,143 

208,079 

60,893 

145,357 

(2,262) 

(29,892) 

(1,678) 

206,912 

1,143 

208,055 

94 

(118) 

(24)

 (24)

(400) 

(3,674) 

400 

22,393 

(321) 

(155) 

(7,955) 

(1,556) 

12,806 

158,163 

(4,074) 

(6,336) 

7 

(76) 

— 

43 

(70) 

6 

(325) 

— 

66 

1,041 

(900) 

(208) 

60,685 

2,073 

(20,633) 

1,243 

15 

(17,302) 

(47,194) 

(1,143) 

1,319 

— 

22,393 

(3,674) 

7 

1,676 

(20,633) 

(2,150) 

— 

1,249 

— 

(325) 

— 

(7,889) 

(1,556) 

1,041 

(885) 

483 

(2) 

(724) 

— 

22,876 

(3,676) 

(717) 

1,676 

(20,633) 

(2,150) 

— 

1,249 

— 

(325) 

— 

(7,889) 

(1,556) 

1,041 

(885) 

176 

(10,746) 

(243) 

(10,989) 

(1,502) 

196,166 

900 

197,066 

145

Wells Fargo & Company 

145 

 
Wells Fargo & Company and Subsidiaries 

Consolidated Statement of Cash Flows 

(in millions) 

Cash flows from operating activities: 

Net income before noncontrolling interests 

Adjustments to reconcile net income to net cash provided by operating activities: 

Provision for credit losses 
Changes in fair value of MSRs, MLHFS and LHFS carried at fair value 
Depreciation, amortization and accretion 
Other net gains (1) 
Stock-based compensation 

Originations and purchases of mortgage loans held for sale (1) 
Proceeds from sales of and paydowns on mortgages loans held for sale (1) 
Net change in: 

Debt and equity securities, held for trading (1) 
Loans held for sale (1) 
Deferred income taxes 
Derivative assets and liabilities 
Other assets (1) 
Other accrued expenses and liabilities 

Net cash provided by operating activities 

Cash flows from investing activities: 

Net change in: 

Year ended December 31, 

2018 

2017 

2016 

$ 

22,876 

22,460 

22,045 

1,744 
453 
5,593 
(7,630) 
2,255 

(152,832) 
119,097 

35,054 

(960) 
1,970 
1,513 
7,805 
(865) 

36,073 

2,528 
886 
5,406 
(1,518) 
2,046 
(181,269) 
134,984 

33,505 
327 
666 
(5,025) 
(1,214) 
4,837 

18,619 

3,770 
139 
4,970 
(6,337) 
1,945 
(205,300) 
127,479 

63,309 
(451) 
1,793 
2,089 
(14,232) 
(211) 

1,008 

Federal funds sold and securities purchased under resale agreements (2) 

(1,184) 

(21,497) 

(15,747) 

Available-for-sale debt securities: 
Proceeds from sales (1) 
Prepayments and maturities (1) 
Purchases (1) 

Held-to-maturity securities: 

Paydowns and maturities 
Purchases 

Equity securities, not held for trading: 

Proceeds from sales and capital returns (1) 
Purchases (1) 

Loans: 

Loans originated by banking subsidiaries, net of principal collected 
Proceeds from sales (including participations) of loans held for investment 
Purchases (including participations) of loans 
Principal collected on nonbank entities’ loans 
Loans originated by nonbank entities 

Net cash paid for acquisitions 
Proceeds from sales of foreclosed assets and short sales 
Other, net (2) 

Net cash used by investing activities 

Cash flows from financing activities: 

Net change in: 
Deposits 
Short-term borrowings 

Long-term debt: 

Proceeds from issuance 
Repayment 
Preferred stock: 

Proceeds from issuance 
Redeemed 
Cash dividends paid 

Common stock: 

Proceeds from issuance 
Stock tendered for payment of withholding taxes 
Repurchased 
Cash dividends paid 

Net change in noncontrolling interests 
Other, net 

Net cash provided (used) by financing activities 

Net change in cash, cash equivalents, and restricted cash (2) 

Cash, cash equivalents, and restricted cash at beginning of year (2) 

Cash, cash equivalents, and restricted cash at end of year (2) 

Supplemental cash flow disclosures: 

Cash paid for interest 
Cash paid for income taxes 

7,320 
36,725 
(60,067) 

10,934 
— 

6,242 
(6,433) 

(18,619) 
16,294 
(2,088) 
6,791 
(6,482) 
(10) 

3,592 
(769) 

(7,754) 

(48,034) 
2,531 

47,595 
(40,565) 

— 

(2,150) 
(1,622) 

632 
(331) 
(20,633) 
(7,692) 
(462) 
(248) 

(70,979) 

(42,660) 

215,947 

173,287 

42,067 
45,688 
(103,656) 

30,958 
40,998 
(120,978) 

10,673 
— 

5,451 
(3,735) 

317 
10,439 
(3,702) 
7,448 
(6,814) 
(320) 
5,198 
(709) 

7,957 
(23,593) 

3,711 
(5,383) 

(39,002) 
10,061 
(6,221) 
6,844 
(7,743) 
(30,584) 
7,311 
(508) 

(13,152) 

(141,919) 

29,912 
14,020 

43,575 
(80,802) 

677 
— 
(1,629) 

1,211 
(393) 
(9,908) 
(7,480) 
30 
(133) 

(10,920) 

(5,453) 

221,400 

215,947 

82,767 
(1,198) 

90,111 
(34,462) 

2,101 
— 
(1,566) 

1,415 
(494) 
(8,116) 
(7,472) 
(188) 
(107) 

122,791 

(18,120) 

239,520 

221,400 

14,366 
1,977 

9,103 
6,592 

5,573 
8,446 

$ 

$ 

(1) 	 Financial information for the prior periods has been revised to reflect presentation changes made in connection with our adoption in first quarter 2018 of ASU 2016-01 – 
Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities. See Note 1 (Summary of Significant 
Accounting Policies) for more information. 

(2) 	 Financial information has been revised to reflect the impact of our adoption in first quarter 2018 of ASU 2016-18 – Statement of Cash Flows (Topic 230): Restricted Cash in 

which we changed the presentation of our cash and cash equivalents to include both cash and due from banks as well as interest-earning deposits with banks, which are 
inclusive of any restricted cash. See Note 1 (Summary of Significant Accounting Policies) for more information. 

The accompanying notes are an integral part of these statements. See Note 1 (Summary of Significant Accounting Policies) for noncash activities. 

146 

Wells Fargo & Company 

146

Notes to Financial Statements 

See the Glossary of Acronyms at the end of this Report for terms used throughout the Financial Statements and related Notes. 

Note 1:  Summary of Significant Accounting Policies 

Wells Fargo & Company is a diversified financial services 
company. We provide banking, trust and investments, mortgage 
banking, investment banking, retail banking, brokerage, and 
consumer and commercial finance through banking locations, 
the internet and other distribution channels to consumers, 
businesses and institutions in all 50 states, the District of 
Columbia, and in foreign countries. When we refer to 
“Wells Fargo,” “the Company,” “we,” “our” or “us,” we mean 
Wells Fargo & Company and Subsidiaries (consolidated). 
Wells Fargo & Company (the Parent) is a financial holding 
company and a bank holding company. We also hold a majority 
interest in a real estate investment trust, which has publicly 
traded preferred stock outstanding. 

Our accounting and reporting policies conform with U.S. 

generally accepted accounting principles (GAAP) and practices 
in the financial services industry. To prepare the financial 
statements in conformity with GAAP, management must make 
estimates based on assumptions about future economic and 
market conditions (for example, unemployment, market 
liquidity, real estate prices, etc.) that affect the reported amounts 
of assets and liabilities at the date of the financial statements, 
income and expenses during the reporting period and the related 
disclosures. Although our estimates contemplate current 
conditions and how we expect them to change in the future, it is 
reasonably possible that actual conditions could be worse than 
anticipated in those estimates, which could materially affect our 
results of operations and financial condition. Management has 
made significant estimates in several areas, including: 
• 	

allowance for credit losses (Note 6 (Loans and Allowance for 
Credit Losses)); 
valuations of residential mortgage servicing rights (MSRs) 
(Note 9 (Securitizations and Variable Interest Entities) and 
Note 10 (Mortgage Banking Activities)) and financial 
instruments (Note 18 (Fair Values of Assets and 
Liabilities)); 
liabilities for contingent litigation losses (Note 16 (Legal 
Actions)); and 
income taxes (Note 23 (Income Taxes)). 

• 	

• 	

• 	

Actual results could differ from those estimates. 

Accounting Standards Adopted in 2018 
In 2018, we adopted the following new accounting guidance: 
• 	 Accounting Standards Update (ASU or Update) 2018-14 – 
Compensation – Retirement Benefits – Defined Benefit 
Plans—General (Subtopic 715-20): Disclosure Framework – 
Changes to the Disclosure Requirements for Defined 
Benefit Plans 

• 	 ASU 2018-02 – Income Statement-Reporting 

Comprehensive Income (Topic 220): Reclassification of 
Certain Tax Effects from Accumulated Other 
Comprehensive Income 

• 	 ASU 2017-09 – Compensation – Stock Compensation 
(Topic 718): Scope of Modification Accounting; 

• 	 ASU 2017-07 – Improving the Presentation of Net Periodic 
Pension Cost and Net Periodic Postretirement Benefit Cost; 
• 	 ASU 2017-05 – Other Income – Gains and Losses from the 

Derecognition of Nonfinancial Assets (Subtopic 610-20): 
Clarifying the Scope of Asset Derecognition Guidance and 
Accounting for Partial Sales of Nonfinancial Assets; 
• 	 ASU 2017-01 – Business Combinations (Topic 805): 

Clarifying the Definition of a Business; 

• 	 ASU 2016-18 – Statement of Cash Flows (Topic 230): 

Restricted Cash; 

• 	 ASU 2016-16 – Income Taxes (Topic 740): Intra-Entity 

Transfers of Assets Other Than Inventory; 

• 	 ASU 2016-15 – Statement of Cash Flows (Topic 230): 
Classification of Certain Cash Receipts and Cash 
Payments; 

• 	 ASU 2016-04 – Liabilities – Extinguishments of Liabilities 

(Subtopic 405-20): Recognition of Breakage for Certain 
Prepaid Stored-Value Products; 

• 	 ASU 2016-01 – Financial Instruments – Overall (Subtopic 

825-10): Recognition and Measurement of Financial Assets 
and Financial Liabilities; and 

• 	 ASU 2014-09 – Revenue from Contracts With Customers 

(Topic 606) and subsequent related Updates. 

ASU 2018-14 changes the disclosure requirements for our 
defined benefit pension and postretirement plans. We are 
eliminating two disclosures that are no longer considered 
beneficial: (1) information related to amounts in accumulated 
other comprehensive income to be recognized in the next year as 
benefit cost and (2) the effect of one-percentage point change on 
assumed health care cost trend rates. We have added two 
disclosures: (1) the weighted-average interest crediting rates for 
plans with promised interest crediting rates, and (2) 
explanations for significant gain and losses related to changes in 
the benefit obligation. We early adopted this change in fourth 
quarter 2018. 

ASU 2018-02 allows a reclassification to update amounts in 
accumulated other comprehensive income to an appropriate tax 
rate under the Tax Cuts & Jobs Act. In 2018, we reclassified 
$400 million resulting in a reduction of accumulated other 
comprehensive income and an increase to retained earnings. For 
additional information, see Note 25 (Other Comprehensive 
Income). We have finalized our provisional tax estimates based 
on the completion of our U.S. tax filings in fourth quarter 2018. 

ASU 2017-09 clarifies when to account for a change to the 
terms or conditions of a share-based payment award as a 
modification. Under the ASU, modification accounting is 
required only if the fair value, the vesting conditions, or the 
classification of the award (as equity or liability) changes as a 
result of the change in terms or conditions. The Update is 
applied to awards modified on or after the adoption date and 
accordingly, did not have a material impact on our consolidated 
financial statements. 

ASU 2017-07 requires that the service cost component of net 
benefit cost be reported in the same line item as other 
compensation costs arising from services rendered by employees 
during the period, and the other pension cost components 
(interest cost, expected return on plan assets and amortization of 
actuarial gains and losses) be presented in the income statement 
separate from the service cost component. The income statement 
line item used to present the other pension cost components 
must be disclosed. We adopted this change in first quarter 2018. 
The Update did not have a material impact on our consolidated 
financial statements. 

147

Wells Fargo & Company 

147 

 
 
 
 
 
Note 1:  Summary of Significant Accounting Policies (continued) 

ASU 2017-05 provides guidance for recognizing gains and 
losses from the transfer of nonfinancial assets in contracts with 
non-customers. The ASU applies to nonfinancial assets, 
including real estate (e.g., buildings, land, windmills, solar 
farms), ships and intellectual property. We adopted this change 
in first quarter 2018. The Update did not have a material impact 
on our consolidated financial statements. 

ASU 2017-01 requires that when substantially all of the fair 
value of gross assets acquired is concentrated in a single asset (or 
a group of similar assets), the assets acquired would not 
represent a business. We adopted this change in first quarter 
2018. The Update is applied prospectively and did not have a 
material impact on our consolidated financial statements. 

ASU 2016-18 requires that restricted cash and cash equivalents 
are included with the total cash and cash equivalents in the 
consolidated statement of cash flows. In addition, the nature of 
any restrictions will be disclosed in the footnotes to the financial 
statements. We adopted this change in first quarter 2018. Our 
retrospective adoption includes changes to our presentation of 
cash and cash equivalents in our consolidated statement of cash 
flows to include both cash and due from banks as well as 
interest-earning deposits with banks. In addition, we had 
corresponding changes on our consolidated balance sheets. 

ASU 2016-16 requires us to recognize the income tax effects of 
intercompany sales and transfers of assets other than inventory 
in the period in which the transfer occurs. We adopted this 
change in first quarter 2018. The Update did not have a material 
impact on our consolidated financial statements. 

ASU 2016-15 addresses eight specific cash flow issues with the 
objective of reducing the existing diversity in practice for 
reporting in the statement of cash flows. We adopted this change 
in first quarter 2018. The Update did not have a material impact 
on our consolidated financial statements. 

ASU 2016-04 modifies the accounting for certain prepaid card 
products to require the recognition of breakage. Breakage 
represents the estimated amount that will not be redeemed by 
the cardholder for goods or services. We adopted this change in 
first quarter 2018. Upon adoption, we recorded a cumulative-
effect adjustment that increased retained earnings, given 
estimated breakage, by $20 million. 

ASU 2016-01 changes the accounting for certain equity 
securities to record at fair value with unrealized gains or losses 
reflected in earnings, as well as improve the disclosures of equity 
securities and the fair value of financial instruments. The Update 
also requires that for purposes of disclosing the fair value of 
financial instruments recorded at amortized cost, including 
loans and long-term debt, the valuation methodology is based on 
an exit price notion. 

We adopted the Update in first quarter 2018 and recorded a 

cumulative-effect adjustment as of January 1, 2018, that 
increased retained earnings by $106 million as a result of a 
transition adjustment to reclassify $118 million in net unrealized 
gains from other comprehensive income to retained earnings, 
partially offset by a transition adjustment to decrease retained 
earnings by $12 million primarily to adjust the carrying value of 
our auction rate securities from cost to fair value. No transition 
adjustment was recorded for investments changed to the 
measurement alternative (described below), which was applied 
prospectively. 

As a result of adopting this ASU, our investments in 
marketable equity securities, including those previously 
classified as available-for-sale, are accounted for at fair value 
with unrealized gains or losses reflected in earnings. 
Additionally, our share of unrealized gains or losses related to 
marketable equity securities held by our equity method investees 
are reflected in earnings. Prior to adoption, such unrealized 
gains and losses were reflected in other comprehensive income. 
Our investments in nonmarketable equity securities previously 
accounted for under the cost method of accounting, except for 
Federal Reserve Bank stock, are now accounted for either at fair 
value with unrealized gains and losses reflected in earnings or 
using the measurement alternative. The measurement 
alternative is similar to the cost method of accounting, except 
the carrying value is adjusted through earnings for impairment, 
if any, and changes in observable and orderly transactions in the 
same or similar investment. We account for substantially all of 
our private equity investments, previously using the cost method 
of accounting, now under the measurement alternative. Our 
auction rate securities portfolio is now accounted for at fair value 
with unrealized gains or losses reflected in earnings. 

In connection with our adoption of this Update, we have 
modified our balance sheet and income statement presentation 
to report marketable and nonmarketable equity securities and 
their results separately from debt securities by now reporting all 
equity securities in a new line labeled “Equity securities” in both 
the balance sheet and income statement. Additionally we now 
report loans held for trading purposes in loans held for sale and 
have reclassified net gains and losses on marketable equity 
securities used as economic hedges of deferred compensation 
obligations from “Net gains for trading activities” to “Net gains 
from equity securities”. All prior periods have been revised to 
conform to these changes in reporting. 

148 

Wells Fargo & Company 

148

Table 1.1 provides a summary of our reporting changes 
implemented in connection with our adoption of ASU 2016-01 in 
first quarter 2018. 

Table 1.1:  Summary of Reporting Changes 

Financial instrument or 

transaction type 

Balance Sheet

As previously reported 

Revised reporting 

   Marketable equity securities 

Trading assets and available for sale investment securities  Equity securities (new caption)


   Nonmarketable equity securities 

Other assets 

   Loans held for trading 

Trading assets 

   Debt securities held for trading 

Trading assets 

Equity securities (new caption)


Loans held for sale


Debt securities (formerly “Investment securities”)
 

Income Statement

 Interest income:

      Marketable equity securities 

Trading assets and investment securities 

      Nonmarketable equity securities 

Other 

      Loans held for trading 

Trading assets 

      Debt securities held for trading 

Trading assets 

 Noninterest income:

Equity securities (new caption)

Equity securities (new caption)

Loans held for sale

Debt securities (formerly “Investment securities”)

 Deferred compensation gains (1)  Net gains from trading activities 

Net gains from equity securities 

(1)  Reclassification of net gains and losses on marketable equity securities economically hedging our deferred compensation obligations. 

Table 1.2 summarizes financial assets and liabilities by form 

and measurement accounting model. 

Table 1.2:  Accounting Model for Financial Assets and Liabilities 

Balance sheet caption 

Measurement model(s) 

Financial statement Note reference 

Cash and due from banks 

Interest-earning deposits with banks 

Cost 

Cost 

Federal funds sold and securities purchased

Amortized cost 

under resale agreements 

N/A 

N/A 

N/A 

Debt securities: 

Trading 

Available-for-sale 

Held-to-maturity 

Mortgage loans held for sale 

Loans held for sale 

Loans 

Derivative assets and liabilities 

Equity securities: 

Marketable 

Nonmarketable 

Other assets 

Deposits 

Short-term borrowings 

Long-term debt 

FV-NI (1) 

FV-OCI (2) 

Note 4:  Trading Activities 
Note 18:  Fair Values of Assets and Liabilities 

Note 5:  Available-for-Sale and Held-to-Maturity Debt Securities 
Note 18:  Fair Values of Assets and Liabilities 

Amortized cost 

Note 5:  Available-for-Sale and Held-to-Maturity Debt Securities 

FV-NI (1)
LOCOM (3) 

FV-NI (1)
LOCOM (3) 

Amortized cost 
FV-NI (1) 

FV-NI (1)
FV-OCI (2) 

FV-NI (1) 

FV-NI (1)
Cost method 
Equity method
MA (4) 

Amortized cost (5) 

Amortized cost 

Amortized cost 

Amortized cost 

Note 18:  Fair Values of Assets and Liabilities 

Note 18:  Fair Values of Assets and Liabilities 

Note 6:  Loans and Allowance for Credit Losses 
Note 18:  Fair Values of Assets and Liabilities 

Note 4:  Trading Activities 
Note 17:  Derivatives 
Note 18:  Fair Values of Assets and Liabilities 

Note 4:  Trading Activities 
Note 8:  Equity Securities
Note 18:  Fair Values of Assets and Liabilities 

Note 4:  Trading Activities 
Note 8:  Equity Securities
Note 18:  Fair Values of Assets and Liabilities 

Note 7:  Premises, Equipment, Lease Commitments and Other
Assets 

N/A 

N/A 

N/A 

(1)  FV-NI represents the fair value through net income accounting model. 
(2)  FV-OCI represents the fair value through other comprehensive income accounting model. 
(3)  LOCOM represents the lower of cost or fair value accounting model. 
(4)  MA represents the measurement alternative accounting model. 
(5)  Other assets are generally carried at amortized cost, except for bank-owned life insurance which is carried at cash surrender value. 

149

Wells Fargo & Company 

149 

  
  
 
  
 
Note 1:  Summary of Significant Accounting Policies (continued) 

ASU 2014-09 modifies the guidance used to recognize revenue 
from contracts with customers for transfers of goods or services 
and transfers of non-financial assets, unless those contracts are 
within the scope of other guidance. We adopted the Update in 
first quarter 2018, and upon a modified retrospective adoption, 
we recorded a cumulative-effect adjustment as of January 1, 
2018, that decreased retained earnings by $32 million, due to 
changes in the timing of revenue for corporate trust services that 
are provided over the life of the associated trust. In addition, we 
changed the presentation of some costs such that underwriting 
expenses of our broker-dealer business that were previously 
netted against revenue are now included in noninterest expense, 
and card payment network charges that were previously 
included in noninterest expense are now netted against card fee 
revenue. 

Consolidation 
Our consolidated financial statements include the accounts of 
the Parent and our subsidiaries in which we have a controlling 
interest. 

We are also a variable interest holder in certain entities in 

which equity investors do not have the characteristics of a 
controlling financial interest or where the entity does not have 
enough equity at risk to finance its activities without additional 
subordinated financial support from other parties (referred to as 
variable interest entities (VIEs)). Our variable interest arises 
from contractual, ownership or other monetary interests in the 
entity, which change with fluctuations in the fair value of the 
entity’s net assets. We consolidate a VIE if we are the primary 
beneficiary. We are the primary beneficiary if we have a 
controlling financial interest, which includes both the power to 
direct the activities that most significantly impact the VIE and a 
variable interest that potentially could be significant to the VIE. 
To determine whether or not a variable interest we hold could 
potentially be significant to the VIE, we consider both qualitative 
and quantitative factors regarding the nature, size and form of 
our involvement with the VIE. We assess whether or not we are 
the primary beneficiary of a VIE on an ongoing basis.

 Significant intercompany accounts and transactions are 
eliminated in consolidation. When we have significant influence 
over operating and financing decisions for a company but do not 
own a majority of the voting equity interests, we account for the 
investment using the equity method of accounting, which 
requires us to recognize our proportionate share of the 
company’s earnings. If we do not have significant influence, we 
account for the equity security under the fair value method, cost 
method or measurement alternative. 

Cash, Cash Equivalents and Restricted Cash 
Cash, cash equivalents and restricted cash include cash on hand, 
cash items in transit, and amounts due from or held with other 
depository institutions. See Note 3 (Cash, Loan and Dividend 
Restrictions) for the nature of our restrictions on cash and cash 
equivalents. 

Trading Activities 
We engage in trading activities to accommodate the investment 
and risk management activities of our customers. These 
activities predominantly occur in our Wholesale Banking 
businesses and to a lesser extent other divisions of the Company. 
The assets and liabilities classified as trading include debt 
securities, loans, equity securities, derivatives and short sales, 
which are reported within the balance sheet line item based on 
the form of the instrument. In addition, debt securities that are 

held for investment purposes that we have elected to account for 
under the fair value method, are classified as trading. 

Our trading assets and liabilities are carried on the balance 

sheet at fair value with changes in fair value recognized in net 
gains from trading activities and interest income and interest 
expense recognized in net interest income. 

Customer accommodation trading activities include our 
actions as an intermediary to buy and sell financial instruments 
and market-making activities. We also take positions to manage 
our exposure to customer accommodation activities. We hold 
financial instruments for trading in long positions (assets), as 
well as short positions where we sold financial instruments we 
have not yet purchased (liabilities), to facilitate our trading 
activities. As an intermediary we interact with market buyers 
and sellers to facilitate the purchase and sale of financial 
instruments to meet the anticipated or current needs of our 
customers. For example, we may purchase or sell a derivative to 
a customer who wants to manage interest rate risk exposure. We 
typically enter into an offsetting derivative or security position to 
manage our exposure to the customer transaction. We earn 
income based on the transaction price difference between the 
customer transaction and the offsetting position, which is 
reflected in the fair value changes of the positions recorded in 
the net gains from trading activities. 

Our market-making activities include taking long and short 

trading positions to facilitate customer order flow. These 
activities are typically executed on a short-term basis. As a 
market-maker we earn income due to: (1) difference between the 
price paid or received for the purchase and sale of the security 
(bid-ask spread), (2) the net interest income of the positions, 
and (3) the changes in fair value of the trading positions held on 
our balance sheet. Additionally, we may enter into separate 
derivative or security positions to manage our exposure related 
to our long and short trading positions taken in our market-
making activities. Income earned on these market-making 
activities are reflected in the fair value changes of these positions 
recorded in net gains from trading activities. 

Debt Securities 
Our investments in debt securities that are not held for trading 
purposes are classified as either debt securities available-for-sale 
(AFS) or held-to-maturity (HTM). 

AVAILABLE-FOR-SALE DEBT SECURITIES 
Debt securities for which the Company does not have the 
postitive intent and ability to hold to maturity are classified as 
AFS. These AFS debt securities are reported at fair value with 
unrealized gains and losses, net of applicable income taxes, 
reported in cumulative OCI. 

We conduct other-than-temporary impairment (OTTI) 
analysis on a quarterly basis or more often if a potential loss-
triggering event occurs. The initial indicator of OTTI is a decline 
in fair value below the amortized cost of the debt security. 

An AFS debt security that has a decline in the fair value 
below the security’s amortized cost records OTTI if we (1) have 
the intent to sell the security, (2) it is more likely than not that 
we will be required to sell the security before recovery of its 
amortized cost basis, or (3) we do not expect to recover the 
entire amortized cost basis of the security. 

Estimating recovery of the amortized cost basis of an AFS 

debt security is based upon an assessment of the cash flows 
expected to be collected. If the present value of cash flows 
expected to be collected, discounted at the security’s effective 
yield, is less than amortized cost, OTTI is considered to have 
occurred. In performing an assessment of the cash flows 

150 

Wells Fargo & Company 

150

 
 
expected to be collected, we consider all relevant information 
including: 
• 	

the length of time and the extent to which the fair value has 
been less than the amortized cost basis; 
the historical and implied volatility of the fair value of the 
security; 
the cause of the price decline, such as the general level of 
interest rates or adverse conditions specifically related to 
the security, an industry or a geographic area; 
the issuer’s financial condition, near-term prospects and 
ability to service the debt; 
the payment structure of the debt security and the 
likelihood of the issuer being able to make payments that 
increase in the future; 
for asset-backed securities, the credit performance of the 
underlying collateral, including delinquency rates, level of 
non-performing assets, cumulative losses to date, collateral 
value and the remaining credit enhancement compared with 
expected credit losses; 
any change in rating agencies’ credit ratings at evaluation 
date from acquisition date and any likely imminent action; 
independent analyst reports and forecasts, sector credit 
ratings and other independent market data; and 
recoveries or additional declines in fair value subsequent to 
the balance sheet date. 

• 	

• 	

• 	

• 	

• 	

• 	

• 	

• 	

If we intend to sell the security, or if it is more likely than 

not we will be required to sell the security before recovery of 
amortized cost basis, an OTTI write-down is recognized in 
earnings equal to the entire difference between the amortized 
cost basis and fair value of the security. For debt security that is 
considered other-than-temporarily impaired that we do not 
intend to sell or it is more likely than not that we will not be 
required to sell before recovery, the OTTI write-down is 
separated into an amount representing the credit loss, which is 
recognized in earnings, and the amount related to all other 
factors, which is recognized in OCI. The measurement of the 
credit loss component is equal to the difference between the debt 
security’s amortized cost basis and the present value of its 
expected future cash flows discounted at the security’s effective 
yield. The remaining difference between the security’s fair value 
and the present value of expected future cash flows is due to all 
other factors. We believe that we will fully collect the carrying 
value of securities on which we have recorded a non-credit­
related impairment in OCI. 

Following the recognition of OTTI, the security’s new 
amortized cost basis is the previous basis minus the OTTI 
amount recognized in earnings. 

We recognize realized gains and losses on the sale of AFS 

debt securities in net gains (losses) on debt securities using the 
specific identification method. 

Unamortized premiums and discounts are recognized in 
interest income over the contractual life of the security using the 
interest method. As principal repayments are received on 
securities (i.e., primarily mortgage-backed securities (MBS)) a 
proportionate amount of the related premium or discount is 
recognized in income so that the effective interest rate on the 
remaining portion of the security continues unchanged. 

HELD-TO-MATURITY DEBT SECURITIES  Debt securities for 
which the Company has the positive intent and ability to hold to 
maturity are classified as held-to-maturity (HTM). These HTM 
debt securities are reported at historical cost adjusted for 
amortization of premiums and accretion of discounts. We 
recognize OTTI when there is a decline in fair value and we do 

not expect to recover the entire amortized cost basis of the debt 
security. The amortized cost is written-down to fair value with 
the credit loss component recorded to earnings and the 
remaining component recognized in OCI. The OTTI assessment 
related to intent to sell, required to sell, whether we expect 
recovery of the amortized cost basis and determination of any 
credit loss component recognized in earnings for HTM debt 
securities is the same as described for AFS debt securities. AFS 
debt securities transferred to the HTM classification are 
recorded at fair value and the unrealized gains or losses resulting 
from the transfer of these securities continue to be reported in 
cumulative OCI. The unamortized OCI balance is amortized into 
earnings over the remaining life of the security using the 
effective interest method. The HTM amortized cost basis used in 
the OTTI analysis includes the unamortized OCI balances related 
to previous security transfers. 

Securities Purchased and Sold Agreements 
Securities purchased under resale agreements and securities sold 
under repurchase agreements are accounted for as collateralized 
financing transactions and are recorded at the acquisition or sale 
price plus accrued interest. We monitor the fair value of 
securities purchased and sold and obtain collateral from or 
return it to counterparties when appropriate. These financing 
transactions do not create material credit risk given the 
collateral provided and the related monitoring process. 

Mortgage Loans and Loans Held for Sale 
Mortgage loans held for sale (MLHFS) include commercial and 
residential mortgages originated for sale and securitization in 
the secondary market, which is our principal market, or for sale 
as whole loans. We have elected the fair value option for 
substantially all residential MLHFS (see Note 18 (Fair Values of 
Assets and Liabilities)). The remaining residential MLHFS are 
held at the lower of cost or fair value (LOCOM) and are valued 
on an aggregate portfolio basis. Commercial MLHFS are held at 
LOCOM and are valued on an individual loan basis. 

Loans held for sale (LHFS) includes commercial loans 
originated for sale in the secondary market and loans used in 
market-making activities in our trading business. The loans held 
for trading purposes are carried at fair value, with the remainder 
of LHFS recorded at LOCOM. 

Gains and losses on MLHFS are recorded in mortgage 
banking noninterest income. Gains and losses on LHFS used in 
trading activities are recognized in net gains from trading 
activities, with gains and losses on LHFS not used in trading 
activities recognized in other noninterest income. Direct loan 
origination costs and fees for MLHFS and LHFS under the fair 
value option are recognized in income at origination. For 
MLHFS and LHFS recorded at LOCOM, loan costs and fees are 
deferred at origination and are recognized in income at time of 
sale. Interest income on MLHFS and LHFS is calculated based 
upon the note rate of the loan and is recorded in interest income. 
Our lines of business are authorized to originate held-for­
investment loans that meet or exceed established loan product 
profitability criteria, including minimum positive net interest 
margin spreads in excess of funding costs. When a 
determination is made at the time of commitment to originate 
loans as held for investment, it is our intent to hold these loans 
to maturity or for the “foreseeable future,” subject to periodic 
review under our management evaluation processes, including 
corporate asset/liability management. In determining the 
“foreseeable future” for loans, management considers (1) the 
current economic environment and market conditions, (2) our 
business strategy and current business plans, (3) the nature and 

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Note 1:  Summary of Significant Accounting Policies (continued) 

type of the loan receivable, including its expected life, and 
(4) our current financial condition and liquidity demands. If 
subsequent changes, including changes in interest rates, 
significantly impact the ongoing profitability of certain loan 
products, we may subsequently change our intent to hold these 
loans, and we would take actions to sell such loans. Upon such 
management determination, we immediately transfer these 
loans to the MLHFS or LHFS portfolio at LOCOM. 

Loans 
Loans are reported at their outstanding principal balances net of 
any unearned income, cumulative charge-offs, unamortized 
deferred fees and costs on originated loans and unamortized 
premiums or discounts on purchased loans. PCI loans are 
reported net of any remaining purchase accounting adjustments. 
See the “Purchased Credit-Impaired Loans” section in this Note 
for our accounting policy for PCI loans. 

Unearned income, deferred fees and costs, and discounts 

and premiums are amortized to interest income over the 
contractual life of the loan using the interest method. Loan 
commitment fees are generally deferred and amortized into 
noninterest income on a straight-line basis over the commitment 
period. 

We have certain private label and co-brand credit card loans 

through a program agreement that involves our active 
participation in the operating activity of the program with a third 
party. We share in the economic results of the loans subject to 
this agreement. We consider the program to be a collaborative 
arrangement and therefore report our share of revenue and 
losses on a net basis in interest income for loans, other 
noninterest income and provision for credit losses as applicable. 
Our net share of revenue from this activity represented less than 
1% of our total revenues for 2018. 

Loans also include direct financing leases that are recorded 
at the aggregate of minimum lease payments receivable plus the 
estimated residual value of the leased property, less unearned 
income. Leveraged leases, which are a form of direct financing 
leases, are recorded net of related non-recourse debt. Leasing 
income is recognized as a constant percentage of outstanding 
lease financing balances over the lease terms in interest income. 

NONACCRUAL AND PAST DUE LOANS  We generally place 
loans on nonaccrual status when: 
• 	

the full and timely collection of interest or principal 
becomes uncertain (generally based on an assessment of the 
borrower’s financial condition and the adequacy of 
collateral, if any), such as in bankruptcy or other 
circumstances; 
they are 90 days (120 days with respect to real estate 1-4 
family first and junior lien mortgages) past due for interest 
or principal, unless both well-secured and in the process of 
collection; 

• 	

from accretable yield, independent of performance in accordance 
of their contractual terms, and we expect to fully collect the new 
carrying values of such loans (that is, the new cost basis arising 
out of purchase accounting). 

When we place a loan on nonaccrual status, we reverse the 
accrued unpaid interest receivable against interest income and 
suspend amortization of any net deferred fees. If the ultimate 
collectability of the recorded loan balance is in doubt on a 
nonaccrual loan, the cost recovery method is used and cash 
collected is applied to first reduce the carrying value of the loan. 
Otherwise, interest income may be recognized to the extent cash 
is received. Generally, we return a loan to accrual status when all 
delinquent interest and principal become current under the 
terms of the loan agreement and collectability of remaining 
principal and interest is no longer doubtful. 

We typically re-underwrite modified loans at the time of a 

restructuring to determine if there is sufficient evidence of 
sustained repayment capacity based on the borrower’s financial 
strength, including documented income, debt to income ratios 
and other factors. If the borrower has demonstrated 
performance under the previous terms and the underwriting 
process shows the capacity to continue to perform under the 
restructured terms, the loan will generally remain in accruing 
status. When a loan classified as a troubled debt restructuring 
(TDR) performs in accordance with its modified terms, the loan 
either continues to accrue interest (for performing loans) or will 
return to accrual status after the borrower demonstrates a 
sustained period of performance (generally six consecutive 
months of payments, or equivalent, inclusive of consecutive 
payments made prior to the modification). Loans will be placed 
on nonaccrual status and a corresponding charge-off is recorded 
if we believe it is probable that principal and interest 
contractually due under the modified terms of the agreement 
will not be collectible. 

Our loans are considered past due when contractually 
required principal or interest payments have not been made on 
the due dates. 

LOAN CHARGE-OFF POLICIES  For commercial loans, we 
generally fully charge off or charge down to net realizable value 
(fair value of collateral, less estimated costs to sell) for loans 
secured by collateral when: 
• 	 management judges the loan to be uncollectible; 
• 	

repayment is deemed to be protracted beyond reasonable 
time frames; 
the loan has been classified as a loss by either our internal 
loan review process or our banking regulatory agencies; 
the customer has filed bankruptcy and the loss becomes 
evident owing to a lack of assets; or 
the loan is 180 days past due unless both well-secured and 
in the process of collection. 

• 	

• 	

• 	

• 	 part of the principal balance has been charged off, except for 

• 	

credit card loans, which are generally not placed on 
nonaccrual status, but are generally fully charged off when 
the loan reaches 180 days past due; or 
for junior lien mortgages, we have evidence that the related 
first lien mortgage may be 120 days past due or in the 
process of foreclosure regardless of the junior lien 
delinquency status. 

PCI loans are written down at acquisition to fair value using 

an estimate of cash flows deemed to be collectible and an 
accretable yield is established. Accordingly, such loans are not 
classified as nonaccrual because they continue to earn interest 

For consumer loans, we fully charge off or charge down to 

net realizable value when deemed uncollectible due to 
bankruptcy or other factors, or no later than reaching a defined 
number of days past due, as follows: 
• 	

1-4 family first and junior lien mortgages – We generally 
charge down to net realizable value when the loan is 180 
days past due. 

• 	 Automobile loans – We generally fully charge off when the 

loan is 120 days past due. 

• 	 Credit card loans – We generally fully charge off when the 

loan is 180 days past due. 

• 	 Unsecured loans (closed end) – We generally fully charge 

off when the loan is 120 days past due. 

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• 	 Unsecured loans (open end) – We generally fully charge off 

when the loan is 180 days past due. 

• 	 Other secured loans – We generally fully or partially charge 
down to net realizable value when the loan is 120 days past 
due. 

IMPAIRED LOANS  We consider a loan to be impaired when, 
based on current information and events, we determine that we 
will not be able to collect all amounts due according to the loan 
contract, including scheduled interest payments. This evaluation 
is generally based on delinquency information, an assessment of 
the borrower’s financial condition and the adequacy of collateral, 
if any. Our impaired loans predominantly include loans on 
nonaccrual status in the commercial portfolio segment and loans 
modified in a TDR, whether on accrual or nonaccrual status. 

When we identify a loan as impaired, we generally measure 

the impairment, if any, based on the difference between the 
recorded investment in the loan (net of previous charge-offs, 
deferred loan fees or costs and unamortized premium or 
discount) and the present value of expected future cash flows, 
discounted at the loan’s effective interest rate. When the value of 
an impaired loan is calculated by discounting expected cash 
flows, interest income is recognized using the loan’s effective 
interest rate over the remaining life of the loan. When collateral 
is the sole source of repayment for the impaired loan, rather 
than the borrower’s income or other sources of repayment, we 
charge down to net realizable value. 

TROUBLED DEBT RESTRUCTURINGS  In situations where, for 
economic or legal reasons related to a borrower’s financial 
difficulties, we grant a concession for other than an insignificant 
period of time to the borrower that we would not otherwise 
consider, the related loan is classified as a TDR. These modified 
terms may include rate reductions, principal forgiveness, term 
extensions, payment forbearance and other actions intended to 
minimize our economic loss and to avoid foreclosure or 
repossession of the collateral, if applicable. For modifications 
where we forgive principal, the entire amount of such principal 
forgiveness is immediately charged off. Loans classified as TDRs, 
including loans in trial payment periods (trial modifications), are 
considered impaired loans. Other than resolutions such as 
foreclosures, sales and transfers to held-for-sale, we may remove 
loans held for investment from TDR classification, but only if 
they have been refinanced or restructured at market terms and 
qualify as a new loan. 

PURCHASED CREDIT-IMPAIRED LOANS  Loans acquired with 
evidence of credit deterioration since their origination and where 
it is probable that we will not collect all contractually required 
principal and interest payments are PCI loans. PCI loans are 
recorded at fair value at the date of acquisition, and the 
historical allowance for credit losses related to these loans is not 
carried over. Fair value at date of acquisition is generally 
determined using a discounted cash flow method and any excess 
cash flow expected to be collected over the carrying value 
(estimated fair value at acquisition date) is referred to as the 
accretable yield and is recognized in interest income using an 
effective yield method over the remaining life of the loan, or pool 
of loans if aggregated based on common risk characteristics. The 
difference between contractually required payments and the 
cash flows expected to be collected at acquisition, considering 
the impact of prepayments, is referred to as the nonaccretable 
difference. Based on quarterly evaluations of remaining cash 
flows expected to be collected, expected decreases may result in 
recording a provision for loss and expected increases may result 

in a prospective yield adjustment after first reversing any 
allowance for losses related to the loan, or pool of loans. 

Resolutions of loans may include sales of loans to third 
parties, receipt of payments in settlement with the borrower, or 
foreclosure of the collateral. For individual PCI loans, gains or 
losses on sales to third parties are included in other noninterest 
income, and gains or losses as a result of a settlement with the 
borrower are included in interest income. Our policy is to 
remove an individual loan from a pool based on comparing the 
amount received from its resolution with its contractual amount. 
Any difference between these amounts is absorbed by the 
nonaccretable difference for the entire pool, which assumes that 
the amount received from resolution approximates pool 
performance expectations. Any material change in remaining 
effective yield caused by this removal method is addressed by 
our quarterly cash flow evaluation process for each 
pool. We may also sell groups of loans from a pool and include 
any gains or losses on sales to third parties in other noninterest 
income. Any difference between the amount received from the 
buyer and the contractual amount due from the customer is 
absorbed by the nonaccretable difference for the entire pool. We 
maintain the effective yield for the remaining loans in the pool 
consistent with the yield immediately prior to the sale. 

Modified PCI loans are not removed from a pool even if 
those loans would otherwise be deemed TDRs. Modified PCI 
loans that are accounted for individually are considered TDRs 
and removed from PCI accounting if there has been a concession 
granted in excess of the original nonaccretable difference. We 
include these TDRs in our impaired loans. 

FORECLOSED ASSETS  Foreclosed assets obtained through our 
lending activities primarily include real estate. Generally, loans 
have been written down to their net realizable value prior to 
foreclosure. Any further reduction to their net realizable value is 
recorded with a charge to the allowance for credit losses at 
foreclosure. We allow up to 90 days after foreclosure to finalize 
determination of net realizable value. Thereafter, changes in net 
realizable value are recorded to noninterest expense. The net 
realizable value of these assets is reviewed and updated 
periodically depending on the type of property. Certain 
government-guaranteed mortgage loans upon foreclosure are 
included in accounts receivable, not foreclosed assets. These 
receivables were loans predominantly insured by the FHA or 
guaranteed by the VA and are measured based on the balance 
expected to be recovered from the FHA or VA. 

ALLOWANCE FOR CREDIT LOSSES (ACL)  The allowance for 
credit losses is management’s estimate of credit losses inherent 
in the loan portfolio, including unfunded credit commitments, at 
the balance sheet date. We have an established process to 
determine the appropriateness of the allowance for credit losses 
that assesses the losses inherent in our portfolio and related 
unfunded credit commitments. We develop and document our 
allowance methodology at the portfolio segment level – 
commercial loan portfolio and consumer loan portfolio. While 
we attribute portions of the allowance to our respective 
commercial and consumer portfolio segments, the entire 
allowance is available to absorb credit losses inherent in the total 
loan portfolio and unfunded credit commitments. 

Our process involves procedures to appropriately consider 
the unique risk characteristics of our commercial and consumer 
loan portfolio segments. For each portfolio segment, losses are 
estimated collectively for groups of loans with similar 
characteristics, individually or pooled for impaired loans or, for 

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Note 1:  Summary of Significant Accounting Policies (continued) 

PCI loans, based on the changes in cash flows expected to be 
collected. 

Our allowance levels are influenced by loan volumes, loan 
grade migration or delinquency status, historic loss experience 
and other conditions influencing loss expectations, such as 
economic conditions. 

COMMERCIAL PORTFOLIO SEGMENT ACL METHODOLOGY 
Generally, commercial loans are assessed for estimated losses by 
grading each loan using various risk factors as identified through 
periodic reviews. Our estimation approach for the commercial 
portfolio reflects the estimated probability of default in 
accordance with the borrower’s financial strength and the 
severity of loss in the event of default, considering the quality of 
any underlying collateral. Probability of default and severity at 
the time of default are statistically derived through historical 
observations of default and losses after default within each credit 
risk rating. These estimates are adjusted as appropriate based on 
additional analysis of long-term average loss experience 
compared to previously forecasted losses, external loss data or 
other risks identified from current economic conditions and 
credit quality trends. The estimated probability of default and 
severity at the time of default are applied to loan equivalent 
exposures to estimate losses for unfunded credit commitments. 

The allowance also includes an amount for the estimated 
impairment on nonaccrual commercial loans and commercial 
loans modified in a TDR, whether on accrual or nonaccrual 
status. 

CONSUMER PORTFOLIO SEGMENT ACL METHODOLOGY 
For consumer loans that are not identified as a TDR, we 
generally determine the allowance on a collective basis utilizing 
forecasted losses to represent our best estimate of inherent loss. 
We pool loans, generally by product types with similar risk 
characteristics, such as residential real estate mortgages and 
credit cards. As appropriate and to achieve greater accuracy, we 
may further stratify selected portfolios by sub-product, 
origination channel, vintage, loss type, geographic location and 
other predictive characteristics. Models designed for each pool 
are utilized to develop the loss estimates. We use assumptions 
for these pools in our forecast models, such as historic 
delinquency and default, loss severity, home price trends, 
unemployment trends, and other key economic variables that 
may influence the frequency and severity of losses in the pool. 
In determining the appropriate allowance attributable to 
our residential mortgage portfolio, we take into consideration 
portfolios determined to be at elevated risk, such as junior lien 
mortgages behind delinquent first lien mortgages and junior 
lien lines of credit subject to near term significant payment 
increases. We incorporate the default rates and severity of loss 
for these higher risk portfolios, including the impact of our 
established loan modification programs. Accordingly, the loss 
content associated with the effects of loan modifications and 
higher risk portfolios has been captured in our ACL 
methodology. 

We separately estimate impairment for consumer loans that 

have been modified in a TDR (including trial modifications), 
whether on accrual or nonaccrual status. 

OTHER ACL MATTERS  The allowance for credit losses for both 
portfolio segments includes an amount for imprecision or 
uncertainty that may change from period to period. This amount 
represents management’s judgment of risks inherent in the 
processes and assumptions used in establishing the allowance. 
This imprecision considers economic environmental factors, 

modeling assumptions and performance, process risk, and other 
subjective factors, including industry trends and emerging risk 
assessments. 

Securitizations and Beneficial Interests 
In certain asset securitization transactions that meet the 
applicable criteria to be accounted for as a sale, assets are sold to 
an entity referred to as a Special Purpose Entity (SPE), which 
then issues beneficial interests in the form of senior and 
subordinated interests collateralized by the assets. In some 
cases, we may retain beneficial interests issued by the entity. 
Additionally, from time to time, we may also re-securitize certain 
assets in a new securitization transaction. 

The assets and liabilities transferred to an SPE are excluded 
from our consolidated balance sheet if the transfer qualifies as a 
sale and we are not required to consolidate the SPE. 

For transfers of financial assets recorded as sales, we 
recognize and initially measure at fair value all assets obtained 
(including beneficial interests) and liabilities incurred. We 
record a gain or loss in noninterest income for the difference 
between the carrying amount and the fair value of the assets 
sold. Fair values are based on quoted market prices, quoted 
market prices for similar assets, or if market prices are not 
available, then the fair value is estimated using discounted cash 
flow analyses with assumptions for credit losses, prepayments 
and discount rates that are corroborated by and verified against 
market observable data, where possible. Interests retained from 
and liabilities incurred in securitizations with off-balance sheet 
entities include debt and equity securities, loans, MSRs, 
derivative assets and liabilities, other assets, other liabilities, 
such as liabilities for mortgage repurchase losses or long-term 
debt and are accounted for as described within this Note. 

Mortgage Servicing Rights (MSRs) 
We recognize the rights to service mortgage loans for others, or 
MSRs, as assets whether we purchase the MSRs or the MSRs 
result from a sale or securitization of loans we originate (asset 
transfers). We initially record all of our MSRs at fair value. 
Subsequently, residential loan MSRs are carried at fair value. All 
of our MSRs related to our commercial mortgage loans are 
subsequently measured at LOCOM. The valuation and sensitivity 
of MSRs is discussed further in Note 9 (Securitizations and 
Variable Interest Entities), Note 10 (Mortgage Banking 
Activities) and Note 18 (Fair Values of Assets and Liabilities). 

For MSRs carried at fair value, changes in fair value are 
reported in mortgage banking noninterest income in the period 
in which the change occurs. MSRs subsequently measured at 
LOCOM are amortized in proportion to, and over the period of, 
estimated net servicing income. The amortization of MSRs is 
reported in mortgage banking noninterest income, analyzed 
monthly and adjusted to reflect changes in prepayment speeds, 
as well as other factors. 

MSRs accounted for at LOCOM are periodically evaluated 

for impairment based on the fair value of those assets. For 
purposes of impairment evaluation and measurement, we 
stratify MSRs based on the predominant risk characteristics of 
the underlying loans, including investor and product type. If, by 
individual stratum, the carrying amount of these MSRs exceeds 
fair value, a valuation allowance is established. The valuation 
allowance is adjusted as the fair value changes. 

Premises and Equipment 
Premises and equipment are carried at cost less accumulated 
depreciation and amortization. Capital leases, where we are the 

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lessee, are included in premises and equipment at the capitalized 
amount less accumulated amortization. 

We primarily use the straight-line method of depreciation 
and amortization. Estimated useful lives range up to 40 years for 
buildings, up to 10 years for furniture and equipment, and the 
shorter of the estimated useful life (up to 8 years) or the lease 
term for leasehold improvements. We amortize capitalized 
leased assets on a straight-line basis over the lives of the 
respective leases. 

the variability of cash flows to be received or paid related to a 
recognized asset or liability (“cash flow hedge”), or (3) held for 
customer accommodation trading or asset/liability risk 
management or other purposes, including economic hedges not 
qualifying for hedge accounting. For derivatives not designated 
as a fair value or cash flow hedge, we report changes in the fair 
values in current period noninterest income. For additional 
information on derivative assets and liabilities used in our 
trading business, see Note 4 (Trading Activities). 

Goodwill and Identifiable Intangible Assets 
Goodwill is recorded in business combinations under the 
purchase method of accounting when the purchase price is 
higher than the fair value of net assets, including identifiable 
intangible assets. 

We assess goodwill for impairment at a reporting unit level 
on an annual basis or more frequently in certain circumstances. 
We have determined that our reporting units are one level below 
the operating segments and distinguish these reporting units 
based on how the segments and reporting units are managed, 
taking into consideration the economic characteristics, nature of 
the products, and customers of the segments and reporting 
units. At the time we acquire a business, we allocate goodwill to 
applicable reporting units based on their relative fair value, and 
if we have a significant business reorganization, we may 
reallocate the goodwill. If we sell a business, a portion of 
goodwill is included with the carrying amount of the divested 
business. 

We have the option of performing a qualitative assessment 
of goodwill. We may also elect to bypass the qualitative test and 
proceed directly to a quantitative test. If we perform a qualitative 
assessment of goodwill to test for impairment and conclude it is 
more likely than not that a reporting unit’s fair value is greater 
than its carrying amount, quantitative tests are not required. 
However, if we determine it is more likely than not that a 
reporting unit’s fair value is less than its carrying amount, then 
we complete a quantitative assessment to determine if there is 
goodwill impairment. We apply various quantitative valuation 
methodologies, including discounted cash flow and earnings 
multiple approaches, to determine the estimated fair value, 
which is compared to the carrying value of each reporting unit. If 
the fair value is less than the carrying amount, an additional test 
is required to measure the amount of impairment. We recognize 
impairment losses as a charge to other noninterest expense 
(unless related to discontinued operations) and an adjustment to 
the carrying value of the goodwill asset. Subsequent reversals of 
goodwill impairment are prohibited. 

We amortize core deposit and other customer relationship 

intangibles on an accelerated basis over useful lives not 
exceeding 10 years. We review such intangibles for impairment 
whenever events or changes in circumstances indicate that 
their carrying amounts may not be recoverable. Impairment is 
indicated if the sum of undiscounted estimated future net cash 
flows is less than the carrying value of the asset. Impairment is 
permanently recognized by writing down the asset to the 
extent that the carrying value exceeds the estimated fair value. 

Derivatives and Hedging Activities 
DERIVATIVES  We recognize all derivatives on the balance 
sheet at fair value. On the date we enter into a derivative 
contract, we designate the derivative as (1) qualifying for hedge 
accounting in a hedge of the fair value of a recognized asset or 
liability or an unrecognized firm commitment, including hedges 
of foreign currency exposure (“fair value hedge”), (2) qualifying 
for hedge accounting in a hedge of a forecasted transaction or of 

DOCUMENTATION AND EFFECTIVENESS ASSESSMENT FOR 
ACCOUNTING HEDGES  For fair value and cash flow hedges 
qualifying for hedge accounting, we formally document at 
inception the relationship between hedging instruments and 
hedged items, our risk management objective, strategy and our 
evaluation of effectiveness for our hedge transactions. This 
process includes linking all derivatives designated as fair value 
or cash flow hedges to specific assets and liabilities on the 
balance sheet or to specific forecasted transactions. We assess 
hedge effectiveness using regression analysis, both at inception 
of the hedging relationship and on an ongoing basis. For fair 
value hedges, the regression analysis involves regressing the 
periodic change in fair value of the hedging instrument against 
the periodic changes in fair value of the asset or liability being 
hedged due to changes in the hedged risk(s). For cash flow 
hedges, the regression analysis involves regressing the periodic 
changes in fair value of the hedging instrument against the 
periodic changes in fair value of the hypothetical derivative. The 
hypothetical derivative has terms that identically match and 
offset the cash flows of the forecasted transaction being hedged 
due to changes in the hedged risk(s). The initial assessment for 
fair value and cash flow hedges includes an evaluation of the 
quantitative measures of the regression results used to validate 
the conclusion of high effectiveness. Periodically, as required, we 
also formally assess whether the derivative we designated in 
each hedging relationship is expected to be and has been highly 
effective in offsetting changes in fair values or cash flows of the 
hedged item using the regression analysis method. 

FAIR VALUE HEDGES  For a fair value hedge, we record 
changes in the fair value of the derivative in current period 
income, except for certain derivatives in which a portion is 
recorded to OCI. We record basis adjustments to the amortized 
cost of the hedged asset or liability due to the changes in fair 
value related to the hedged risk with the offset recorded in 
current period net income. We present derivative gains or losses 
in the same income statement category as the hedged asset or 
liability, as follows: 
• 	 For fair value hedges of interest rate risk, amounts are 

reflected in net interest income; 

• 	 For hedges of foreign currency risk, amounts representing 

the fair value changes less the accrual for periodic cash flow 
settlements are reflected in noninterest income. The 
periodic cash flow settlements are reflected in net interest 
income; 

• 	 For hedges of both interest rate risk and foreign currency 
risk, amounts representing the fair value change less the 
accrual for periodic cash flow settlements is attributed to 
both net interest income and noninterest income. The 
periodic cash flow settlements are reflected in net interest 
income. 

The entire derivative gain or loss is included in the 

assessment of hedge effectiveness for all fair value hedge 
relationships, except for hedges of foreign-currency 

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Note 1:  Summary of Significant Accounting Policies (continued) 

denominated available-for-sale debt securities and long-term 
debt liabilities, as follows: 
• 	 When hedged with cross-currency swaps, the change in fair 

value of the derivative attributable to cross-currency basis 
spread changes component is excluded from the assessment 
of hedge effectiveness. The initial fair value of the excluded 
component is amortized to net interest income. For these 
hedges, the difference between changes in fair value of the 
excluded component and the amount recorded in earnings 
is recorded in OCI; 

• 	 When hedged with foreign currency forward derivatives, the 
change in fair value of the derivative attributable to the time 
value component related to the changes in the difference 
between the spot and forward price is excluded from the 
assessment of hedge effectiveness. For these hedges, the 
changes in fair value of the excluded component are 
recorded in net interest income. 

CASH FLOW HEDGES  For a cash flow hedge, we record 
changes in the fair value of the derivative in OCI. We 
subsequently reclassify gains and losses from these changes in 
fair value from OCI to net income in the same period(s) that the 
hedged transaction affects net income and in the same income 
statement category as the hedged item, thus to net interest 
income. The entire gain or loss on these derivatives is included 
in the assessment of hedge effectiveness. 

DISCONTINUING HEDGE ACCOUNTING  We discontinue 
hedge accounting prospectively when (1) a derivative is no longer 
highly effective in offsetting changes in the fair value or cash 
flows of a hedged item, (2) a derivative expires or is sold, 
terminated or exercised, (3) we elect to discontinue the 
designation of a derivative as a hedge, or (4) in a cash flow 
hedge, a derivative is de-designated because it is no longer 
probable that a forecasted transaction will occur. 

When we discontinue fair value hedge accounting, we no 
longer adjust the previously hedged asset or liability for changes 
in fair value, and remaining cumulative adjustments to the 
hedged item and accumulated amounts reported in OCI are 
accounted for in the same manner as other components of the 
carrying amount of the asset or liability. If the hedged item is 
derecognized, the accumulated amounts reported in OCI are 
immediately reclassified to net income. If the derivative 
continues to be held after fair value hedge accounting ceases, we 
carry the derivative on the balance sheet at its fair value with 
changes in fair value included in noninterest income. 

When we discontinue cash flow hedge accounting and it is 

probable that the forecasted transaction will occur, the 
accumulated amount reported in OCI at the de-designation date 
continues to be reported in OCI until the forecasted transaction 
affects net income at which point the related OCI amount is 
reclassified to net income. If cash flow hedge accounting is 
discontinued and it is probable the forecasted transaction will no 
longer occur, the accumulated gains and losses reported in OCI 
at the de-designation date is immediately reclassified to net 
income. If the derivative continues to be held after cash flow 
hedge accounting ceases, we carry the derivative on the balance 
sheet at its fair value with changes in fair value included in 
noninterest income. 

EMBEDDED DERIVATIVES  We may purchase or originate 
financial instruments that contain an embedded derivative. At 
inception of the financial instrument, we assess (1) if the 
economic characteristics of the embedded derivative are not 
clearly and closely related to the economic characteristics of the 

financial instrument (host contract), (2) if the financial 
instrument that embodies both the embedded derivative and the 
host contract is not measured at fair value with changes in fair 
value reported in net income, and (3) if a separate instrument 
with the same terms as the embedded instrument would meet 
the definition of a derivative. If the embedded derivative meets 
all of these conditions, we separate it from the host contract by 
recording the bifurcated derivative at fair value and the 
remaining host contract at the difference between the basis of 
the hybrid instrument and the fair value of the bifurcated 
derivative. The bifurcated derivative is carried at fair value with 
changes recorded in current period noninterest income. 

COUNTERPARTY CREDIT RISK AND NETTING  By using 
derivatives, we are exposed to counterparty credit risk, which is 
the risk that counterparties to the derivative contracts do not 
perform as expected. If a counterparty fails to perform, our 
counterparty credit risk is equal to the amount reported as a 
derivative asset on our balance sheet. The amounts reported as a 
derivative asset are derivative contracts in a gain position, and to 
the extent subject to legally enforceable master netting 
arrangements, net of derivatives in a loss position with the same 
counterparty and cash collateral received. We minimize 
counterparty credit risk through credit approvals, limits, 
monitoring procedures, executing master netting arrangements 
and obtaining collateral, where appropriate. Counterparty credit 
risk related to derivatives is considered in determining fair value 
and our assessment of hedge effectiveness. To the extent 
derivatives subject to master netting arrangements meet the 
applicable requirements, including determining the legal 
enforceability of the arrangement, it is our policy to present 
derivative balances and related cash collateral amounts net on 
the balance sheet. In the second quarter of 2017, we adopted 
Settlement to Market treatment for the cash collateralizing our 
interest rate derivative contracts with certain centrally cleared 
counterparties. As a result of this adoption, derivative balances 
with these counterparties are considered settled by the collateral. 

For additional information on our derivatives and hedging 

activities, see Note 17 (Derivatives). 

Equity Securities 
Marketable equity securities have readily determinable fair 
values and include, but are not limited to securities used in our 
trading activities. Marketable equity securities are recorded at 
fair value with unrealized gains and losses, due to changes in fair 
value, reflected in earnings. Unrealized gains and losses are 
recognized in net gains from trading activities for equity 
securities related to our trading activities and net gains from 
equity securities for the remaining securities. Realized gains and 
losses are recognized in net gains from trading activities for 
equity securities related to our trading activities and net gains 
from equity securities for the remaining securities. Interest and 
dividend income from marketable equity securities is recognized 
in interest income. 

Nonmarketable equity securities do not have readily 
determinable fair values, and do not include investments for 
which we hold a controlling interest in the investee. These 
securities are accounted for under one of the following 
accounting methods: 
• 	 Fair Value: This method is an election. The securities are 
recorded at fair value with unrealized gains or losses 
reflected in earnings; 

• 	 Equity Method: We use this method when we have the 

ability to exert significant influence over the investee. These 

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securities are carried at cost and adjusted for our share of 
the investee’s earnings or losses, less any impairments; 
• 	 Cost Method: This method is required for specific securities, 
such as Federal Reserve Bank stock and Federal Home Loan 
Bank stock. These investments are held at their cost minus 
impairment. If impaired, the carrying value is written down 
to the fair value of the security; 

• 	 Measurement Alternative: This method is followed by all 

remaining nonmarketable equity securities. These securities 
are carried at cost less impairment, and adjusted up or 
down to fair value upon the occurrence of orderly 
observable transactions of the same or similar security of 
the same issuer. 

Our review for impairment for equity method, cost method 

and measurement alternative securities typically includes an 
analysis of the facts and circumstances of each security, the 
intent or requirement to sell the security, the expectations of 
cash flows, capital needs and the viability of its business model. 
For equity method and cost method investments, we reduce the 
asset’s carrying value when we consider declines in value to be 
other than temporary. For securities accounted for under the 
measurement alternative, we reduce the asset value when the 
fair value is less than carrying value, without the consideration 
of recovery. We recognize all estimated impairment losses as an 
unrealized loss recorded in net gains on equity securities. 

Realized gains and losses on the sale of nonmarketable 
equity securities are recognized in net gains on equity securities. 

Operating Lease Assets 
Operating lease rental income for leased assets is recognized in 
other income on a straight-line basis over the lease term. Related 
depreciation expense is recorded on a straight-line basis over the 
estimated useful life, considering the estimated residual value of 
the leased asset. The useful life may be adjusted to the term of 
the lease depending on our plans for the asset after the lease 
term. On a periodic basis, leased assets are reviewed for 
impairment. Impairment loss is recognized if the carrying 
amount of leased assets exceeds fair value and is not recoverable. 
The carrying amount of leased assets is not recoverable if it 
exceeds the sum of the undiscounted cash flows expected to 
result from the lease payments and the estimated residual value 
upon the eventual disposition of the equipment. 

Pension Accounting 
We account for our defined benefit pension plans using an 
actuarial model. Two principal assumptions in determining net 
periodic pension cost are the discount rate and the expected 
long-term rate of return on plan assets. 

A discount rate is used to estimate the present value of our 

future pension benefit obligations. We use a consistent 
methodology to determine the discount rate using a yield curve 
with maturity dates that closely match the estimated timing of 
the expected benefit payments for our plans. The yield curve is 
derived from a broad-based universe of high quality corporate 
bonds as of the measurement date. 

Our determination of the reasonableness of our expected 

long-term rate of return on plan assets is highly quantitative by 
nature. We evaluate the current asset allocations and expected 
returns under two sets of conditions: (1) projected returns using 
several forward-looking capital market assumptions, and (2) 
historical returns for the main asset classes dating back to 1970 
or the earliest period for which historical data was readily 
available for the asset classes included. Using long-term 
historical data allows us to capture multiple economic 

environments, which we believe is relevant when using historical 
returns. We place greater emphasis on the forward-looking 
return and risk assumptions than on historical results. We use 
the resulting projections to derive a base line expected rate of 
return and risk level for the Cash Balance Plan’s prescribed asset 
mix. We evaluate the portfolio based on: (1) the established 
target asset allocations over short term (one-year) and longer 
term (ten-year) investment horizons, and (2) the range of 
potential outcomes over these horizons within specific standard 
deviations. We perform the above analyses to assess the 
reasonableness of our expected long-term rate of return on plan 
assets. We consider the expected rate of return to be a long-term 
average view of expected returns. 

At year end, we re-measure our defined benefit plan 
liabilities and related plan assets and recognize any resulting 
actuarial gain or loss in other comprehensive income. We 
generally amortize net actuarial gain or loss in excess of a 5% 
corridor from accumulated OCI into net periodic pension cost 
over the estimated average remaining participation period, 
which at December 31, 2018, is 19 years. See Note 22 (Employee 
Benefits and Other Expenses) for additional information on our 
pension accounting. 

Income Taxes 
We file consolidated and separate company U.S. federal income 
tax returns, foreign tax returns and various combined and 
separate company state tax returns. 

We evaluate two components of income tax expense: 
current and deferred income tax expense. Current income tax 
expense represents our estimated taxes to be paid or refunded 
for the current period and includes income tax expense related 
to our uncertain tax positions. Deferred income tax expense 
results from changes in deferred tax assets and liabilities 
between periods. We determine deferred income taxes using the 
balance sheet method. Under this method, the net deferred tax 
asset or liability is based on the tax effects of the differences 
between the book and tax bases of assets and liabilities, and 
recognizes enacted changes in tax rates and laws in the period in 
which they occur. Deferred tax assets are recognized subject to 
management’s judgment that realization is “more likely than 
not.” Uncertain tax positions that meet the more likely than not 
recognition threshold are measured to determine the amount of 
benefit to recognize. An uncertain tax position is measured at the 
largest amount of benefit that management believes has a 
greater than 50% likelihood of realization upon settlement. Tax 
benefits not meeting our realization criteria represent 
unrecognized tax benefits. We account for interest and penalties 
as a component of income tax expense. In 2018, we finalized the 
recognition of the U.S. tax expense associated with a deemed 
repatriation of undistributed earnings of certain non-U.S. 
subsidiaries as required under the 2017 Tax Act. We do not 
intend to distribute these earnings in a taxable manner, and 
therefore intend to limit distributions to foreign earnings 
previously taxed in the U.S., that would qualify for the 100% 
dividends received deduction, and that would not result in any 
significant state or foreign taxes. All other undistributed foreign 
earnings will continue to be permanently reinvested outside the 
U.S. 

See Note 23 (Income Taxes) to Financial Statements in this 

Report for a further description of our provision for income 
taxes and related income tax assets and liabilities. 

Stock-Based Compensation 
We have stock-based employee compensation plans as more 
fully discussed in Note 20 (Common Stock and Stock Plans). Our 

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157 

Note 1:  Summary of Significant Accounting Policies (continued) 

Long-Term Incentive Compensation Plan provides for awards of 
incentive and nonqualified stock options, stock appreciation 
rights, restricted shares, restricted share rights (RSRs), 
performance share awards (PSAs) and stock awards without 
restrictions. For most awards, we measure the cost of employee 
services received in exchange for an award of equity 
instruments, such as stock options, RSRs or PSAs, based on the 
fair value of the award on the grant date. The cost is normally 
recognized in our income statement over the vesting period of 
the award; awards with graded vesting are expensed on a 
straight-line method. Awards that continue to vest after 
retirement are expensed over the shorter of the period of time 
between the grant date and the final vesting period or between 
the grant date and when a team member becomes retirement 
eligible; awards to team members who are retirement eligible at 
the grant date are subject to immediate expensing upon grant. 
Beginning in 2013, certain RSRs and all PSAs granted 
include discretionary conditions that can result in forfeiture and 
are subject to variable accounting. For these awards, the 
associated compensation expense fluctuates with changes in our 
stock price. For PSAs, compensation expense also fluctuates 
based on the estimated outcome of meeting the performance 
conditions. 

Earnings Per Common Share 
We compute earnings per common share by dividing net income 
(after deducting dividends on preferred stock) by the average 
number of common shares outstanding during the year. We 
compute diluted earnings per common share by dividing net 
income (after deducting dividends on preferred stock) by the 
average number of common shares outstanding during the year 
plus the effect of common stock equivalents (for example, stock 
options, restricted share rights, convertible debentures and 
warrants) that are dilutive. 

Fair Value of Financial Instruments 
We use fair value measurements in our fair value disclosures and 
to record certain assets and liabilities at fair value on a recurring 
basis, such as instruments used in our trading activities, or on a 
nonrecurring basis, such as measuring impairment on assets 
carried at amortized cost. We base our fair values on the price 
that would be received to sell an asset or paid to transfer a 
liability in an orderly transaction between market participants at 
the measurement date. These fair value measurements are based 
on the exit price notion and are determined by maximizing the 
use of observable inputs. However, for certain instruments, we 
must utilize unobservable inputs in determining fair value due to 
the lack of observable inputs in the market, which requires 
greater judgment in the measurement of fair value. 

In instances where there is limited or no observable market 
data for the asset or liability, fair value measurements are based 
on internal models, third-party vendor pricing, broker pricing or 
a combination of these sources. The valuation models utilize 
external market information and vendor or broker pricing where 
available, and consider the economic and competitive 
environment, the characteristics of the asset or liability, recent 
prices for products we offer or issue, and other relevant internal 
and external factors. As with any valuation technique used to 
estimate fair value, changes in underlying assumptions used, 
including discount rates and estimates of future cash flows, 
could significantly affect the results of current or future values. 
Accordingly, these fair value estimates may not be realized in an 
actual sale or immediate settlement of the asset or liability. 

Our fair value measurements are adjusted, where necessary, 

to incorporate the lack of market liquidity. Fair value 

measurements based on vendor or broker prices may reflect exit 
prices that inherently consider the lack of market liquidity. 
When the impact of illiquid markets has not already been 
incorporated in the fair value measurement, we adjust the 
vendor or broker price using internal models based on 
discounted cash flows. For certain residential MLHFS and 
certain securities where the significant inputs have become 
unobservable due to illiquid markets and vendor or broker 
pricing is not used, our discounted cash flow model uses a 
discount rate that reflects what we believe a market participant 
would require in light of the illiquid market. 

Where markets are inactive and transactions are not 
orderly, transaction or quoted prices for assets or liabilities in 
inactive markets may require adjustment due to the uncertainty 
of whether the underlying transactions are orderly. For items 
that use price quotes in inactive markets, we analyze the degree 
of market inactivity and distressed transactions to determine the 
appropriate adjustment to the price quotes. 

We continually assess the level and volume of market 
activity in our debt and equity security classes in determining 
adjustments, if any, to price quotes. Given market conditions can 
change over time, our determination of which securities markets 
are considered active or inactive can change. If we determine a 
market to be inactive, the degree to which price quotes require 
adjustment, can also change. See Note 18 (Fair Values of Assets 
and Liabilities) for discussion of the fair value hierarchy and 
valuation methodologies applied to financial instruments to 
determine fair value. 

Private Share Repurchases 
During 2018 and 2017, we repurchased approximately 
94 million shares and approximately 89 million shares of our 
common stock, respectively, under private forward repurchase 
contracts and a written repurchase plan pursuant to Rule 10b5-1 
of the Securities Exchange Act of 1934 that we executed in fourth 
quarter 2018. We enter into these stock repurchase transactions 
to complement our open-market common stock repurchase 
strategies, to allow us to manage our share repurchases in a 
manner consistent with our capital plans, currently submitted 
under the Comprehensive Capital Analysis and Review (CCAR), 
and to provide an economic benefit to the Company. 

Our payments to the counterparties for the private forward 

repurchase contracts are recorded in permanent equity in the 
quarter paid and are not subject to re-measurement. The 
classification of the up-front payments as permanent equity 
assures that we have appropriate repurchase timing consistent 
with our capital plans, which contemplated a fixed dollar 
amount available per quarter for share repurchases pursuant to 
Federal Reserve Board (FRB) supervisory guidance. In return, 
the counterparty agrees to deliver a variable number of shares 
based on a per share discount to the volume-weighted average 
stock price over the contract period. There are no scenarios 
where the contracts would not either physically settle in shares 
or allow us to choose the settlement method. Our total number 
of outstanding shares of common stock is not reduced until 
settlement of the private forward repurchase contract. We had 
no unsettled private forward repurchase contracts at 
December 31, 2018, or December 31, 2017. 

Under the Rule 10b5-1 repurchase plan, payments and 
receipt of repurchased shares settle on the same day and the 
shares repurchased reduce the total number of outstanding 
shares of common stock upon the settlement of each trade under 
the plan. 

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158

 
 
SUPPLEMENTAL CASH FLOW INFORMATION  Noncash 
activities are presented in Table 1.3, including information on 
transfers affecting MLHFS and debt securities. 

Table 1.3:  Supplemental Cash Flow Information 

(in millions) 

Trading debt securities retained from securitizations of MLHFS 

Transfers from loans to MLHFS 

Transfers from available-for-sale debt securities to held-to-maturity debt securities 

Deconsolidation of reverse mortgages previously sold: 

Loans 

Long-term debt 

2018 

$ 

37,265 

5,366 

16,479 

— 

— 

Year ended December 31, 

2017 

52,435 

5,500 

50,405 

— 

— 

2016 

72,399 

6,894 

4,161 

3,807 

3,769 

SUBSEQUENT EVENTS  We have evaluated the effects of events 
that have occurred subsequent to December 31, 2018, and there 
have been no material events that would require recognition in 
our 2018 consolidated financial statements or disclosure in the 
Notes to the consolidated financial statements. On 
February 7, 2019, we experienced system issues caused by an 
automatic power shutdown at one of our main data center 
facilities. This power shutdown was triggered by a smoke alarm 
that resulted from a steam condition created by routine 
maintenance activities in the building. Although applications 
and related workloads were systematically re-routed to back-up 
data centers throughout the day, certain of our services 

experienced disruptions that delayed service to our 
customers. As an example, our online and mobile banking 
systems and certain ATM functions experienced disruptions for 
several hours, and certain critical mortgage origination systems 
experienced disruptions for several days. We are currently 
assessing these system issues and expect that the Company will 
incur costs associated with system enhancements that may be 
necessary to improve the speed of re-routing applications and 
related workloads to back-up data centers, help ensure that 
applications are fully operational to the extent an incident 
occurs, and reduce the likelihood of similar issues occurring in 
the future. 

Note 2:  Business Combinations 

We regularly explore opportunities to acquire financial services 
companies and businesses. Generally, we do not make a public 
announcement about an acquisition opportunity until a 
definitive agreement has been signed. For information on 
additional contingent consideration related to acquisitions, 

which is considered to be a guarantee, see Note 15 (Guarantees, 
Pledged Assets and Collateral, and Other Commitments). 
Business combinations completed in 2017 and 2016 are 
presented in Table 2.1. There were no new acquisitions during 
2018. As of December 31, 2018, we had no pending acquisitions. 

Table 2.1:  Business Combinations Activity 

Name of acquisition 

2017: 

Location 

Type of business 

Date 

Total assets 
(in millions) 

Golden Capital Management, LLC 

Charlotte, NC 

Asset Management 

July 1  $ 

83 

2016: 

GE Railcar Services 

Chicago, IL 

Railcar and locomotive leasing 

January 1  $ 

4,339 

GE Capital’s Commercial Distribution Finance and 

Vendor Finance Businesses 

Analytic Investors, LLC 

North America, Asia, 
Australia / New Zealand and
EMEA 
Los Angeles, CA 

Specialty Lending 

Asset Management 

March 1, July
1, August 1 & 
October 1 
October 1 

32,531 

106 

$ 

36,976 

During 2018, we completed the sale of Wells Fargo 
Shareowner Services in February, the sale of the automobile 
lending business of Reliable Financial Services, Inc. and Reliable 
Finance Holding Company in August, and the sale of 
52 branches in Indiana, Ohio, Michigan and part of Wisconsin in 
November. Included with the branches sale were approximately 
$2.0 billion of deposits. 

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159 

  
 
  
 
Note 3:  Cash, Loan and Dividend Restrictions
 

Cash and cash equivalents may be restricted as to usage or 
withdrawal. Federal Reserve Board (FRB) regulations require 
that each of our subsidiary banks maintain reserve balances on 
deposit with the Federal Reserve Banks. Table 3.1 provides a 
summary of restrictions on cash equivalents in addition to the 
FRB reserve cash balance requirements. 

Table 3.1:  Nature of Restrictions on Cash Equivalents 

(in millions) 

Dec 31,
2018 

Dec 31,
2017 

Average required reserve balance for FRB (1)  $  12,428 

12,306 

Reserve balance for non-U.S. central banks 

517 

617 

Segregated for benefit of brokerage

customers under federal and other 
brokerage regulations 

Related to consolidated variable interest 
entities (VIEs) that can only be used to
settle liabilities of VIEs 

1,135 

666 

147 

487 

(1) 	 FRB required reserve balance represents average for the years ended 

December 31, 2018, and December 31, 2017. 

Federal law restricts the amount and the terms of both 

credit and non-credit transactions between a bank and its 
nonbank affiliates. These covered transactions may not exceed 
10% of the bank’s capital and surplus (which for this purpose 
represents Tier 1 and Tier 2 capital, as calculated under the risk-
based capital (RBC) guidelines, plus the balance of the allowance 
for credit losses excluded from Tier 2 capital) with any single 
nonbank affiliate and 20% of the bank’s capital and surplus with 
all its nonbank affiliates. Transactions that are extensions of 
credit may require collateral to be held to provide added security 
to the bank. For further discussion of RBC, see Note 28 
(Regulatory and Agency Capital Requirements) in this Report. 
Dividends paid by our subsidiary banks are subject to 
various federal and state regulatory limitations. Dividends that 
may be paid by a national bank without the express approval of 
the Office of the Comptroller of the Currency (OCC) are limited 
to that bank’s retained net profits for the preceding two calendar 
years plus retained net profits up to the date of any dividend 
declaration in the current calendar year. Retained net profits, as 
defined by the OCC, consist of net income less dividends 
declared during the period. 

We also have a state-chartered subsidiary bank that is 

subject to state regulations that limit dividends. Under these 
provisions and regulatory limitations, our national and state-
chartered subsidiary banks could have declared additional 
dividends of $15.2 billion at December 31, 2018, without 
obtaining prior regulatory approval. We have elected to retain 
higher capital at our national and state-chartered subsidiary 
banks in order to meet internal capital policy minimums and 
regulatory requirements. Our nonbank subsidiaries are also 
limited by certain federal and state statutory provisions and 
regulations covering the amount of dividends that may be paid 
in any given year. In addition, under a Support Agreement dated 
June 28, 2017, among Wells Fargo & Company, the parent 
holding company (the “Parent”), WFC Holdings, LLC, an 
intermediate holding company and subsidiary of the Parent (the 
“IHC”), and Wells Fargo Bank, N.A., Wells Fargo Securities, 
LLC, and Wells Fargo Clearing Services, LLC, each an indirect 
subsidiary of the Parent, the IHC may be restricted from making 
dividend payments to the Parent if certain liquidity and/or 
capital metrics fall below defined triggers. Based on retained 
earnings at December 31, 2018, our nonbank subsidiaries could 
have declared additional dividends of $24.4 billion at 
December 31, 2018, without obtaining prior approval. 

The FRB’s Capital Plan Rule (codified at 12 CFR 225.8 of 

Regulation Y) establishes capital planning and prior notice and 
approval requirements for capital distributions including 
dividends by certain large bank holding companies. The FRB has 
also published guidance regarding its supervisory expectations 
for capital planning, including capital policies regarding the 
process relating to common stock dividend and repurchase 
decisions in the FRB’s SR Letter 15-18. The effect of this 
guidance is to require the approval of the FRB (or specifically 
under the Capital Plan Rule, a notice of non-objection) for the 
Company to repurchase or redeem common or perpetual 
preferred stock as well as to raise the per share quarterly 
dividend from its current level of $0.45 per share as declared by 
the Company’s Board of Directors on January 22, 2019, payable 
on March 1, 2019. 

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Note 4:  Trading Activities
 

Table 4.1 presents a summary of our trading assets and liabilities 
measured at fair value through earnings. 

Table 4.1:  Trading Activities and Liabilities 

(in millions) 

Trading assets: 

Debt securities 

Equity securities 

Loans held for sale 

Gross trading derivative assets 

Netting (1) 

Total trading derivative assets 

Total trading assets 

Trading liabilities: 

Short sale 

Gross trading derivative liabilities 

Netting (1) 

Total trading derivative liabilities 

Total trading liabilities 

Dec 31,
2018 

Dec 31,
2017 

$ 

69,989 

19,449 

1,469 

29,216 

57,624 

30,004 

1,023 

31,340 

(19,807) 

(19,629) 

9,409 

100,316 

19,720 

28,717 

11,711 

100,362 

18,472 

31,386 

(21,178) 

(23,062) 

7,539 

$ 

27,259 

8,324 

26,796 

(1) 	 Represents balance sheet netting for trading derivative asset and liability balances, and trading portfolio level counterparty valuation adjustments. 

Table 4.2 provides a summary of the net interest income 

earned from trading securities, and net gains and losses due to 

the realized and unrealized gains and losses from trading 
activities. 

Table 4.2:  Net Interest Income and Net Gains (Losses) on Trading Activities 

(in millions) 

Interest income (1): 

Debt securities 

Equity securities 

Loans held for sale 

Total interest income	 

Less: Interest expense (2)	 

Net interest income	 

Net gains (losses) from trading activities: 

Debt securities 

Equity securities 

Loans held for sale 

Derivatives (3) 

Year ended December 31, 

2018 

2017 

2016 

$ 

2,831 

587 

62 

3,480 

587 

2,893 

(824) 

(4,240) 

(1) 

5,667 

602 

3,495 

2,313 

515 

38 

2,866 

416 

2,450 

125 

3,394 

45 

(3,022) 

542 

2,992 

2,047 

383 

29 

2,459 

353 

2,106 

(444) 

1,213 

55 

(214) 

610 

2,716 

Total net gains from trading activities (4)	 

Total trading-related net interest and noninterest income	 

$ 

(1) 	 Represents interest and dividend income earned on trading securities. 
(2) 	 Represents interest and dividend expense incurred on trading securities we have sold but have not yet purchased. 
(3) 	 Excludes economic hedging of mortgage banking and asset/liability management activities, for which hedge results (realized and unrealized) are reported with the 

respective hedged activities. 

(4) 	 Represents realized gains (losses) from our trading activities and unrealized gains (losses) due to changes in fair value of our trading positions, attributable to the type of 

asset or liability. 

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161 

 
  
 
 
Note 5:  Available-for-Sale and Held-to-Maturity Debt Securities 

Table 5.1 provides the amortized cost and fair value by major 
categories of available-for-sale debt securities, which are carried 
at fair value, and held-to-maturity debt securities, which are 
carried at amortized cost. The net unrealized gains (losses) for 

available-for-sale debt securities are reported on an after-tax 
basis as a component of cumulative OCI. Information on debt 
securities held for trading is included in Note 4 (Trading 
Activities) to Financial Statements in this Report. 

Table 5.1:  Amortized Cost and Fair Value 

(in millions) 

December 31, 2018 

Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions (1) 
Mortgage-backed securities: 

Federal agencies 
Residential 

Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other debt obligations (2) 

Other (3) 

 Amortized 
Cost 

Gross 
unrealized 
gains 

Gross
unrealized 
losses 

Fair value 

$ 

13,451 

48,994 

155,974 
2,638 

4,207 

162,819 

6,230 

35,581 

5,396 

3 

716 

369 
142 

40 

551 

131 

158 

100 

(106) 

(446) 

(3,140) 
(5) 

(22) 

(3,167) 

(90) 

(396) 

(13) 

13,348 

49,264 

153,203 
2,775 

4,225 

160,203 

6,271 

35,343 

5,483 

Total available-for-sale debt securities 

272,471 

1,659 

(4,218) 

269,912 

Held-to-maturity debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions 

Federal agency and other mortgage-backed securities (4) 

Collateralized loan obligations 

Other (3) 

Total held-to-maturity debt securities 

Total (5) 

December 31, 2017 

Available-for-sale debt securities: 

44,751 

6,286 

93,685 

66 

— 

144,788 

4 

30 

112 

— 

— 

146 

$ 

417,259 

1,805 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions (1) 

Mortgage-backed securities: 

$ 

Federal agencies 

Residential 

Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other debt obligations (2) 

Other (3) 

Total available-for-sale debt securities 

Held-to-maturity debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions 

Federal agency and other mortgage-backed securities (4) 

Collateralized loan obligations 

Other (3) 

Total held-to-maturity debt securities 

6,425 

50,733 

160,561 

4,356 
4,487 

169,404 

7,343 

35,675 

5,516 

275,096 

44,720 

6,313 

87,527 

661 

114 

139,335 

2 

1,032 

930 

254 
80 

1,264 

363 

384 

137 

189 

84 

201 

4 

— 

478 

(415) 

(116) 

(2,288) 

— 

— 

(2,819) 

(7,037) 

(108) 

(439) 

(1,272) 

(2) 
(2) 

(1,276) 

(40) 

(3) 

(5) 

44,340 

6,200 

91,509 

66 

— 

142,115 

412,027 

6,319 

51,326 

160,219 

4,608 
4,565 

169,392 

7,666 

36,056 

5,648 

(103) 

(43) 

(682) 

— 

— 

(828) 

(2,699) 

44,806 

6,354 

87,046 

665 

114 

138,985 

415,392 

3,182 

(1,871) 

276,407 

Total (5) 

$ 

414,431 

3,660 

(1)  Available-for-sale debt securities include investments in tax-exempt preferred debt securities issued by investment funds or trusts that predominantly invest in tax-exempt 

municipal securities. The cost basis and fair value of these types of securities was $6.3 billion each at December 31, 2018, and $5.2 billion each at December 31, 2017. 

(2)  Available-for-sale debt securities include collateralized debt obligations (CDOs) with a cost basis and fair value of $662 million and $800 million, respectively, at 

December 31, 2018, and $887 million and $1.0 billion, respectively, at December 31, 2017. 

(3)  The “Other” category of available-for-sale debt securities largely includes asset-backed securities collateralized by student loans. Included in the “Other” category of held-

to-maturity debt securities are asset-backed securities collateralized by automobile leases or loans and cash with a cost basis and fair value of $0 million each at 
December 31, 2018, and $114 million each at December 31, 2017. 

(4)  Predominantly consists of federal agency mortgage-backed securities at both December 31, 2018, and December 31, 2017. 
(5)  At December 31, 2018 and 2017, we held no securities of any single issuer (excluding the U.S. Treasury and federal agencies and government-sponsored entities (GSEs)) 

with a book value that exceeded 10% of stockholder’s equity. 

162 

Wells Fargo & Company 

162

  
 
Gross Unrealized Losses and Fair Value 
Table 5.2 shows the gross unrealized losses and fair value of 
available-for-sale and held-to-maturity debt securities by length 
of time those individual securities in each category have been in 
a continuous loss position. Debt securities on which we have 

taken credit-related OTTI write-downs are categorized as being 
“less than 12 months” or “12 months or more” in a continuous 
loss position based on the point in time that the fair value 
declined to below the cost basis and not the period of time since 
the credit-related OTTI write-down. 

Table 5.2:  Gross Unrealized Losses and Fair Value 

(in millions) 

December 31, 2018 

Less than 12 months 

12 months or more 

Total 

Gross 
unrealized 
losses 

Fair value 

Gross 
unrealized 
losses 

Fair value 

Gross 
unrealized 
losses 

Fair value 

Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
Mortgage-backed securities: 

$ 

Federal agencies 
Residential 
Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other debt obligations 
Other 

Total available-for-sale debt securities 

Held-to-maturity debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
 Federal agency and other mortgage-backed

securities 

Collateralized loan obligations

Total held-to-maturity debt securities 

(1) 
(73) 

(42) 
(3) 
(20) 
(65) 

(64) 

(388) 
(7) 
(598) 

(3) 
(4) 

(5) 

— 
(12) 

498 
9,746 

10,979 
398 
1,972 
13,349 

1,965 

28,306 
819 
54,683 

895 
598 

4,635 

— 
6,128 

(105) 
(373) 

6,204 
9,017 

(106) 
(446) 

6,702 
18,763 

(3,098) 
(2) 
(2)
(3,102) 

112,252 
69 
 79
112,400 

(3,140) 
(5) 
 (22) 
(3,167) 

123,231 
467 
2,051 
125,749 

(26) 

298 

(90) 

2,263 

(8) 
(6) 
(3,620) 

553 
159 
128,631 

(396) 
(13) 
(4,218) 

28,859 
978 
183,314 

(412) 
(112) 

41,083 
3,992 

(415) 
(116) 

41,978 
4,590

(2,283) 

77,741 

(2,288) 

82,376 

— 

(2,807) 

— 
122,816 

— 

(2,819) 

— 
128,944 

Total 

$ 

(610) 

60,811 

(6,427) 

251,447 

(7,037) 

312,258 

December 31, 2017 

Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
Mortgage-backed securities: 

$ 

Federal agencies 
Residential 
Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other debt obligations 
Other 

Total available-for-sale debt securities 

Held-to-maturity debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
Federal agency and other mortgage-backed securities 

Collateralized loan obligations

Total held-to-maturity debt securities 

Total 

$ 

(27) 
(17) 

(243) 
(1) 
(1) 
(245) 

(4) 

(1) 
(1) 
(295) 

(69) 
(5) 
(198) 

— 
(272) 

(567) 

4,065 
6,179 

52,559 
47 
101 
52,707 

239 

373 
37 
63,600 

11,255 
500 
29,713 

— 
41,468 

(81) 
(422) 

(1,029) 
(1) 
(1) 
(1,031) 

(36) 

(2) 
(4) 
(1,576) 

(34) 
(38) 
(484) 

— 
(556) 

105,068 

(2,132) 

2,209 
11,766 

44,691 
58 
133 
44,882 

503 

146 
483 
59,989 

1,490 
1,683 
28,244 

— 
31,417 

91,406 

(108) 
(439) 

(1,272) 
(2) 
(2) 
(1,276) 

(40) 

(3) 
(5) 
(1,871) 

(103) 
(43) 
(682) 

— 
(828) 

6,274 
17,945 

97,250 
105 
234 
97,589 

742 

519 
520 
123,589 

12,745 
2,183 
57,957 

— 
72,885 

(2,699) 

196,474 

163

Wells Fargo & Company 

163 

  
 
 
Note 5:  Available-for-Sale and Held-to Maturity Debt Securities (continued) 

CORPORATE DEBT SECURITIES  The unrealized losses 
associated with corporate debt securities are predominantly 
related to unsecured debt obligations issued by various 
corporations. We evaluate the financial performance of each 
issuer on a quarterly basis to determine if the issuer can make all 
contractual principal and interest payments. Based upon this 
assessment, we expect to recover the entire amortized cost basis 
of these securities. 

COLLATERALIZED LOAN AND OTHER DEBT OBLIGATIONS 
The unrealized losses associated with collateralized loan and 
other debt obligations relate to securities predominantly backed 
by commercial collateral. The unrealized losses are typically 
driven by changes in projected collateral losses, credit spreads 
and interest rates. We assess for credit impairment by estimating 
the present value of expected cash flows. The key assumptions 
for determining expected cash flows include default rates, loss 
severities and prepayment rates. We also consider cash flow 
forecasts and, as applicable, independent industry analyst 
reports and forecasts, sector credit ratings, and other 
independent market data. Based upon our assessment of the 
expected credit losses and the credit enhancement level of the 
securities, we expect to recover the entire amortized cost basis of 
these securities. 

OTHER DEBT SECURITIES  The unrealized losses associated 
with other debt securities predominantly relate to other asset-
backed securities. The losses are usually driven by changes in 
projected collateral losses, credit spreads and interest rates. We 
assess for credit impairment by estimating the present value of 
expected cash flows. The key assumptions for determining 
expected cash flows include default rates, loss severities and 
prepayment rates. Based upon our assessment of the expected 
credit losses and the credit enhancement level of the securities, 
we expect to recover the entire amortized cost basis of these 
securities. 

OTHER DEBT SECURITIES MATTERS  The fair values of our 
debt securities could decline in the future if the underlying 
performance of the collateral for the residential and commercial 
MBS or other securities deteriorate, and our credit enhancement 
levels do not provide sufficient protection to our contractual 
principal and interest. As a result, there is a risk that significant 
OTTI may occur in the future. 

We have assessed each debt security with gross unrealized 
losses included in the previous table for credit impairment. As 
part of that assessment we evaluated and concluded that we do 
not intend to sell any of the debt securities and that it is more 
likely than not that we will not be required to sell prior to 
recovery of the amortized cost basis. We evaluate, where 
necessary, whether credit impairment exists by comparing the 
present value of the expected cash flows to the debt securities’ 
amortized cost basis. 

For descriptions of the factors we consider when analyzing 

debt securities for impairment, see Note 1 (Summary of 
Significant Accounting Policies) and below. 

SECURITIES OF U.S. TREASURY AND FEDERAL AGENCIES 
AND FEDERAL AGENCY MORTGAGE-BACKED SECURITIES 
(MBS)  The unrealized losses associated with U.S. Treasury and 
federal agency securities and federal agency MBS are generally 
driven by changes in interest rates and not due to credit losses 
given the explicit or implicit guarantees provided by the U.S. 
government. 

SECURITIES OF U.S. STATES AND POLITICAL 
SUBDIVISIONS  The unrealized losses associated with securities 
of U.S. states and political subdivisions are usually driven by 
changes in the relationship between municipal and term funding 
credit curves rather than by changes to the credit quality of the 
underlying securities. Substantially all of these investments with 
unrealized losses are investment grade. The securities were 
generally underwritten in accordance with our own investment 
standards prior to the decision to purchase. Some of these 
securities are guaranteed by a bond insurer, but we did not rely 
on this guarantee when making our investment decision. These 
investments will continue to be monitored as part of our ongoing 
impairment analysis but are expected to perform, even if the 
rating agencies reduce the credit rating of the bond insurers. As 
a result, we expect to recover the entire amortized cost basis of 
these securities. 

RESIDENTIAL AND COMMERCIAL MBS  The unrealized losses 
associated with private residential MBS and commercial MBS 
are generally driven by changes in projected collateral losses, 
credit spreads and interest rates. We assess for credit 
impairment by estimating the present value of expected cash 
flows. The key assumptions for determining expected cash flows 
include default rates, loss severities and/or prepayment rates. 
We estimate security losses by forecasting the underlying 
mortgage loans in each transaction. We use forecasted loan 
performance to project cash flows to the various tranches in the 
structure. We also consider cash flow forecasts and, as 
applicable, independent industry analyst reports and forecasts, 
sector credit ratings, and other independent market data. Based 
upon our assessment of the expected credit losses and the credit 
enhancement level of the securities, we expect to recover the 
entire amortized cost basis of these securities. 

164 

Wells Fargo & Company 

164

 
 
Table 5.3 shows the gross unrealized losses and fair value of 

the available-for-sale and held-to-maturity debt securities by 
those rated investment grade and those rated less than 
investment grade, according to their lowest credit rating by 
Standard & Poor’s Rating Services (S&P) or Moody’s Investors 
Service (Moody’s). Credit ratings express opinions about the 
credit quality of a debt security. Debt securities rated investment 
grade, that is those rated BBB- or higher by S&P or Baa3 or 
higher by Moody’s, are generally considered by the rating 
agencies and market participants to be low credit risk. 
Conversely, debt securities rated below investment grade, 
labeled as “speculative grade” by the rating agencies, are 
considered to be distinctively higher credit risk than investment 

grade debt securities. We have also included debt securities not 
rated by S&P or Moody’s in the table below based on our internal 
credit grade of the debt securities (used for credit risk 
management purposes) equivalent to the credit rating assigned 
by major credit agencies. The unrealized losses and fair value of 
unrated debt securities categorized as investment grade based on 
internal credit grades were $20 million and $5.2 billion, 
respectively, at December 31, 2018, and $32 million and $6.9 
billion, respectively, at December 31, 2017. If an internal credit 
grade was not assigned, we categorized the debt security as non-
investment grade. 

Table 5.3:  Gross Unrealized Losses and Fair Value by Investment Grade 

Investment grade 

Non-investment grade 

Gross 
unrealized 
losses 

Fair value 

Gross 
unrealized 
losses 

Fair value 

(in millions) 

December 31, 2018 

Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions 

Mortgage-backed securities: 

Federal agencies 

Residential 

Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other debt obligations 

Other 

$ 

(106) 

(425) 

6,702 

18,447 

(3,140) 

123,231 

(2) 

(20) 

295 

1,999 

(3,162) 

125,525 

(17) 

(396) 

(7) 

791 

28,859 

726 

Total available-for-sale debt securities 

(4,113) 

181,050 

Held-to-maturity debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions 

Federal agency and other mortgage-backed securities 

Collateralized loan obligations

Total held-to-maturity debt securities 

Total 

December 31, 2017 

Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions 

Mortgage-backed securities: 

Federal agencies 

Residential 

Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other debt obligations 

Other 

$ 

$ 

(415) 

(116) 

(2,278) 

—

(2,809) 

(6,922) 

41,978 

4,590 

81,977 

 —

128,545 

309,595 

(108) 

(412) 

6,274 

17,763 

(1,272) 

97,250 

(1) 

(1) 

42 

183 

(1,274) 

97,475 

(13) 

(3) 

(2) 

304 

519 

469 

Total available-for-sale debt securities 

(1,812) 

122,804 

Held-to-maturity debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions 

Federal agency and other mortgage-backed securities 

Collateralized loan obligations

Total held-to-maturity debt securities 

Total 

$ 

(103) 

(43) 

(680) 

—

(826) 

(2,638) 

12,745 

2,183 

57,789 

 —

72,717 

195,521 

— 

(21) 

— 

(3) 

(2)

(5) 

(73) 

— 

(6) 

(105) 

— 

— 

(10) 

 —

(10) 

(115) 

— 

(27) 

— 

(1) 

(1) 

(2) 

(27) 

— 

(3) 

(59) 

— 

— 

(2) 

 —

(2) 

(61) 

— 

316 

— 

172 

 52

224 

1,472 

— 

252 

2,264 

— 

— 

399 

 —

399 

2,663 

— 

182 

— 

63 

51 

114 

438 

— 

51 

785 

— 

— 

168 

 —

168 

953 

165

Wells Fargo & Company 

165 

  
 
 
 
 
 
 
Note 5:  Available-for-Sale and Held-to Maturity Debt Securities (continued) 

Contractual Maturities 
Table 5.4 shows the remaining contractual maturities and 
contractual weighted-average yields (taxable-equivalent basis) of 
available-for-sale debt securities. The remaining contractual 

principal maturities for MBS do not consider prepayments. 
Remaining expected maturities will differ from contractual 
maturities because borrowers may have the right to prepay 
obligations before the underlying mortgages mature. 

Table 5.4:  Contractual Maturities 

(in millions) 

December 31, 2018 

Available-for-sale debt securities (1): 

Fair value: 

Securities of U.S. Treasury and federal

agencies 

Securities of U.S. states and political

subdivisions 

Mortgage-backed securities: 

Total 

Within one year 

After one year 
through five years 

After five years 
through ten years 

After ten years 

amount 

Yield 

Amount 

Yield 

Amount 

Yield 

Amount 

Yield 

Amount 

Yield 

Remaining contractual maturity 

$ 

13,348 

1.87%  $  1,087 

1.52%  $  12,213 

1.90%  $ 

48 

1.89%  $ 

— 

—% 

49,264 

4.78 

3,568 

2.92 

6,644 

3.42 

4,635 

3.44 

34,417 

5.42 

Federal agencies 

Residential 
Commercial 

153,203 

2,775 
4,225 

Total mortgage-backed securities 

160,203 

3.42 

4.01 
3.64 

3.44 

5.11 

3.89 

3.17 

— 

— 
— 

— 

— 

— 
— 

— 

169 

14 
— 

3.52 

5.85 
— 

1,909 

6 
342 

2.56 

3.04 
3.60 

151,125 

2,755 
3,883 

3.43 

4.00 
3.65 

183 

3.70 

2,257 

2.72 

157,763 

3.45 

390 

6.27 

2,525 

5.25 

2,743 

4.68 

613 

5.67 

— 

— 

28 

4.18 

8,866 

3.91 

26,449 

3.89 

15 

6.02 

818 

3.84 

1,446 

2.17 

3,204 

3.44 

6,271 

35,343 

5,483 

Corporate debt securities 

Collateralized loan and other debt 

obligations 

Other 

Total available-for-sale debt 
securities at fair value 

December 31, 2017 

Available-for-sale debt securities (1): 

Fair value: 

Securities of U.S. Treasury and federal 

agencies 

Securities of U.S. states and political

subdivisions 

Mortgage-backed securities: 

Federal agencies 

Residential 

Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other debt obligations 

Other 

Total available-for-sale debt 
securities at fair value 

$  269,912 

3.70%  $  5,060 

2.89%  $  22,411 

2.82%  $  19,995 

3.64%  $222,446 

3.81% 

$ 

6,319 

1.59 %  $ 

81 

1.37 %  $ 

6,189 

1.59 %  $ 

49 

1.89 %  $ 

— 

— % 

51,326 

5.88 

2,380 

3.47 

9,484 

3.42 

2,276 

4.63 

37,186 

6.75 

160,219 

4,608 

4,565 

169,392 

7,666 

36,056 

5,648 

3.27 

3.52 

3.45 

3.28 

5.12 

2.98 

2.46 

15 

— 

— 

15 

2.03 

— 

— 

2.03 

210 

24 

— 

3.08 

5.67 

— 

234 

3.35 

5,534 

11 

166 

5,711 

2.82 

2.46 

2.69 

2.82 

154,460 

4,573 

4,399 

163,432 

3.28 

3.51 

3.48 

3.30 

443 

5.54 

2,738 

5.56 

3,549 

4.70 

936 

5.26 

— 

71 

— 

3.56 

50 

463 

1.68 

2.72 

15,008 

1,466 

2.96 

2.13 

20,998 

3,648 

3.00 

2.53 

$ 

276,407 

3.72 %  $ 

2,990 

3.70 %  $  19,158 

3.11 %  $  28,059 

3.24 %  $  226,200 

3.83 % 

(1)  Weighted-average yields displayed by maturity bucket are weighted based on fair value and predominantly represent contractual coupon rates without effect for any related 

hedging derivatives. 

166 

Wells Fargo & Company 

166

  
 
Table 5.5 shows the amortized cost and weighted-average 

yields of held-to-maturity debt securities by contractual 
maturity. 

Table 5.5:  Amortized Cost by Contractual Maturity 

(in millions) 

December 31, 2018 

Held-to-maturity debt securities (1): 

Amortized cost: 

Securities of U.S. Treasury and

federal agencies 

Securities of U.S. states and 
political subdivisions 

Federal agency and other

mortgage-backed securities 

Collateralized loan obligations 

Other 

$ 

44,751 

2.12% 

$ 

6,286 

4.93 

93,685 

66 

— 

3.10 

3.62 

— 

Total held-to-maturity debt

securities at amortized cost 

$ 

144,788 

2.87%  $ 

December 31, 2017 

Held-to-maturity debt securities (1): 

Amortized cost: 

Securities of U.S. Treasury and federal 

agencies 

$ 

44,720 

2.12 % 

$ 

Securities of U.S. states and political

subdivisions 

Federal agency and other mortgage-

backed securities 

Collateralized loan obligations 

Other 

6,313 

6.02 

87,527 

661 

114 

3.11 

2.86 

1.83 

Total held-to-maturity debt

securities at amortized cost 

$ 

139,335 

2.92 %  $ 

Total 

Within one year 

After one year
through five years 

After five years
through ten years 

After ten years 

amount 

Yield 

Amount 

Yield 

Amount 

Yield 

Amount 

Yield 

Amount 

Yield 

Remaining contractual maturity 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

—% 

$  32,356 

2.04% 

$  12,395 

2.32%  $ 

— 

—% 

— 

— 

— 

— 

72 

6.04 

1,188 

4.91 

5,026 

4.92 

26 

3.52 

— 

— 

— 

— 

— 

66 
— 

— 

93,659 

3.10 

3.62 
— 

— 
— 

— 
— 

—%  $  32,454 

2.05%  $  13,649 

2.55%  $  98,685 

3.19% 

— % 

$  32,330 

2.04 % 

$  12,390 

2.32 % 

$ 

— 

— % 

— 

— 

— 

— 

50 

7.18 

695 

6.31 

5,568 

5.98 

15 

— 

114 

2.81 

— 

1.83 

11 

661 

— 

2.49 

2.86 

— 

87,501 

3.11 

— 

— 

— 

— 

— %  $  32,509 

2.05 %  $  13,757 

2.55 %  $  93,069 

3.28 % 

(1)  Weighted-average yields displayed by maturity bucket are weighted based on amortized cost and predominantly represent contractual coupon rates. 

Table 5.6 shows the fair value of held-to-maturity debt 

securities by contractual maturity. 

Table 5.6:  Fair Value by Contractual Maturity 

(in millions) 

December 31, 2018 

Held-to-maturity debt securities: 

Fair value: 

Total 

Within one 
year 

After one year
through five years 

After five years
through ten years 

After ten years 

amount 

Amount 

Amount 

Amount 

Amount 

Remaining contractual maturity 

Securities of U.S. Treasury and federal agencies 

$ 

44,340 

Securities of U.S. states and political subdivisions 

Federal agency and other mortgage-backed securities 

Collateralized loan obligations 

Other 

6,200 

91,509 

66 

— 

Total held-to-maturity debt securities at fair value 

$ 

142,115 

December 31, 2017 

Held-to-maturity debt securities: 

Fair value: 

Securities of U.S. Treasury and federal agencies 

$ 

Securities of U.S. states and political subdivisions 

Federal agency and other mortgage-backed securities 

Collateralized loan obligations 

Other 

44,806 

6,354 

87,046 

665 

114 

Total held-to-maturity debt securities at fair value 

$ 

138,985 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

32,073 

70 

26 

— 

— 

12,267 

1,191 

— 

66 

— 

— 

4,939 

91,483 

— 

— 

32,169 

13,524 

96,422 

32,388 

12,418 

49 

15 

— 

114 

701 

11 

665 

— 

32,566 

13,795 

— 

5,604 

87,020 

— 

— 

92,624 

167

Wells Fargo & Company 

167 

  
 
  
 
 
 
Note 5:  Available-for-Sale and Held-to Maturity Debt Securities (continued) 

Realized Gains and Losses 
Table 5.7 shows the gross realized gains and losses on sales and 
OTTI write-downs related to available-for-sale debt securities. 

Table 5.7:  Realized Gains and Losses 

(in millions) 

Gross realized gains 

Gross realized losses 

OTTI write-downs 

Net realized gains from available-for-sale debt securities 

Year ended December 31, 

2018 

$ 

155 

(19) 

(28) 

$ 

108 

2017 

948 

(207) 

(262) 

479 

2016 

1,234 

(103) 

(189) 

942 

Other-Than-Temporary Impaired Debt Securities 
Table 5.8 shows the detail of total OTTI write-downs included in 
earnings for available-for-sale debt securities. There were no 

OTTI write-downs on held-to-maturity debt securities during the 
years ended December 31, 2018, 2017 or 2016. 

Table 5.8:  Detail of OTTI Write-downs 

(in millions) 

Debt securities OTTI write-downs included in earnings: 

Securities of U.S. states and political subdivisions 

Mortgage-backed securities: 

Residential 

Commercial 

Corporate debt securities 

Other debt securities 

Total debt securities OTTI write-downs included in earnings 

Table 5.9 shows the detail of OTTI write-downs on 
available-for-sale debt securities included in earnings and the 
related changes in OCI for the same securities. 

Table 5.9:  OTTI Write-downs Included in Earnings and the Related Changes in OCI 

(in millions) 

OTTI on debt securities 

Recorded as part of gross realized losses: 

Credit-related OTTI 

Intent-to-sell OTTI 

Total recorded as part of gross realized losses 

Changes to OCI for losses (reversal of losses) in non-credit-related OTTI (1): 

Securities of U.S. states and political subdivisions 

Residential mortgage-backed securities 

Commercial mortgage-backed securities 

Corporate debt securities 

Other debt securities 

Total changes to OCI for non-credit-related OTTI 

Year ended December 31, 

2018 

2017 

2016 

$

2 

150 

63 

34 

14 

72 

6 

4 

18 

— 

4 

28

11 

80 

21 

—

262 

189 

$

$ 

Year ended December 31, 

2018 

2017 

2016 

27

1 

28 

(2) 

2 

(11) 

— 

— 

(11) 

119 

143 

262 

(5) 

(1) 

(51) 

1 

(1) 

(57) 

205 

143 

46 

189 

8 

(3) 

24 

(13) 

2 

18 

207 

Total OTTI losses (reversal of losses) recorded on debt securities 

$

17

(1)  Represents amounts recorded to OCI for impairment of debt securities, due to factors other than credit, that have also had credit-related OTTI write-downs during the 

period. Increases represent initial or subsequent non-credit-related OTTI on debt securities. Decreases represent partial to full reversal of impairment due to recoveries in 
the fair value of debt securities due to non-credit factors. 

168 

Wells Fargo & Company 

168

  
 
  
 
  
 
 
 
 
 
 
Table 5.10 presents a rollforward of the OTTI credit loss that 
has been recognized in earnings as a write-down of available-for-
sale debt securities we still own (referred to as “credit-impaired” 
debt securities) and do not intend to sell. Recognized credit loss 
represents the difference between the present value of expected 

Table 5.10:  Rollforward of OTTI Credit Loss 

(in millions) 

Credit loss recognized, beginning of year 

Additions: 

For securities with initial credit impairments 

For securities with previous credit impairments 

Total additions 

Reductions: 

For securities sold, matured, or intended/required to be sold 

For recoveries of previous credit impairments (1) 

Total reductions 

Credit loss recognized, end of year 

future cash flows discounted using the security’s current 
effective interest rate and the amortized cost basis of the security 
prior to considering credit loss. 

Year ended December 31, 

2018 

$ 

742 

2017 

1,043 

2016 

1,092 

1 

26 

27 

9 

110 

119 

85 

58 

143 

(204) 

(414) 

(184) 

(3) 

(6) 

(8) 

(207) 

(420) 

(192) 

$ 

562 

742 

1,043 

(1)  Recoveries of previous credit impairments result from increases in expected cash flows subsequent to credit loss recognition. Such recoveries are reflected prospectively as 

interest yield adjustments using the effective interest method. 

169

Wells Fargo & Company 

169 

  
 
Note 6:  Loans and Allowance for Credit Losses 

Table 6.1 presents total loans outstanding by portfolio segment 
and class of financing receivable. Outstanding balances include a 
total net reduction of $1.3 billion and $3.9 billion at 
December 31, 2018 and 2017, respectively, for unearned income, 

net deferred loan fees, and unamortized discounts and 
premiums, which among other things, reflect the 
impact of various loan sales. 

Table 6.1:  Loans Outstanding 

(in millions) 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer 

Total loans 

Our foreign loans are reported by respective class of 
financing receivable in the table above. Substantially all of our 
foreign loan portfolio is commercial loans. Loans are classified 
as foreign primarily based on whether the borrower’s primary 

Table 6.2:  Commercial Foreign Loans Outstanding 

(in millions) 

Commercial foreign loans: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

2018 

2017 

2016 

2015 

2014 

December 31, 

$  350,199 

333,125 

330,840 

299,892 

271,795 

121,014 

126,599 

132,491 

122,160 

111,996 

22,496 

19,696 

24,279 

19,385 

23,916 

19,289 

22,164 

12,367 

18,728 

12,307 

513,405 

503,388 

506,536 

456,583 

414,826 

285,065 

284,054 

275,579 

273,869 

265,386 

34,398 

39,025 

45,069 

36,148 

39,713 

37,976 

53,371 

38,268 

46,237 

36,700 

62,286 

40,266 

53,004 

34,039 

59,966 

39,098 

59,717 

31,119 

55,740 

35,763 

439,705 

453,382 

461,068 

459,976 

447,725 

$ 

953,110 

956,770 

967,604 

916,559 

862,551 

address is outside of the United States. Table 6.2 presents total 
commercial foreign loans outstanding by class of financing 
receivable. 

2018 

2017 

2016 

2015 

2014 

December 31, 

$ 

62,564 

60,106 

6,731 

1,011 

1,159 

8,033 

655 

1,126 

55,396 

8,541 

375 

972 

49,049 

8,350 

444 

274 

44,707 

4,776 

218 

336 

Total commercial foreign loans 

$ 

71,465 

69,920 

65,284 

58,117 

50,037 

170 

Wells Fargo & Company 

170

  
 
  
 
Loan Concentrations 
Loan concentrations may exist when there are amounts loaned 
to borrowers engaged in similar activities or similar types of 
loans extended to a diverse group of borrowers that would cause 
them to be similarly impacted by economic or other conditions. 
At December 31, 2018 and 2017, we did not have concentrations 
representing 10% or more of our total loan portfolio in domestic 
commercial and industrial loans and lease financing by industry 
or CRE loans (real estate mortgage and real estate construction) 
by state or property type. Real estate 1-4 family non-PCI 
mortgage loans to borrowers in the state of California 
represented 12% of total loans at both December 31, 2018 and 
2017, and PCI loans were under 1% in both years. These 
California loans are generally diversified among the larger 
metropolitan areas in California, with no single area consisting 
of more than 5% of total loans. We continuously monitor 
changes in real estate values and underlying economic or market 
conditions for all geographic areas of our real estate 1-4 family 
mortgage portfolio as part of our credit risk management 
process. 

Some of our real estate 1-4 family first and junior lien 
mortgage loans include an interest-only feature as part of the 
loan terms. These interest-only loans were approximately 4% of 
total loans at both December 31, 2018 and 2017. Substantially all 
of these interest-only loans at origination were considered to be 
prime or near prime. We do not offer option adjustable-rate 
mortgage (ARM) products, nor do we offer variable-rate 
mortgage products with fixed payment amounts, commonly 
referred to within the financial services industry as negative 
amortizing mortgage loans. We acquired an option payment loan 
portfolio (Pick-a-Pay) from Wachovia at December 31, 2008. A 
majority of the portfolio was identified as PCI loans. Since the 
acquisition, we have reduced our exposure to the option 
payment portion of the portfolio through our modification 
efforts and loss mitigation actions. At December 31, 2018, 
approximately 1% of total loans remained with the payment 
option feature compared with 10% at December 31, 2008. 

Our first and junior lien lines of credit products generally 
have draw periods of 10, 15 or 20 years, with variable interest 
rate and payment options during the draw period of (1) interest 
only or (2) 1.5% of total outstanding balance plus accrued 

Table 6.3:  Loan Purchases, Sales, and Transfers 

interest. During the draw period, the borrower has the option of 
converting all or a portion of the line from a variable interest rate 
to a fixed rate with terms including interest-only payments for a 
fixed period between three to seven years or a fully amortizing 
payment with a fixed period between five to 30 years. At the end 
of the draw period, a line of credit generally converts to an 
amortizing payment schedule with repayment terms of up to 
30 years based on the balance at time of conversion. At 
December 31, 2018, our lines of credit portfolio had an 
outstanding balance of $43.6 billion, of which $11.1 billion, or 
25%, is in its amortization period, another $1.3 billion, or 3%, of 
our total outstanding balance, will reach their end of draw period 
during 2019 through 2020, $11.3 billion, or 26%, during 2021 
through 2023, and $19.9 billion, or 46%, will convert in 
subsequent years. This portfolio had unfunded credit 
commitments of $60.1 billion at December 31, 2018. The lines 
that enter their amortization period may experience higher 
delinquencies and higher loss rates than the lines in their draw 
period. At December 31, 2018, $488 million, or 4%, of 
outstanding lines of credit that are in their amortization period 
were 30 or more days past due, compared with $553 million, or 
2%, for lines in their draw period. We have considered this 
increased inherent risk in our allowance for credit loss estimate. 
In anticipation of our borrowers reaching the end of their 
contractual commitment, we have created a program to inform, 
educate and help these borrowers transition from interest-only 
to fully-amortizing payments or full repayment. We monitor the 
performance of the borrowers moving through the program in 
an effort to refine our ongoing program strategy. 

Loan Purchases, Sales, and Transfers 
Table 6.3 summarizes the proceeds paid or received for 
purchases and sales of loans and transfers from loans held for 
investment to mortgages/loans held for sale at lower of cost or 
fair value. This loan activity primarily includes loans purchased 
and sales of whole loan or participating interests, whereby we 
receive or transfer a portion of a loan after origination. The table 
excludes PCI loans and loans recorded at fair value, including 
loans originated for sale because their loan activity normally 
does not impact the allowance for credit losses. 

(in millions) 

Purchases 

Sales 

Transfers to MLHFS/LHFS 

$ 

Commercial 

Consumer (1) 

2,065 

(1,905) 

(617) 

16 

(261) 

(1,995) 

2018 

Total 

2,081 

(2,166) 

(2,612) 

Year ended December 31, 

Commercial 

Consumer (1) 

3,675 

(2,066) 

(736) 

2 

(425) 

(2) 

2017 

Total 

3,677 

(2,491) 

(738) 

(1)  Excludes activity in government insured/guaranteed real estate 1-4 family first mortgage loans. As servicer, we are able to buy delinquent insured/guaranteed loans out of 
the Government National Mortgage Association (GNMA) pools, and manage and/or resell them in accordance with applicable requirements. These loans are predominantly 
insured by the Federal Housing Administration (FHA) or guaranteed by the Department of Veterans Affairs (VA). Accordingly, these loans have limited impact on the 
allowance for loan losses. 

171

Wells Fargo & Company 

171 

 
  
 
  
Note 6:  Loans and Allowance for Credit Losses (continued) 

Commitments to Lend 
A commitment to lend is a legally binding agreement to lend 
funds to a customer, usually at a stated interest rate, if funded, 
and for specific purposes and time periods. We generally require 
a fee to extend such commitments. Certain commitments are 
subject to loan agreements with covenants regarding the 
financial performance of the customer or borrowing base 
formulas on an ongoing basis that must be met before we are 
required to fund the commitment. We may reduce or cancel 
consumer commitments, including home equity lines and credit 
card lines, in accordance with the contracts and applicable law. 
We may, as a representative for other lenders, advance 

funds or provide for the issuance of letters of credit under 
syndicated loan or letter of credit agreements. Any advances are 
generally repaid in less than a week and would normally require 
default of both the customer and another lender to expose us to 
loss. These temporary advance arrangements totaled 
approximately $91 billion at December 31, 2018, and $85 billion 
at December 31, 2017. 

We issue commercial letters of credit to assist customers in 

purchasing goods or services, typically for international trade. At 
December 31, 2018 and 2017, we had $919 million and 
$982 million, respectively, of outstanding issued commercial 
letters of credit. We also originate multipurpose lending 
commitments under which borrowers have the option to draw 
on the facility for different purposes in one of several forms, 
including a standby letter of credit. See Note 15 (Guarantees, 
Pledged Assets and Collateral, and Other Commitments) for 
additional information on standby letters of credit. 

When we make commitments, we are exposed to credit risk. 

The maximum credit risk for these commitments will generally 
be lower than the contractual amount because a significant 
portion of these commitments are expected to expire without 
being used by the customer. In addition, we manage the 
potential risk in commitments to lend by limiting the total 
amount of commitments, both by individual customer and in 
total, by monitoring the size and maturity structure of these 
commitments and by applying the same credit standards for 
these commitments as for all of our credit activities. 

For loans and commitments to lend, we generally require 

collateral or a guarantee. We may require various types of 
collateral, including commercial and consumer real estate, 
automobiles, other short-term liquid assets such as accounts 
receivable or inventory and long-lived assets, such as equipment 
and other business assets. Collateral requirements for each loan 
or commitment may vary based on the loan product and our 
assessment of a customer’s credit risk according to the specific 
credit underwriting, including credit terms and structure. 
The contractual amount of our unfunded credit 

commitments, including unissued standby and commercial 
letters of credit, is summarized by portfolio segment and class of 
financing receivable in Table 6.4. The table excludes the issued 
standby and commercial letters of credit and temporary advance 
arrangements described above. 

Table 6.4:  Unfunded Credit Commitments 

(in millions) 

Commercial: 

Dec 31,
2018 

Dec 31, 
2017 

Commercial and industrial 

$ 330,492 

326,626 

Real estate mortgage 

Real estate construction 

Total commercial 

Consumer: 

6,984 

7,485 

16,400 

16,621 

353,876 

350,732 

Real estate 1-4 family first mortgage 

29,736 

29,876 

Real estate 1-4 family 
junior lien mortgage 

Credit card 

37,719 

38,897 

109,840 

108,465 

Other revolving credit and installment 

27,530 

27,541 

Total consumer 

204,825 

204,779 

Total unfunded 

credit commitments 

$ 558,701 

555,511 

172 

Wells Fargo & Company 

172

  
 
Allowance for Credit Losses 
Table 6.5 presents the allowance for credit losses, which consists 
of the allowance for loan losses and the allowance for unfunded 
credit commitments. 

Table 6.5:  Allowance for Credit Losses 

(in millions) 

Balance, beginning of year 

Provision for credit losses 

Interest income on certain impaired loans (1) 

Loan charge-offs: 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer 

Total loan charge-offs 

Loan recoveries: 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer 

Total loan recoveries 

Net loan charge-offs 

Other 

Balance, end of year 

Components: 

Year ended December 31, 

2018 

2017 

2016 

2015 

2014 

$  11,960 

12,540 

12,512 

13,169 

14,971 

1,744 

(166) 

2,528 

(186) 

3,770 

(205) 

2,442 

(198) 

1,395 

(211) 

(727) 

(42) 

— 

(70) 

(839) 

(179) 

(179) 

(1,599) 

(947) 

(685) 

(3,589) 

(4,428) 

304 

70 

13 

23 

410 

267 

219 

307 

363 

118 

(789) 

(38) 

— 

(45) 

(1,419) 

(734) 

(627) 

(27) 

(1) 

(41) 

(59) 

(4) 

(14) 

(66) 

(9) 

(15) 

(872) 

(1,488) 

(811) 

(717) 

(240) 

(279) 

(1,481) 

(1,002) 

(713) 

(3,715) 

(452) 

(495) 

(507) 

(635) 

(721) 

(864) 

(1,259) 

(1,116) 

(1,025) 

(845) 

(708) 

(742) 

(643) 

(729) 

(668) 

(3,759) 

(3,643) 

(4,007) 

(4,587) 

(5,247) 

(4,454) 

(4,724) 

297 

82 

30 

17

426 

288 

266 

239 

319 

121 

263 

116 

38 

11 

428 

373 

266 

207 

325 

128 

252 

127 

37

8 

424 

245 

259 

175 

325 

134 

369 

160 

136 

8 

673 

212 

238 

161 

349 

146 

1,274 

1,684 

1,233 

1,659 

1,299 

1,727 

1,138 

1,562 

1,106 

1,779 

(2,744) 

(2,928) 

(3,520) 

(2,892) 

(2,945) 

(87) 

6

 (17)

 (9)

 (41) 

$  10,707 

11,960 

12,540 

12,512 

13,169 

Allowance for loan losses 

Allowance for unfunded credit commitments 

Allowance for credit losses 

Net loan charge-offs as a percentage of average total loans 

Allowance for loan losses as a percentage of total loans 

Allowance for credit losses as a percentage of total loans 

$  9,775 

11,004 

932 

956 

$  10,707 

11,960 

0.29% 

1.03 

1.12 

0.31 

1.15 

1.25 

11,419 

1,121 

12,540 

0.37 

1.18 

1.30 

11,545 

12,319 

967 

850 

12,512 

13,169 

0.33 

1.26 

1.37 

0.35 

1.43 

1.53 

(1)  Certain impaired loans with an allowance calculated by discounting expected cash flows using the loan’s effective interest rate over the remaining life of the loan recognize 

changes in allowance attributable to the passage of time as interest income. 

173

Wells Fargo & Company 

173 

  
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

Table 6.6 summarizes the activity in the allowance for credit 

losses by our commercial and consumer portfolio segments. 

Table 6.6:  Allowance Activity by Portfolio Segment 

Year ended December 31, 

(in millions) 

Commercial  Consumer 

Total 

Commercial  Consumer 

2018 

Balance, beginning of year 

$ 

6,632 

Provision (reversal of provision) for credit losses 

Interest income on certain impaired loans 

281 

(47) 

5,328 

1,463 

11,960 

1,744 

(119) 

(166) 

7,394 

(261) 

(59) 

5,146 

2,789 

(127) 

(186) 

2017 

Total 

12,540 

2,528 

Loan charge-offs 

Loan recoveries 

Net loan charge-offs 

Other 

Balance, end of year 

(839) 

(3,589) 

(4,428) 

(872) 

(3,715) 

(4,587) 

410 

1,274 

1,684 

426 

1,233 

1,659 

(429) 

(2,315) 

(2,744) 

(446) 

(2,482) 

(2,928) 

(20) 

(67) 

(87) 

4 

2 

6 

$ 

6,417 

4,290 

10,707 

6,632 

5,328 

11,960 

Table 6.7 disaggregates our allowance for credit losses and 

recorded investment in loans by impairment methodology. 

Table 6.7:  Allowance by Impairment Methodology 

(in millions) 

December 31, 2018 

Collectively evaluated (1) 

Individually evaluated (2) 

PCI (3) 

Total 

December 31, 2017 

Collectively evaluated (1) 

Individually evaluated (2) 

PCI (3) 

Total 

Allowance for credit losses 

Recorded investment in loans 

Commercial 

Consumer 

Total 

Commercial 

Consumer 

Total 

$ 

5,903 

3,361 

514 

—

929 

 —

9,264 

1,443 

 —

510,180 

421,574 

931,754 

3,221 

13,126 

16,347 

  4

5,005

5,009 

$ 

6,417 

4,290 

10,707 

513,405 

439,705 

953,110 

$ 

5,927 

705 

—

4,143 

1,185 

 —

10,070 

1,890 

 —

499,342 

425,919 

925,261 

3,960 

  86

14,714 

12,749 

18,674 

12,835 

$ 

6,632 

5,328 

11,960 

503,388 

453,382 

956,770 

(1)  Represents loans collectively evaluated for impairment in accordance with Accounting Standards Codification (ASC) 450-20, Loss Contingencies (formerly FAS 5), and 

pursuant to amendments by ASU 2010-20 regarding allowance for non-impaired loans. 

(2)  Represents loans individually evaluated for impairment in accordance with ASC 310-10, Receivables (formerly FAS 114), and pursuant to amendments by ASU 2010-20 

regarding allowance for impaired loans. 

(3)  Represents the allowance and related loan carrying value determined in accordance with ASC 310-30, Receivables – Loans and Debt Securities Acquired with Deteriorated 

Credit Quality (formerly SOP 3-3) and pursuant to amendments by ASU 2010-20 regarding allowance for PCI loans. 

Credit Quality 
We monitor credit quality by evaluating various attributes and 
utilize such information in our evaluation of the appropriateness 
of the allowance for credit losses. The following sections provide 
the credit quality indicators we most closely monitor. The credit 
quality indicators are generally based on information as of our 
financial statement date, with the exception of updated Fair 
Isaac Corporation (FICO) scores and updated loan-to-value 
(LTV)/combined LTV (CLTV). We obtain FICO scores at loan 
origination and the scores are generally updated at least 
quarterly, except in limited circumstances, including compliance 
with the Fair Credit Reporting Act (FCRA). Generally, the LTV 
and CLTV indicators are updated in the second month of each 
quarter, with updates no older than September 30, 2018. See the 
“Purchased Credit-Impaired Loans” section in this Note for 
credit quality information on our PCI portfolio. 

COMMERCIAL CREDIT QUALITY INDICATORS  In addition to 
monitoring commercial loan concentration risk, we manage a 
consistent process for assessing commercial loan credit quality. 
Generally, commercial loans are subject to individual risk 
assessment using our internal borrower and collateral quality 
ratings. Our ratings are aligned to Pass and Criticized categories. 
The Criticized category includes Special Mention, Substandard, 
and Doubtful categories which are defined by bank regulatory 
agencies. 

Table 6.8 provides a breakdown of outstanding commercial 

loans by risk category. Of the $14.8 billion in criticized 
commercial and industrial loans and $4.8 billion in criticized 
commercial real estate (CRE) loans at December 31, 2018, 
$1.5 billion and $612 million, respectively, have been placed on 
nonaccrual status and written down to net realizable collateral 
value. 

174 

Wells Fargo & Company 

174

  
 
 
  
 
 
 
 
Commercial 
and industrial 

Real estate 
mortgage 

Real estate 
construction 

Lease 
financing 

Total 

Table 6.8:  Commercial Loans by Risk Category 

(in millions) 

December 31, 2018 

By risk category: 

Pass 

Criticized 

$ 

335,412 

116,514 

22,207 

14,783 

4,500 

289 

18,671 

1,025 

19,696 

— 

492,804 

20,597 

513,401 

4 

Total commercial loans (excluding PCI) 

350,195 

121,014 

22,496 

Total commercial PCI loans (carrying value) 

4 

— 

— 

Total commercial loans 

$ 

350,199 

121,014 

22,496 

19,696 

513,405 

December 31, 2017 

By risk category: 

Pass 

Criticized 

Total commercial loans (excluding PCI) 

Total commercial PCI loans (carrying value) 

$ 

316,431 

122,312 

16,608 

4,287 

333,039 

126,599 

86 

— 

23,981 

298 

24,279 

— 

18,162 

1,223 

19,385 

— 

480,886 

22,416 

503,302 

86 

Total commercial loans 

$ 

333,125 

126,599 

24,279 

19,385 

503,388 

Table 6.9 provides past due information for commercial 
loans, which we monitor as part of our credit risk management 
practices. 

Table 6.9:  Commercial Loans by Delinquency Status 

(in millions) 

December 31, 2018 

By delinquency status: 

Commercial 
and industrial 

Real estate 
mortgage 

Real estate 
construction 

Lease 
financing 

Total 

Current-29 days past due (DPD) and still accruing 

$ 

348,158 

120,176 

22,411 

19,443 

510,188 

30-89 DPD and still accruing 

90+ DPD and still accruing 

Nonaccrual loans 

508 

43 

1,486 

207 

51 

580 

53 

— 

32 

163 

— 

90 

931 

94 

2,188 

Total commercial loans (excluding PCI) 

350,195 

121,014 

22,496 

19,696 

513,401 

Total commercial PCI loans (carrying value) 

4 

— 

— 

— 

4 

Total commercial loans 

$ 

350,199 

121,014 

22,496 

19,696 

513,405 

December 31, 2017 

By delinquency status: 

Current-29 DPD and still accruing 

$ 

330,319 

125,642 

24,107 

19,148 

499,216 

30-89 DPD and still accruing 

90+ DPD and still accruing 

Nonaccrual loans 

795 

26 

1,899 

306 

23 

628 

135 

— 

37 

161 

— 

76 

1,397 

49 

2,640 

Total commercial loans (excluding PCI) 

333,039 

126,599 

24,279 

19,385 

503,302 

Total commercial PCI loans (carrying value) 

86 

— 

— 

— 

86 

Total commercial loans 

$ 

333,125 

126,599 

24,279 

19,385 

503,388 

175

Wells Fargo & Company 

175 

  
 
  
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

CONSUMER CREDIT QUALITY INDICATORS  We have various 
classes of consumer loans that present unique risks. Loan 
delinquency, FICO credit scores and LTV for loan types are 
common credit quality indicators that we monitor and utilize in 
our evaluation of the appropriateness of the allowance for credit 
losses for the consumer portfolio segment. 

Many of our loss estimation techniques used for the 
allowance for credit losses rely on delinquency-based models; 
therefore, delinquency is an important indicator of credit quality 
and the establishment of our allowance for credit losses. Table 
6.10 provides the outstanding balances of our consumer 
portfolio by delinquency status. 

Table 6.10:  Consumer Loans by Delinquency Status 

(in millions) 

December 31, 2018 

By delinquency status: 

Current-29 DPD 

30-59 DPD 

60-89 DPD 

90-119 DPD 

120-179 DPD 

180+ DPD 

Government insured/guaranteed loans (1)

Loans held at fair value

Real estate 
1-4 family
first 
mortgage 

Real estate 
1-4 family
junior lien 
mortgage 

Credit card 

Automobile 

Other 
revolving
credit and 
installment 

Total 

$  263,881 

33,644 

38,008 

43,604 

35,794 

414,931 

1,411 

549 

257 

225 

822 

12,688

244

247 

126 

74 

77 

213 

 —

 —

292 

212 

192 

320 

1 

 —

 —

1,040 

140 

314 

109 

2 

— 

 —

 —

87 

80 

27 

20 

 —

 —

3,130 

1,288 

712 

651 

1,056 

12,688

 244 

Total consumer loans (excluding PCI) 

280,077 

34,381 

39,025 

45,069 

36,148 

434,700 

Total consumer PCI loans (carrying value) 

4,988 

17 

— 

— 

— 

5,005 

Total consumer loans 

$  285,065 

34,398 

39,025 

45,069 

36,148 

439,705 

December 31, 2017 

By delinquency status: 

Current-29 DPD 

30-59 DPD 

60-89 DPD 

90-119 DPD 

120-179 DPD 

180+ DPD 

Government insured/guaranteed loans (1)

Loans held at fair value

Total consumer loans (excluding PCI) 

Total consumer PCI loans (carrying value) 

$  251,786 

38,746 

36,996 

1,893 

742 

369 

308 

1,091 

14,767

376

271,332 

12,722 

336 

163 

103 

95 

243 

 —

 —

287 

201 

192 

298 

2 

 —

 —

51,445 

1,385 

392 

146 

3 

— 

 —

 —

37,885 

416,858 

155 

93 

80 

30 

25 

 —

 —

4,056 

1,591 

890 

734 

1,361 

14,767

 376

39,686 

37,976 

53,371 

38,268 

440,633 

27 

— 

— 

— 

12,749 

Total consumer loans 

$  284,054 

39,713 

37,976 

53,371 

38,268 

453,382 

(1)  Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. Loans insured/guaranteed by the FHA/VA and 90+ DPD totaled 

$7.7 billion at December 31, 2018, compared with $10.5 billion at December 31, 2017. 

Of the $2.4 billion of consumer loans not government 

insured/guaranteed that are 90 days or more past due at 
December 31, 2018, $885 million was accruing, compared with 
$3.0 billion past due and $1.0 billion accruing at December 31, 
2017. 

Real estate 1-4 family first mortgage loans 180 days or more 

past due totaled $822 million, or 0.3% of total first mortgages 
(excluding PCI), at December 31, 2018, compared with 
$1.1 billion, or 0.4%, at December 31, 2017. 

Table 6.11 provides a breakdown of our consumer portfolio 
by FICO. Most of the scored consumer portfolio has an updated 
FICO of 680 and above, reflecting a strong current borrower 
credit profile. FICO is not available for certain loan types, or may 
not be required if we deem it unnecessary due to strong 
collateral and other borrower attributes. Substantially all loans 
not requiring a FICO score are securities-based loans originated 
through retail brokerage, and totaled $8.9 billion at 
December 31, 2018, and $8.5 billion at December 31, 2017. 

176 

Wells Fargo & Company 

176

 
  
 
 
 
 
 
 
 
 
 
 
Table 6.11:  Consumer Loans by FICO 

(in millions) 

December 31, 2018 

By FICO: 

< 600 

600-639 

640-679 

680-719 

720-759 

760-799 

800+ 

No FICO available 

FICO not required 

Real estate 1-4 
family first 
mortgage 

Real estate 
1-4 family 
junior lien 
mortgage 

Credit card 

Automobile 

Other revolving 
credit and 
installment 

Total 

$ 

4,273 

2,974 

5,810 

13,568 

27,258 

57,193 

151,465 

4,604 

— 

1,454 

994 

1,898 

3,908 

5,323 

6,315 

13,190 

1,299 

— 

— 

3,292 

2,777 

6,464 

9,445 

7,949 

5,227 

3,794 

77 

— 

— 

7,071 

4,431 

6,225 

7,354 

6,853 

5,947 

7,099 

89 

— 

— 

697 

725 

1,822 

3,384 

4,395 

5,322 

8,411 

2,507 

8,885 

16,787 

11,901 

22,219 

37,659 

51,778 

80,004 

183,959 

8,576 

8,885 

— 

12,932 

34,381 

39,025 

45,069 

36,148 

434,700 

17 

— 

— 

— 

5,005 

Total consumer loans 

$ 

285,065 

34,398 

39,025 

45,069 

36,148 

439,705 

Government insured/guaranteed loans (1) 

12,932 

Total consumer loans (excluding
PCI) 

Total consumer PCI loans (carrying value) 

280,077 

4,988 

December 31, 2017 

By FICO: 

< 600 

600-639 

640-679 

680-719 

720-759 

760-799 

800+ 

$ 

5,145 

3,487 

6,789 

14,977 

27,926 

55,590 

1,768 

1,253 

2,387 

4,797 

6,246 

7,323 

136,729 

15,144 

No FICO available 

FICO not required 

Government insured/guaranteed loans (1) 

Total consumer loans (excluding PCI) 

Total consumer PCI loans (carrying value) 

5,546 

— 

15,143 

271,332 

12,722 

768 

— 

— 

3,525 

3,101 

5,690 

7,628 

8,097 

6,372 

2,994 

569 

— 

— 

8,858 

5,615 

7,696 

8,825 

7,806 

6,468 

7,845 

258 

— 

— 

863 

904 

1,959 

3,582 

5,089 

6,257 

8,455 

2,648 

8,511 

20,159 

14,360 

24,521 

39,809 

55,164 

82,010 

171,167 

9,789 

8,511 

— 

15,143 

39,686 

37,976 

53,371 

38,268 

440,633 

27 

— 

— 

— 

12,749 

Total consumer loans 

$ 

284,054 

39,713 

37,976 

53,371 

38,268 

453,382 

(1)  Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. 

LTV refers to the ratio comparing the loan’s unpaid 

principal balance to the property’s collateral value. CLTV refers 
to the combination of first mortgage and junior lien mortgage 
(including unused line amounts for credit line products) ratios. 
LTVs and CLTVs are updated quarterly using a cascade approach 
which first uses values provided by automated valuation models 
(AVMs) for the property. If an AVM is not available, then the 
value is estimated using the original appraised value adjusted by 
the change in Home Price Index (HPI) for the property location. 
If an HPI is not available, the original appraised value is used. 
The HPI value is normally the only method considered for high 
value properties, generally with an original value of $1 million or 
more, as the AVM values have proven less accurate for these 
properties. 

Table 6.12 shows the most updated LTV and CLTV 
distribution of the real estate 1-4 family first and junior lien 
mortgage loan portfolios. We consider the trends in residential 
real estate markets as we monitor credit risk and establish our 
allowance for credit losses. In the event of a default, any loss 
should be limited to the portion of the loan amount in excess of 
the net realizable value of the underlying real estate collateral 
value. Certain loans do not have an LTV or CLTV due to industry 
data availability and portfolios acquired from or serviced by 
other institutions. 

177

Wells Fargo & Company 

177 

  
 
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

Table 6.12:  Consumer Loans by LTV/CLTV 

December 31, 2018 

December 31, 2017 

(in millions) 

By LTV/CLTV: 

0-60% 

60.01-80% 

80.01-100% 

100.01-120% (1) 

> 120% (1) 

No LTV/CLTV available 

Government insured/guaranteed loans (2) 

Real estate 
1-4 family
first 
mortgage
by LTV 

Real estate 
1-4 family
junior lien 
mortgage
by CLTV 

Real estate 
1-4 family
first 
mortgage
by LTV 

Real estate 
1-4 family
junior lien 
mortgage
by CLTV 

Total 

$  147,666 

15,753 

163,419 

104,477 

11,183 

115,660 

12,372 

1,211 

484 

935 

12,932 

4,874 

1,596 

578 

397 

— 

17,246 

2,807 

1,062 

1,332 

133,902 

104,639 

13,924 

1,868 

783 

1,073 

12,932 

15,143 

16,301 

12,918 

6,580 

2,427 

1,008 

452 

— 

Total 

150,203 

117,557 

20,504 

4,295 

1,791 

1,525 

15,143 

Total consumer loans (excluding PCI) 

280,077 

34,381 

314,458 

271,332 

39,686 

311,018 

Total consumer PCI loans (carrying value) 

4,988 

17 

5,005 

12,722 

27 

12,749 

Total consumer loans 

$  285,065 

34,398 

319,463 

284,054 

39,713 

323,767 

(1)  Reflects total loan balances with LTV/CLTV amounts in excess of 100%. In the event of default, the loss content would generally be limited to only the amount in excess of 

100% LTV/CLTV. 

(2)  Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. 

NONACCRUAL LOANS  Table 6.13 provides loans on nonaccrual 
status. PCI loans are excluded from this table because they 
continue to earn interest from accretable yield, independent of 
performance in accordance with their contractual terms. 

Table 6.13:  Nonaccrual Loans 

(in millions) 

Commercial: 

Dec 31, 

Dec 31, 

2018 

2017 

Commercial and industrial 

$ 

1,486 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

580 

32 

90 

1,899 

628 

37 

76 

2,188 

2,640 

LOANS IN PROCESS OF FORECLOSURE  Our recorded 
investment in consumer mortgage loans collateralized by 
residential real estate property that are in process of foreclosure 
was $4.6 billion and $6.3 billion at December 31, 2018 and 2017, 
respectively, which included $3.2 billion and $4.0 billion, 
respectively, of loans that are government insured/guaranteed. 
Under the Consumer Financial Protection Bureau guidelines, we 
do not commence the foreclosure process on consumer real 
estate loans until after the loan is 120 days delinquent. 
Foreclosure procedures and timelines vary depending on 
whether the property address resides in a judicial or non-judicial 
state. Judicial states require the foreclosure to be processed
through the state’s courts while non-judicial states are processed
without court intervention. Foreclosure timelines vary according
to state law. 

Real estate 1-4 family first mortgage (1) 

3,183 

3,732 

Real estate 1-4 family junior lien 

mortgage 

Automobile 

Other revolving credit and installment 

Total consumer 

Total nonaccrual loans 
(excluding PCI) 

945 

130 

50 

1,086 

130 

58 

4,308 

5,006 

$ 

6,496 

7,646 

(1)  Prior period has been revised to exclude $390 million of MLHFS, LHFS and 

loans held at fair value. 

178 

Wells Fargo & Company 

178

  
 
  
 
LOANS 90 DAYS OR MORE PAST DUE AND STILL ACCRUING 
Certain loans 90 days or more past due as to interest or principal 
are still accruing, because they are (1) well-secured and in the 
process of collection or (2) real estate 1 4 family mortgage loans 
or consumer loans exempt under regulatory rules from being 
classified as nonaccrual until later delinquency, usually 120 days 
past due. PCI loans of $370 million at December 31, 2018, and 
$1.4 billion at December 31, 2017, are not included in these past 
due and still accruing loans even when they are 90 days or more 
contractually past due. These PCI loans are considered to be 
accruing because they continue to earn interest from accretable 
yield, independent of performance in accordance with their 
contractual terms. 

Table 6.14 shows non-PCI loans 90 days or more past due 

and still accruing by class for loans not government insured/ 
guaranteed. 

Table 6.14:  Loans 90 Days or More Past Due and Still 
Accruing (1) 

(in millions) 

Dec 31, 

Dec 31, 

2018 

2017 

Total (excluding PCI): 

$ 

8,704 

Less: FHA insured/VA guaranteed (2) 

7,725 

11,532 

10,475 

Total, not government
insured/guaranteed 

$ 

979 

1,057 

By segment and class, not government

insured/guaranteed: 

Commercial: 

Commercial and industrial 

$

Real estate mortgage 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien 

mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer 

Total, not government
insured/guaranteed 

 43

51 

94 

124 

32 

513 

114 

102 

885 

26 

23 

49 

213 

60 

492 

143 

100 

1,008 

$ 

979 

1,057 

(1)  Financial information for the prior period December 31, 2017 has been revised 
to exclude MLHFS, LHFS and loans held at fair value, which reduced “Total, not 
government insured/guaranteed” by $6 million. 

(2)  Represents loans whose repayments are predominantly insured by the FHA or 

guaranteed by the VA. 

179

Wells Fargo & Company 

179 

  
 
  
 
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

IMPAIRED LOANS  Table 6.15 summarizes key information for 
impaired loans. Our impaired loans predominantly include loans 
on nonaccrual status in the commercial portfolio segment and 
loans modified in a TDR, whether on accrual or nonaccrual 
status. These impaired loans generally have estimated losses 
which are included in the allowance for credit losses. We have 
impaired loans with no allowance for credit losses when loss 
content has been previously recognized through charge-offs and 
we do not anticipate additional charge-offs or losses, or certain 

Table 6.15:  Impaired Loans Summary 

loans are currently performing in accordance with their terms 
and for which no loss has been estimated. Impaired loans 
exclude PCI loans. Table 6.15 includes trial modifications that 
totaled $149 million at December 31, 2018, and $194 million at 
December 31, 2017. 

For additional information on our impaired loans and 
allowance for credit losses, see Note 1 (Summary of Significant 
Accounting Policies). 

(in millions) 

December 31, 2018 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer (2) 

Total impaired loans (excluding PCI) 

December 31, 2017 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer (2) 

Total impaired loans (excluding PCI) 

Recorded investment 

Unpaid 
principal 
balance (1) 

Impaired 
loans 

Impaired
loans with 
related 
allowance for 
credit losses 

Related 
allowance for 
credit losses 

$ 

3,057 

1,228 

74 

146 

2,030 

1,032 

47 

112 

1,730 

1,009 

46 

112 

4,505 

3,221 

2,897 

12,309 

1,886 

449 

153 

162 

14,959 

$ 

19,464 

$ 

3,577 

1,502 

95 

132 

5,306 

14,020 

2,135 

356 

157 

136 

16,804 

$ 

22,110 

10,738 

1,694 

449 

89 

156 

13,126 

16,347 

2,568 

1,239 

54 

99 

4,420 

1,133 

449 

43 

136 

6,181 

9,078 

2,310 

1,207 

45 

89 

3,960 

3,651 

12,225 

1,918 

356 

87 

128 

14,714 

18,674 

6,060 

1,421 

356 

34 

117 

7,988 

11,639 

319 

154 

9 

32 

514 

525 

183 

172 

8 

41 

929 

1,443 

462 

211 

9 

23 

705 

770 

245 

136 

5 

29 

1,185 

1,890 

(1)  Excludes the unpaid principal balance for loans that have been fully charged off or otherwise have zero recorded investment. 
(2) 

Includes the recorded investment of $1.3 billion and $1.4 billion at December 31, 2018 and 2017, respectively, of government insured/guaranteed loans that are 
predominantly insured by the FHA or guaranteed by the VA and generally do not have an allowance. Impaired loans may also have limited, if any, allowance when the 
recorded investment of the loan approximates estimated net realizable value as a result of charge-offs prior to a TDR modification. 

180 

Wells Fargo & Company 

180

 
  
 
Commitments to lend additional funds on loans whose 
terms have been modified in a TDR amounted to $513 million 
and $579 million at December 31, 2018 and 2017, respectively. 
Table 6.16 provides the average recorded investment in 
impaired loans and the amount of interest income recognized on 
impaired loans by portfolio segment and class. 

Table 6.16:  Average Recorded Investment in Impaired Loans 

(in millions) 

Commercial: 

2018 

2017 

2016 

Average 
recorded 
investment 

Recognized 
interest 
income 

Average 
recorded 
investment 

Recognized 
interest 
income 

Average 
recorded 
investment 

Recognized 
interest 
income 

Year ended December 31, 

Commercial and industrial 

$ 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer:

  Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer 

2,287 

1,193 

60 

125 

3,665 

11,522 

1,804 

407 

86 

142 

13,961 

Total impaired loans (excluding PCI) 

$ 

17,626 

173 

89 

7 

1 

270 

664 

116 

50 

11 

10 

851 

1,121 

3,241 

1,328 

66 

105 

4,740 

13,326 

2,041 

323 

86 

117 

15,893 

20,633 

Interest income: 

Cash basis of accounting 

Other (1) 

Total interest income 

$ 

$ 

338 

783 

1,121 

118 

91 

14

1

224 

730 

121 

36 

11 

8

906 

1,130 

299 

831 

1,130 

3,408 

1,636 

115 

88 

5,247 

15,857 

2,294 

295 

93 

89 

18,628 

23,875 

101 

128 

11 

— 

240 

828 

132 

34 

11 

6 

1,011 

1,251 

353 

898 

1,251 

(1) 

Includes interest recognized on accruing TDRs, interest recognized related to certain impaired loans which have an allowance calculated using discounting, and amortization 
of purchase accounting adjustments related to certain impaired loans. 

Table 6.17 summarizes our TDR modifications for the 
periods presented by primary modification type and includes the 
financial effects of these modifications. For those loans that 
modify more than once, the table reflects each modification that 
occurred during the period. Loans that both modify and pay off 
within the period, as well as changes in recorded investment 
during the period for loans modified in prior periods, are not 
included in the table. 

TROUBLED DEBT RESTRUCTURINGS (TDRs)  When, for 
economic or legal reasons related to a borrower’s financial 
difficulties, we grant a concession for other than an insignificant 
period of time to a borrower that we would not otherwise 
consider, the related loan is classified as a TDR, the balance of 
which totaled $15.5 billion and $17.8 billion at December 31, 
2018 and 2017, respectively. We do not consider loan resolutions 
such as foreclosure or short sale to be a TDR. 

We may require some consumer borrowers experiencing 
financial difficulty to make trial payments generally for a period 
of three to four months, according to the terms of a planned 
permanent modification, to determine if they can perform 
according to those terms. These arrangements represent trial 
modifications, which we classify and account for as TDRs. While 
loans are in trial payment programs, their original terms are not 
considered modified and they continue to advance through 
delinquency status and accrue interest according to their original 
terms. 

181

Wells Fargo & Company 

181 

 
  
 
 
Primary modification type (1) 

Financial effects of modifications 

Principal (2) 

Interest rate 
reduction 

Other 
concessions (3) 

Total  Charge- offs (4) 

Weighted 
average 
interest rate 
reduction 

Recorded 
investment 
related to 
interest rate 
reduction (5) 

Note 6:  Loans and Allowance for Credit Losses (continued) 

Table 6.17:  TDR Modifications 

(in millions) 

Year ended December 31, 2018 

Commercial: 

Commercial and industrial 

Real estate mortgage 
Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 
Real estate 1-4 family junior lien mortgage 

Credit card 
Automobile 

Other revolving credit and installment 
Trial modifications (6) 

Total consumer 

Total 

Year ended December 31, 2017 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Trial modifications (6) 

Total consumer 

Total 

Year ended December 31, 2016 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Trial modifications (6) 

Total consumer 

Total 

$ 

$ 

$ 

$ 

$ 

$ 

13 

— 
— 

— 

13 

209 
7 

— 
13 

— 
— 

229 

242 

24 

5 

— 

— 

29 

231 
25 

— 

2 

— 

— 

258 

287 

42 

2 

— 

— 

44 

338 
23 

— 

2 

1 

— 

364 

408 

29 

44 
— 

— 

73 

26 
41 

336 
16 

49 
— 

468 

541 

45 

59 
1 

— 

105 

140 

82 

257 

15 

47 

— 

541 

646 

130 

105 

27 

— 

262 

288 

109 

180 

16 

33 

— 

626 

888 

2,310 

2,352 

375 
25 

63 

419 
25 

63 

2,773 

2,859 

1,042 
113 

— 
55 

12 
8 

1,230 

4,003 

2,912 

507 

26 

37 

1,277 
161 

336 
84 

61 
8 

1,927 

4,786 

2,981 

571 

27 

37 

3,482 

3,616 

1,035 

1,406 

81 

— 

67 

8 

(28) 

1,163 

4,645 

3,154 

560 

72 

8 

188 

257 

84 

55 

(28) 

1,962 

5,578 

3,326 

667 

99 

8 

3,794 

4,100 

1,411 

106 

— 

57 

10 

44 

1,628 

5,422 

2,037 

238 

180 

75 

44 

44 

2,618 

6,718 

58 

— 
— 

— 

58 

4 
5 

— 
30 

— 
— 

39 

97 

173 

20 

— 

— 

193 

15 

14 

— 

39 

1 

— 

69 

1.18%  $ 

0.88 
— 

— 

1.00 

2.25 
2.14 

12.54 
6.21 

7.95 
— 

8.96 

8.06%  $ 

0.64 %  $ 

1.28 

0.69 

— 

1.00 

2.57 

3.26 

11.98 

5.89 

7.47 

— 

6.70 

262 

5.92 %  $ 

360 

1 

— 

— 

361 

49 

37 

— 

36 

2 

— 

124 

485 

1.91 %  $ 

1.15 

1.02 

— 

1.51 

2.69 

3.07 

12.09 

6.07 

6.83 

— 

4.92 

29 

44 
— 

— 

73 

119 
45 

336 
16 

49 
— 

565 

638 

45 

59 

1 

— 

105 

257 

93 

257 

15 

47 

— 

669 

774 

130 

105 

27 

— 

262 

507 

130 

180 

16 

33 

— 

866 

4.13 %  $ 

1,128 

(1)  Amounts represent the recorded investment in loans after recognizing the effects of the TDR, if any. TDRs may have multiple types of concessions, but are presented only 

once in the first modification type based on the order presented in the table above. The reported amounts include loans remodified of $1.9 billion, $2.1 billion and 
$1.6 billion, for the years ended December 31, 2018, 2017, and 2016, respectively. 

(2)  Principal modifications include principal forgiveness at the time of the modification, contingent principal forgiveness granted over the life of the loan based on borrower 

performance, and principal that has been legally separated and deferred to the end of the loan, with a zero percent contractual interest rate. 

(3)  Other concessions include loans discharged in bankruptcy, loan renewals, term extensions and other interest and noninterest adjustments, but exclude modifications that 

also forgive principal and/or reduce the contractual interest rate. 

(4)  Charge-offs include write-downs of the investment in the loan in the period it is contractually modified. The amount of charge-off will differ from the modification terms if 
the loan has been charged down prior to the modification based on our policies. In addition, there may be cases where we have a charge-off/down with no legal principal 
modification. Modifications resulted in legally forgiving principal (actual, contingent or deferred) of $28 million, $32 million and $67 million for the years ended 
December 31, 2018, 2017, and 2016, respectively. 

(5)  Reflects the effect of reduced interest rates on loans with an interest rate concession as one of their concession types, which includes loans reported as a principal primary 

modification type that also have an interest rate concession. 

(6)  Trial modifications are granted a delay in payments due under the original terms during the trial payment period. However, these loans continue to advance through 

delinquency status and accrue interest according to their original terms. Any subsequent permanent modification generally includes interest rate related concessions; 
however, the exact concession type and resulting financial effect are usually not known until the loan is permanently modified. Trial modifications for the period are 
presented net of previously reported trial modifications that became permanent in the current period. 

182 

Wells Fargo & Company 

182

  
 
Recorded investment of defaults 

Year ended December 31, 

2018 

2017 

2016 

$ 

198 

76 

36 

— 

310 

60 

14 

79 

14 

6 

173 

483 

$ 

173 

61 

4 

1 

239 

114 

19 

74 

15 

5 

227 

466 

124 

66 

3 

— 

193 

138 

20 

56 

13 

4 

231 

424 

Table 6.18 summarizes permanent modification TDRs that 

have defaulted in the current period within 12 months of their 
permanent modification date. We are reporting these defaulted 
TDRs based on a payment default definition of 90 days past due 
for the commercial portfolio segment and 60 days past due for 
the consumer portfolio segment. 

Table 6.18:  Defaulted TDRs 

(in millions) 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer 

Total 

Purchased Credit-Impaired Loans 
Substantially all of our PCI loans were acquired from Wachovia 
on December 31, 2008, at which time we acquired commercial 
and consumer loans with a carrying value of $18.7 billion and 
$40.1 billion, respectively. The unpaid principal balance on 
December 31, 2008, was $98.2 billion for the total of 
commercial and consumer PCI loans. Table 6.19 presents PCI 
loans net of any remaining purchase accounting adjustments. 
Real estate 1-4 family first mortgage PCI loans are 
predominantly Pick-a-Pay loans. 

Table 6.19:  PCI Loans 

(in millions) 

Total commercial 

Consumer: 

Dec 31,  Dec 31, 

2018 

2017 

$ 

4 

86 

Real estate 1-4 family first mortgage 

4,988 

12,722 

Real estate 1-4 family junior lien 

mortgage 

Total consumer 

Total PCI loans (carrying value) 

Total PCI loans (unpaid principal balance) 

17 

27 

5,005 

12,749 

5,009 

12,835 

7,348 

18,975 

$ 

$ 

183

Wells Fargo & Company 

183 

  
 
  
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

ACCRETABLE YIELD  The excess of cash flows expected to be
 collected over the carrying value of PCI loans is referred to as 
the accretable yield and is recognized in interest income using an 
effective yield method over the remaining life of the loan, or 
pools of loans. The accretable yield is affected by: 
• 

changes in interest rate indices for variable rate PCI loans – 
expected future cash flows are based on the variable rates in 
effect at the time of the regular evaluations of cash flows 
expected to be collected; 
changes in prepayment assumptions – prepayments affect 
the estimated life of PCI loans which may change the 
amount of interest income, and possibly principal, expected 
to be collected; and 

• 

• 

changes in the expected principal and interest payments 
over the estimated weighted-average life – updates to 
expected cash flows are driven by the credit outlook and 
actions taken with borrowers. Changes in expected future 
cash flows from loan modifications are included in the 
regular evaluations of cash flows expected to be collected. 

The change in the accretable yield related to PCI loans since 

the merger with Wachovia is presented in Table 6.20. Changes 
during 2018 also reflect $2.4 billion in gains on the sale of $6.2 
billion Pick-a-Pay PCI loans. 

Table 6.20:  Change in Accretable Yield 

(in millions) 

Total, beginning of period 

Addition of accretable yield due to acquisitions 

Accretion into interest income (1) 

Accretion into noninterest income due to sales (2) 

2018 

2017 

2016 

2009-2015 

$ 

8,887 

11,216 

16,301 

10,447 

— 

(1,094) 

(2,374) 

2 

27 

132 

(1,406) 

(1,365) 

(14,212) 

(334) 

(9) 

(458) 

Reclassification from nonaccretable difference for loans with improving credit-related

cash flows 

403 

642 

1,221 

Changes in expected cash flows that do not affect nonaccretable difference (3) 

(2,789) 

(1,233) 

(4,959) 

Total, end of period 

$ 

3,033 

8,887 

11,216 

9,734 

10,658 

16,301 

Includes accretable yield released as a result of settlements with borrowers, which is included in interest income. 
Includes accretable yield released as a result of sales to third parties, which is included in noninterest income. 

(1) 
(2) 
(3)  Represents changes in cash flows expected to be collected due to the impact of modifications, changes in prepayment assumptions, changes in interest rates on variable 

rate PCI loans and sales to third parties. 

COMMERCIAL PCI CREDIT QUALITY INDICATORS 
Table 6.21 provides a breakdown of commercial PCI loans by 
risk category. 

Table 6.21: Commercial PCI Loans by Risk Category 

(in millions) 

By risk category: 

Pass 

Criticized 

Total commercial PCI loans 

Dec. 31,
2018 

Dec. 31,
2017 

$ 

$ 

1 

3 

4 

8 

78 

86 

184 

Wells Fargo & Company 

184

 
 
 
  
 
 
Table 6.22 provides past due information for commercial 

PCI loans. 

Table 6.22:  Commercial PCI Loans by Delinquency Status 

(in millions) 

By delinquency status: 

Current-29 DPD and still accruing 

30-89 DPD and still accruing 

Total commercial PCI loans 

Dec. 31,
2018 

Dec. 31, 
2017 

$ 

$ 

3 

1 

4 

86 

— 

86 

CONSUMER PCI CREDIT QUALITY INDICATORS  Our 
consumer PCI loans were aggregated into several pools of loans 
at acquisition. Below, we have provided credit quality indicators 
based on the unpaid principal balance (adjusted for write-

downs) of the individual loans included in the pool, but we have 
not allocated the remaining purchase accounting adjustments, 
which were established at a pool level. Table 6.23 provides the 
delinquency status of consumer PCI loans. 

Table 6.23:  Consumer PCI Loans by Delinquency Status 

December 31, 2018 

December 31, 2017 

(in millions) 

By delinquency status: 

Real estate 
1-4 family
first 
mortgage 

Real estate 
1-4 family
junior lien 
mortgage 

Real estate 
1-4 family
first 
mortgage 

Real estate 
1-4 family
junior lien 
mortgage 

Total 

Current-29 DPD and still accruing 

$ 

5,545 

117 

5,662 

30-59 DPD and still accruing 

60-89 DPD and still accruing 

90-119 DPD and still accruing 

120-179 DPD and still accruing 

180+ DPD and still accruing 

495 

229 

99 

54 

353 

8 

3 

2 

1 

3 

503 

232 

101 

55 

356 

13,127 

1,317 

622 

293 

219 

1,310 

Total consumer PCI loans (adjusted unpaid

principal balance) 

Total consumer PCI loans (carrying value) 

$ 

$ 

6,775 

4,988 

134 

17 

6,909 

16,888 

5,005 

12,722 

138 

8 

3 

2 

2 

4 

157 

27 

Total 

13,265 

1,325 

625 

295 

221 

1,314 

17,045 

12,749 

185

Wells Fargo & Company 

185 

  
 
 
 
  
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

Table 6.24 provides FICO scores for consumer PCI loans. 

Table 6.24:  Consumer PCI Loans by FICO 

December 31, 2018 

December 31, 2017 

Real estate  Real estate 
1-4 family
junior lien 
mortgage 

1-4 family
first 
mortgage 

Real estate 
1-4 family
first 
mortgage 

Real estate 
1-4 family
junior lien 
mortgage 

(in millions) 

By FICO: 

< 600 

600-639 

640-679 

680-719 

720-759 

760-799 

800+ 

No FICO available 

(in millions) 

By LTV/CLTV: 

0-60% 

60.01-80% 

80.01-100% 

100.01-120% (1) 

> 120% (1) 

No LTV/CLTV available 

Total consumer PCI loans (adjusted unpaid

principal balance) 

Total consumer PCI loans (carrying value) 

$ 

$ 

Table 6.25 shows the distribution of consumer PCI loans by 

LTV for real estate 1-4 family first mortgages and by CLTV for 
real estate 1-4 family junior lien mortgages. 

Table 6.25:  Consumer PCI Loans by LTV/CLTV 

134 

17 

6,909 

16,888 

5,005 

12,722 

157 

27 

17,045 

12,749 

December 31, 2018 

December 31, 2017 

Real estate 
1-4 family 
first 
mortgage 
by LTV 

Real estate 
1-4 family 
junior lien 
mortgage 
by CLTV 

Real estate 
1-4 family 
first 
mortgage 
by LTV 

Real estate 
1-4 family
junior lien 
mortgage
by CLTV 

$ 

1,418 

713 

898 

970 

843 

523 

381 

1,029 

6,775 

4,988 

$ 

3,970 

2,161 

542 

82 

19 

1 

Total 

1,445 

731 

918 

994 

863 

534 

387 

4,014 

2,086 

2,393 

2,242 

1,779 

933 

468 

1,037 

2,973 

Total 

4,014 

2,214 

570 

90 

20 

1 

8,010 

6,510 

1,975 

319 

73 

1

27 

18 

20 

24 

20 

11 

6 

8 

44 

53 

28 

8

1

—

134 

17 

Total 

4,051 

2,106 

2,417 

2,271 

1,802 

945 

474 

2,979 

Total 

8,055 

6,573 

2,010 

329 

76 

2 

17,045 

12,749 

37 

20 

24 

29 

23 

12 

6 

6 

45 

63 

35 

10 

3

1

157 

27 

Total consumer PCI loans (adjusted unpaid

principal balance) 

Total consumer PCI loans (carrying value) 

$ 

$ 

6,775 

4,988 

6,909 

16,888 

5,005 

12,722 

(1)  Reflects total loan balances with LTV/CLTV amounts in excess of 100%. In the event of default, the loss content would generally be limited to only the amount in excess of 

100% LTV/CLTV. 

186 

Wells Fargo & Company 

186

 
  
 
  
 
Note 7:  Premises, Equipment, Lease Commitments and Other Assets 

Table 7.1:  Premises and Equipment 

Table 7.3 presents the components of other assets. 

Dec 31,
2018 

Dec 31,
2017 

Table 7.3:  Other Assets 

(in millions) 

Land 

Buildings 

Furniture and equipment 

Leasehold improvements 

$ 

1,757 

8,974 

6,896 

2,387 

1,799 

8,865 

7,089 

2,291 

Premises and equipment leased under

capital leases 

75 

103 

Total premises and equipment 

20,089 

20,147 

(in millions) 

Dec 31, 
2018 

Dec 31, 
2017 

Corporate/bank-owned life insurance 

$  19,751 

Accounts receivable (1) 

Interest receivable 

Core deposit intangibles 

Customer relationship and other amortized

34,281 

6,084 

— 

19,549 

39,127 

5,688 

769 

Less: Accumulated depreciation and

amortization 

Net book value, premises and

equipment 

11,169 

11,300 

intangibles 

Foreclosed assets: 

$ 

8,920 

8,847 

Residential real estate: 

545 

841 

Government insured/guaranteed (1) 

Non-government insured/guaranteed 

Non-residential real estate 

Operating lease assets 

Due from customers on acceptances 

88 

229 

134 

9,036 

258 

120 

252 

270 

9,666 

177 

Other 

9,444 

13,785 

Total other assets 

$  79,850 

90,244 

(1)  Certain government-guaranteed residential real estate mortgage loans upon 

foreclosure are included in Accounts receivable. Both principal and interest 
related to these foreclosed real estate assets are collectible because the loans 
were predominantly insured by the FHA or guaranteed by the VA. For more 
information on the classification of certain government-guaranteed mortgage 
loans upon foreclosure, see Note 1 (Summary of Significant Accounting 
Policies). 

Depreciation and amortization expense for premises and 
equipment was $1.3 billion, $1.2 billion and $1.2 billion in 2018, 
2017 and 2016, respectively. 

Dispositions of premises and equipment resulted in net 
gains of $32 million, $128 million and $44 million in 2018, 2017 
and 2016, respectively, included in other noninterest expense. 
We have obligations under a number of noncancelable 

operating leases for premises and equipment. The leases 
predominantly expire over the next fifteen years, with the 
longest expiring in 2105, and many provide for periodic 
adjustment of rentals based on changes in various economic 
indicators. Some leases also include a renewal option. Table 7.2 
provides the future minimum payments of noncancelable 
operating leases, net of sublease income, with terms greater than 
one year as of December 31, 2018. 

Table 7.2:  Minimum Lease Payments of Operating Leases 

(in millions) 

Year ended December 31, 

2019 

2020 

2021 

2022 

2023 

Thereafter 

Total 

$ 

1,174 

1,056 

880 

713 

577 

1,654 

$ 

6,054 

Total minimum lease payments for operating leases above 

are net of $427 million of noncancelable sublease income. 
Operating lease rental expense (predominantly for premises) 
was $1.3 billion for the years 2018, 2017 and 2016, net of 
sublease income of $73 million, $76 million and $86 million for 
the same years, respectively. 

187

Wells Fargo & Company 

187 

  
 
  
 
  
 
Note 8:  Equity Securities 

Table 8.1 provides a summary of our equity securities by 
business purpose and accounting method, including equity 
securities with readily determinable fair values (marketable) and 
those without readily determinable fair values (nonmarketable). 

Table 8.1:  Equity Securities 

(in millions) 

Held for trading at fair value: 

Dec 31,
2018 

Dec 31,
2017 

Marketable equity securities 

$ 19,449 

30,004 

Not held for trading: 

Fair value: 

Marketable equity securities (1) 

Nonmarketable equity securities (2) 

4,513 

5,594 

Total equity securities at fair value 

10,107 

4,356 

4,867 

9,223 

Equity method: 

LIHTC (3) 

Private equity 

Tax-advantaged renewable energy 

New market tax credit and other 

10,999 

10,269 

3,832 

3,073 

311 

3,839 

1,950 

294 

Total equity method 

18,215 

16,352 

Other: 

Federal Reserve Bank stock and other at 

cost (4) 

Private equity (5) 

5,643 

1,734 

5,828 

1,090 

Total equity securities not held for

trading 

35,699 

32,493 

Total equity securities (6) 

$ 55,148 

62,497 

(1) 

(2) 

Includes $3.2 billion and $3.7 billion at December 31, 2018 and 2017, 
respectively, related to securities held as economic hedges of our deferred 
compensation plan obligations. 
Includes $5.5 billion and $4.9 billion at December 31, 2018 and 2017, 
respectively, related to investments for which we elected the fair value option. 
See Note 18 (Fair Value of Assets and Liabilities) for additional information. 

(3)  Represents low-income housing tax credit investments. 
(4) 

Includes $5.6 billion and $5.4 billion at December 31, 2018 and 2017, 
respectively, related to investments in Federal Reserve Bank and Federal Home 
Loan Bank stock. 

(5)  Represents nonmarketable equity securities for which we have elected to 

account for the security under the measurement alternative. 

(6)  At December 31, 2018 and 2017, we held no securities of any single issuer 

with a book value that exceeded 10% of stockholder’s equity. 

Equity Securities Held for Trading 
Equity securities held for trading purposes are marketable equity 
securities traded on organized exchanges. These securities are 
held as part of our customer accommodation trading activities. 
For more information on these activities, see Note 4 (Trading 
Activities). 

Equity Securities Not Held for Trading 
We also hold equity securities unrelated to trading activities. 
These securities include private equity and tax credit 
investments, securities held as economic hedges or to meet 
regulatory requirements (for example, Federal Reserve Bank and 
Federal Home Loan Bank stock). Equity securities not held for 
trading purposes are accounted for at either fair value, equity 
method, cost or the measurement alternative. 

FAIR VALUE  Marketable equity securities held for purposes 
other than trading primarily consist of exchange-traded equity 
funds held to economically hedge obligations related to our 
deferred compensation plans and to a lesser extent other 
holdings of publicly traded equity securities held for investment 
purposes. We have elected to account for nonmarketable equity 
securities under the fair value method, and substantially all of 
these securities are economically hedged with equity derivatives. 

EQUITY METHOD  Our equity method investments consist of 
tax credit and private equity investments, the majority of which 
are our low-income housing tax credit (LIHTC) investments. 

We invest in affordable housing projects that qualify for the 

LIHTC, which are designed to promote private development of 
low-income housing. These investments generate a return 
mostly through realization of federal tax credit and other tax 
benefits. We recognized pre-tax losses of $1.2 billion for both 
2018 and 2017, related to our LIHTC investments. These losses 
were recognized in other noninterest income. We also 
recognized total tax benefits of $1.5 billion for both 2018 and 
2017, which included tax credits recorded to income taxes of 
$1.2 billion and $1.1 billion for the same periods, respectively. 
We are periodically required to provide additional financial 
support during the investment period. Our liability for unfunded 
commitments was $3.9 billion and $3.6 billion at December 31, 
2018 and 2017, respectively. Substantially all of this liability is 
expected to be paid over the next three years. This liability is 
included in long-term debt. 

OTHER  The remaining portion of our nonmarketable equity 
securities portfolio consists of securities accounted for using the 
cost or measurement alternative method. 

188 

Wells Fargo & Company 

188

 
Realized Gains and Losses 
Table 8.2 provides a summary of the net gains and losses for 
equity securities. Gains and losses for securities held for trading 
are reported in net gains from trading activities. 

Table 8.2:  Net Gains (Losses) from Equity Securities 

(in millions) 

Net gains (losses) from equity securities carried at fair value: 

Marketable equity securities 

Nonmarketable equity securities 

Total equity securities carried at fair value 

Year ended December 31, 

2018 

2017 

2016 

$ 

(389) 

709 

320 

967 

1,557 

2,524 

525 

(21) 

504 

Net gains (losses) from nonmarketable equity securities not carried at fair value: 

Impairment write-downs 

(352) 

(339) 

(448) 

Net unrealized gains related to measurement alternative observable transactions 

Net realized gains on sale 

All other 

Total nonmarketable equity securities not carried at fair value 

418 

1,504 

33 

1,603 

—

980 

97 

738 

Net gains (losses) from economic hedge derivatives (1) 

(408) 

(1,483) 

— 

849 

73 

474 

125 

Total net gains from equity securities 

$ 

1,515 

1,779 

1,103 

(1) 

Includes net gains (losses) on derivatives not designated as hedging instruments. 

Measurement Alternative 
Table 8.3 provides additional information about the impairment 
write-downs and observable price adjustments related to 

nonmarketable equity securities accounted for under the 
measurement alternative. Gains and losses related to these 
adjustments are also included in Table 8.2. 

Table 8.3:  Measurement Alternative 

(in millions) 

Net gains (losses) recognized in earnings during the period: 

Gross unrealized gains due to observable price changes 

Gross unrealized losses due to observable price changes 

Impairment write-downs 

Realized net gains from sale 

Total net gains recognized during the period 

The cumulative gross unrealized gains and (losses) due to 

observable price changes as of December 31, 2018, were 
$415 million and $(25) million, respectively. Cumulative 
impairment losses as of December 31, 2018, were $33 million. 
These cumulative amounts represent carrying value adjustments 
to equity securities accounted for under the measurement 
alternative that were recognized on the balance sheet as of 
December 31, 2018. 

Year ended December 31, 

2018 

443 

(25) 

(33) 

274 

659 

$ 

$ 

189

Wells Fargo & Company 

189 

  
 
  
Note 9:  Securitizations and Variable Interest Entities 

Involvement with Special Purpose Entities (SPEs) 
In the normal course of business, we enter into various types of 
on- and off-balance sheet transactions with SPEs, which are 
corporations, trusts, limited liability companies or partnerships 
that are established for a limited purpose. Generally, SPEs are 
formed in connection with securitization transactions. In a 
securitization transaction, assets are transferred to an SPE, 
which then issues to investors various forms of interests in those 
assets and may also enter into derivative transactions. In a 
securitization transaction where we transferred assets from our 
balance sheet, we typically receive cash and/or other interests in 
an SPE as proceeds for the assets we transfer. Also, in certain 
transactions, we may retain the right to service the transferred 
receivables and to repurchase those receivables from the SPE if 
the outstanding balance of the receivables falls to a level where 
the cost exceeds the benefits of servicing such receivables. In 
addition, we may purchase the right to service loans in an SPE 
that were transferred to the SPE by a third party. 

In connection with our securitization activities, we have 
various forms of ongoing involvement with SPEs, which may 
include: 
• 

underwriting securities issued by SPEs and subsequently 
making markets in those securities; 
providing liquidity facilities to support short-term 
obligations of SPEs issued to third-party investors; 
providing credit enhancement on securities issued by SPEs 
or market value guarantees of assets held by SPEs through 
the use of letters of credit, financial guarantees, credit 
default swaps and total return swaps; 
entering into other derivative contracts with SPEs; 
holding senior or subordinated interests in SPEs; 
acting as servicer or investment manager for SPEs; and 
providing administrative or trustee services to SPEs. 

• 

• 

• 
• 
• 
• 

SPEs formed in connection with securitization transactions 
are generally considered variable interest entities (VIEs). SPEs 
formed for other corporate purposes may be VIEs as well. A VIE 
is an entity that has either a total equity investment that is 
insufficient to finance its activities without additional 
subordinated financial support or whose equity investors lack 
the ability to control the entity’s activities or lack the ability to 
receive expected benefits or absorb obligations in a manner 
that’s consistent with their investment in the entity. A VIE is 
consolidated by its primary beneficiary, the party that has both 
the power to direct the activities that most significantly impact 
the VIE and a variable interest that could potentially be 
significant to the VIE. A variable interest is a contractual, 
ownership or other interest whose value changes with changes in 
the fair value of the VIE’s net assets. To determine whether or 
not a variable interest we hold could potentially be significant to 
the VIE, we consider both qualitative and quantitative factors 
regarding the nature, size and form of our involvement with the 
VIE. We assess whether or not we are the primary beneficiary of 
a VIE on an on-going basis. 

We have segregated our involvement with VIEs between 

those VIEs which we consolidate, those which we do not 
consolidate and those for which we account for the transfers of 
financial assets as secured borrowings. Secured borrowings are 
transactions involving transfers of our financial assets to third 
parties that are accounted for as financings with the assets 
pledged as collateral. Accordingly, the transferred assets remain 
recognized on our balance sheet. Subsequent tables within this 
Note further segregate these transactions by structure type. 

190 

Wells Fargo & Company 

190

Table 9.1 provides the classifications of assets and liabilities 

in our balance sheet for our transactions with VIEs. 

Table 9.1:  Balance Sheet Transactions with VIEs 

(in millions) 

December 31, 2018 

Cash and due from banks 

Interest-earning deposits with banks 

Debt securities:

 Trading debt securities 

 Available-for-sale debt securities (1) 

 Held-to-maturity debt securities 

Loans 

Mortgage servicing rights 

Derivative assets 

Equity securities 

Other assets 

Total assets 

Short-term borrowings 

Derivative liabilities 

Accrued expenses and other liabilities 

Long-term debt 

Total liabilities 

Noncontrolling interests 

Net assets 

December 31, 2017 

Cash and due from banks 

Interest-earning deposits with banks 

Debt securities:

  Trading debt securities 

  Available-for-sale debt securities (1) 

 Held-to-maturity debt securities 

Loans 

Mortgage servicing rights 

Derivative assets 

Equity securities 

Other assets 

Total assets 

Short-term borrowings 

Derivative liabilities 

Accrued expenses and other liabilities 

Long-term debt 

Total liabilities 

Noncontrolling interests 

Net assets 

VIEs that 
we do not 
consolidate 

VIEs that 
we 
consolidate 

Transfers 
that we 
account for 
as secured 
borrowings 

$ 

— 

— 

2,110 

2,686 

510 

139 

8 

45 

— 

— 

1,433 

13,564 

14,761 

53 

11,041 

— 

— 

— 

85 

221 

32,594 

14,062 

— 

— 

200 

317 

— 

94 

— 

— 

— 

6 

617 

493 

—

8 

93 

Total 

139 

8 

2,355

3,003

510 

15,091 

14,761 

53 

11,126 

227 

47,273 

493 

 26 

430 

4,779 

5,728 

 34

— 

26 

231 

3,870 

4,127 

—

— 

—  (2) 

191  (2) 

816  (2) 

1,007 

 34

594 

  —

$  28,467 

13,021 

23 

41,511 

$ 

— 

— 

1,305 

3,288 

485 

4,274 

13,628 

44 

10,740 

— 

116 

371 

— 

— 

— 

12,482 

— 

— 

306 

342 

33,764 

13,617 

— 

106 

244 

3,590 

3,940 

— 

— 

5  (2) 

132  (2) 

1,479  (2) 

1,616 

283 

$ 

29,824 

11,718 

— 

— 

201 

358 

— 

110 

— 

— 

— 

6 

675 

522 

— 

10 

111 

643 

— 

32 

116 

371 

1,506

3,646

485 

16,866 

13,628 

44 

11,046 

348 

48,056 

522 

111 

386 

5,180 

6,199 

283 

41,574 

(1)  Excludes certain debt securities related to loans serviced for the Federal National Mortgage Association (FNMA), Federal Home Loan Mortgage Corporation (FHLMC) and 

GNMA. 

(2)  There were no VIE liabilities with recourse to the general credit of Wells Fargo for the periods presented. 

Transactions with Unconsolidated VIEs 
Our transactions with unconsolidated VIEs include 
securitizations of residential mortgage loans, CRE loans, student 
loans, automobile loans and leases, certain dealer floorplan 
loans; investment and financing activities involving 
collateralized debt obligations (CDOs) backed by asset-backed 
and CRE securities, tax credit structures, collateralized loan 
obligations (CLOs) backed by corporate loans, and other types of 

structured financing. We have various forms of involvement with 
VIEs, including servicing, holding senior or subordinated 
interests, entering into liquidity arrangements, credit default 
swaps and other derivative contracts. Involvements with these 
unconsolidated VIEs are recorded on our balance sheet in debt 
and equity securities, loans, MSRs, derivative assets and 
liabilities, other assets, other liabilities, and long-term debt, as 
appropriate. 

191

Wells Fargo & Company 

191 

  
 
 
Note 9:  Securitizations and Variable Interest Entities (continued) 

Table 9.2 provides a summary of unconsolidated VIEs with 

which we have significant continuing involvement, but we are 
not the primary beneficiary. We do not consider our continuing 
involvement in an unconsolidated VIE to be significant when it 
relates to third-party sponsored VIEs for which we were not the 
transferor (unless we are servicer and have other significant 
forms of involvement) or if we were the sponsor only or sponsor 
and servicer but do not have any other forms of significant 
involvement. 

Significant continuing involvement includes transactions 

where we were the sponsor or transferor and have other 
significant forms of involvement. Sponsorship includes 
transactions with unconsolidated VIEs where we solely or 
materially participated in the initial design or structuring of the 
entity or marketing of the transaction to investors. When we 
transfer assets to a VIE and account for the transfer as a sale, we 

Table 9.2:  Unconsolidated VIEs 

are considered the transferor. We consider investments in 
securities (other than those held temporarily in trading), loans, 
guarantees, liquidity agreements, written options and servicing 
of collateral to be other forms of involvement that may be 
significant. We have excluded certain transactions with 
unconsolidated VIEs from the balances presented in the 
following table where we have determined that our continuing 
involvement is not significant due to the temporary nature and 
size of our variable interests, because we were not the transferor 
or because we were not involved in the design of the 
unconsolidated VIEs. We also exclude from the table secured 
borrowing transactions with unconsolidated VIEs (for 
information on these transactions, see the Transactions with 
Consolidated VIEs and Secured Borrowings section in this Note). 

(in millions) 

December 31, 2018 

Residential mortgage loan securitizations: 

Conforming (2) 

Other/nonconforming 

Commercial mortgage securitizations 

Collateralized debt obligations: 

Debt securities 

Loans (3) 

Asset-based finance structures 

Tax credit structures 

Collateralized loan obligations 

Investment funds 

Other (4) 

Total 

Residential mortgage loan securitizations: 

Conforming 

Other/nonconforming 

Commercial mortgage securitizations 

Collateralized debt obligations: 

Debt securities 

Loans (3) 

Asset-based finance structures 

Tax credit structures 

Collateralized loan obligations 

Investment funds 

Other (4) 

Total 

(continued on following page) 

Total 
VIE 
assets 

Debt and 
equity
interests (1) 

Servicing 

Other 
commitments 
and 

assets  Derivatives 

guarantees  Net assets 

Carrying value – asset (liability) 

$  1,172,833 

2,377 

13,811 

10,596 

153,350 

453 

2,409 

57 

893 

659 

— 

304 

— 

— 

205 

35,185 

12,087 

2 

185 

1,688 

— 

42 

207 

— 

— 

— 

— 

— 

— 

— 

$  1,374,802 

17,780 

14,761 

— 

— 

(22) 

5 

— 

— 

— 

— 

— 

44 

27 

Debt and 
equity
interests (1) 

Servicing 

assets  Derivatives 

(171) 

16,017 

— 

(40) 

(20)

— 

— 

510 

3,240 

 (15)

— 

205 

(3,870) 

8,217 

— 

— 

— 

— 

42 

251 

(4,101) 

28,467 

Maximum exposure to loss 

Other 
commitments 
and 
guarantees 

Total 
exposure 

$ 

2,377 

13,811 

453 

2,409 

—

— 

205 

12,087 

— 

42 

207 

57 

893 

 —

— 

— 

— 

— 

— 

— 

$ 

17,780 

14,761 

— 

— 

28 

1,183 

17,371 

— 

510 

11,563 

14,893 

  5

  20

— 

— 

— 

— 

— 

45 

78 

— 

71 

 25

— 

276 

1,420 

13,507 

— 

— 

158 

— 

42 

410 

14,415 

47,034 

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(continued from previous page) 

(in millions) 

December 31, 2017 

Residential mortgage loan securitizations: 

Conforming (2) 

Other/nonconforming 

Commercial mortgage securitizations 

Collateralized debt obligations: 

Debt securities 

Loans (3) 

Asset-based finance structures 

Tax credit structures 

Collateralized loan obligations 

Investment funds 

Other (4) 

Total 

Residential mortgage loan securitizations: 

Conforming 

Other/nonconforming 

Commercial mortgage securitizations 

Collateralized debt obligations: 

Debt securities 

Loans (3) 

Asset-based finance structures 

Tax credit structures 

Collateralized loan obligations 

Investment funds 

Other (4) 

Total 

Total 
VIE 

Debt and 
equity 
assets  interests (1) 

Servicing 
assets 

Derivatives 

Carrying value - asset (liability) 

Other 
commitments 
and 
guarantees 

Net assets 

$ 1,169,410 

14,175 

144,650 

1,031 

1,481 

2,333 

2,100 

598 

2,198 

— 

1,443 

1,867 

31,852 

11,258 

23 

225 

2,257 

1 

50 

577 

12,665 

73 

890 

— 

— 

— 

— 

— 

— 

— 

$ 1,367,437 

20,092 

13,628 

— 

— 

28 

5 

— 

— 

— 

— 

— 

(95) 

(62) 

Debt and 
equity 
interests (1) 

Servicing 
assets 

Derivatives 

(190) 

14,575 

— 

(34) 

(20) 

— 

— 

(3,590) 

— 

— 

— 

671 

3,082 

(15) 

1,443 

1,867 

7,668 

1 

50 

482 

(3,834) 

29,824 

Maximum exposure to loss 

Other 
commitments 
and 
guarantees 

Total 
exposure 

$ 

2,100 

12,665 

598 

2,198 

— 

1,443 

1,867 

11,258 

1 

50 

577 

73 

890 

— 

— 

— 

— 

— 

— 

— 

$ 

20,092 

13,628 

— 

— 

42 

5 

— 

— 

— 

— 

— 

120 

167 

1,137 

15,902 

— 

671 

10,202 

13,332 

20 

— 

71 

25 

1,443 

1,938 

1,175 

12,433 

— 

— 

157 

1 

50 

854 

12,762 

46,649 

(1) 

Includes total equity interests of $11.0 billion and $10.7 billion at December 31, 2018 and 2017, respectively. Also includes debt interests in the form of both loans and 
securities. Excludes certain debt securities held related to loans serviced for FNMA, FHLMC and GNMA. 

(2)  Excludes assets and related liabilities with a recorded carrying value on our balance sheet of $1.2 billion and $2.2 billion at December 31, 2018 and 2017, respectively, for 

certain delinquent loans that are eligible for repurchase from GNMA loan securitizations. The recorded carrying value represents the amount that would be payable if the 
Company was to exercise the repurchase option. The carrying amounts are excluded from the table because the loans eligible for repurchase do not represent interests in 
the VIEs. 

(3)  Represents senior loans to trusts that are collateralized by asset-backed securities. The trusts invested in senior tranches from a diversified pool of U.S. asset 

securitizations, of which all were current and 100% were rated as investment grade by the primary rating agencies at December 31, 2017. These senior loans were 
accounted for at amortized cost and were subject to the Company’s allowance and credit charge-off policies. The securitization was terminated in first quarter 2018. 
Includes structured financing and credit-linked note structures. At December 31, 2017, also contains investments in auction rate securities (ARS) issued by VIEs that we 
did not sponsor and, accordingly, are unable to obtain the total assets of the entity. 

(4) 

In Table 9.2, “Total VIE assets” represents the remaining 
principal balance of assets held by unconsolidated VIEs using 
the most current information available. For VIEs that obtain 
exposure to assets synthetically through derivative instruments, 
the remaining notional amount of the derivative is included in 
the asset balance. “Carrying value” is the amount in our 
consolidated balance sheet related to our involvement with the 
unconsolidated VIEs. “Maximum exposure to loss” from our 
involvement with off-balance sheet entities, which is a required 
disclosure under GAAP, is determined as the carrying value of 
our involvement with off-balance sheet (unconsolidated) VIEs 
plus the remaining undrawn liquidity and lending commitments, 
the notional amount of net written derivative contracts, and 
generally the notional amount of, or stressed loss estimate for, 
other commitments and guarantees. It represents estimated loss 

that would be incurred under severe, hypothetical 
circumstances, for which we believe the possibility is extremely 
remote, such as where the value of our interests and any 
associated collateral declines to zero, without any consideration 
of recovery or offset from any economic hedges. Accordingly, 
this required disclosure is not an indication of expected loss. 

RESIDENTIAL MORTGAGE LOANS  Residential mortgage loan 
securitizations are financed through the issuance of fixed-rate or 
floating-rate asset-backed securities, which are collateralized by 
the loans transferred to a VIE. We typically transfer loans we 
originated to these VIEs, account for the transfers as sales, retain 
the right to service the loans and may hold other beneficial 
interests issued by the VIEs. We also may be exposed to limited 
liability related to recourse agreements and repurchase 

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Note 9:  Securitizations and Variable Interest Entities (continued) 

agreements we make to our issuers and purchasers, which are 
included in other commitments and guarantees. In certain 
instances, we may service residential mortgage loan 
securitizations structured by third parties whose loans we did 
not originate or transfer. Our residential mortgage loan 
securitizations consist of conforming and nonconforming 
securitizations. 

Conforming residential mortgage loan securitizations are 

those that are guaranteed by the GSEs, including GNMA. 
Because of the power of the GSEs over the VIEs that hold the 
assets from these conforming residential mortgage loan 
securitizations, we do not consolidate them. 

The loans sold to the VIEs in nonconforming residential 
mortgage loan securitizations are those that do not qualify for a 
GSE guarantee. We may hold variable interests issued by the 
VIEs, including senior securities. We do not consolidate the 
nonconforming residential mortgage loan securitizations 
included in the table because we either do not hold any variable 
interests, hold variable interests that we do not consider 
potentially significant or are not the primary servicer for a 
majority of the VIE assets. 

Other commitments and guarantees include amounts 
related to loans sold that we may be required to repurchase, or 
otherwise indemnify or reimburse the investor or insurer for 
losses incurred, due to material breach of contractual 
representations and warranties as well as other retained 
recourse arrangements. The maximum exposure to loss for 
material breach of contractual representations and warranties 
represents a stressed case estimate we utilize for determining 
stressed case regulatory capital needs and is considered to be a 
remote scenario. 

COMMERCIAL MORTGAGE LOAN SECURITIZATIONS 
Commercial mortgage loan securitizations are financed through 
the issuance of fixed or floating-rate asset-backed securities, 
which are collateralized by the loans transferred to the VIE. In a 
typical securitization, we may transfer loans we originate to 
these VIEs, account for the transfers as sales, retain the right to 
service the loans and may hold other beneficial interests issued 
by the VIEs. In certain instances, we may service commercial 
mortgage loan securitizations structured by third parties whose 
loans we did not originate or transfer. We typically serve as 
primary or master servicer of these VIEs. The primary or master 
servicer in a commercial mortgage loan securitization typically 
cannot make the most significant decisions impacting the 
performance of the VIE and therefore does not have power over 
the VIE. We do not consolidate the commercial mortgage loan 
securitizations included in the disclosure because we either do 
not have power or do not have a variable interest that could 
potentially be significant to the VIE. 

COLLATERALIZED DEBT OBLIGATIONS (CDOs)  A CDO is a 
securitization where a VIE purchases a pool of assets consisting 
of asset-backed securities and issues multiple tranches of equity 
or notes to investors. In some CDOs, a portion of the assets are 
obtained synthetically through the use of derivatives such as 
credit default swaps or total return swaps. 

In addition to our role as arranger, we may have other forms 
of involvement with these CDOs. Such involvement may include 
acting as liquidity provider, derivative counterparty, secondary 
market maker or investor. For certain CDOs, we may also act as 
the collateral manager or servicer. We receive fees in connection 
with our role as collateral manager or servicer. 

We assess whether we are the primary beneficiary of CDOs 

based on our role in them in combination with the variable 

interests we hold. Subsequently, we monitor our ongoing 
involvement to determine if the nature of our involvement has 
changed. We are not the primary beneficiary of these CDOs in 
most cases because we do not act as the collateral manager or 
servicer, which generally denotes power. In cases where we are 
the collateral manager or servicer, we are not the primary 
beneficiary because we do not hold interests that could 
potentially be significant to the VIE. 

COLLATERALIZED LOAN OBLIGATIONS (CLOs)  A CLO is a 
securitization where an SPE purchases a pool of assets consisting 
of loans and issues multiple tranches of equity or notes to 
investors. Generally, CLOs are structured on behalf of a third-
party asset manager that typically selects and manages the assets 
for the term of the CLO. Typically, the asset manager has the 
power over the significant decisions of the VIE through its 
discretion to manage the assets of the CLO. We assess whether 
we are the primary beneficiary of CLOs based on our role in 
them and the variable interests we hold. In most cases, we are 
not the primary beneficiary because we do not have the power to 
manage the collateral in the VIE. 

In addition to our role as arranger, we may have other forms 

of involvement with these CLOs. Such involvement may include 
acting as underwriter, derivative counterparty, secondary market 
maker or investor. For certain CLOs, we may also act as the 
servicer, for which we receive fees in connection with that role. 
We also earn fees for arranging these CLOs and distributing the 
securities. 

ASSET-BASED FINANCE STRUCTURES  We engage in various 
forms of structured finance arrangements with VIEs that are 
collateralized by various asset classes including energy contracts, 
automobile and other transportation loans and leases, 
intellectual property, equipment and general corporate credit. 
We typically provide senior financing, and may act as an interest 
rate swap or commodity derivative counterparty when necessary. 
In most cases, we are not the primary beneficiary of these 
structures because we do not have power over the significant 
activities of the VIEs involved in them. 

For example, we have investments in asset-backed securities 

that are collateralized by automobile leases or loans and cash. 
These fixed-rate and variable-rate securities have been 
structured as single-tranche, fully amortizing, unrated bonds 
that are equivalent to investment-grade securities due to their 
significant overcollateralization. The securities are issued by 
VIEs that have been formed by third-party automobile financing 
institutions primarily because they require a source of liquidity 
to fund ongoing vehicle sales operations. The third-party 
automobile financing institutions manage the collateral in the 
VIEs, which is indicative of power in them and we therefore do 
not consolidate these VIEs. 

TAX CREDIT STRUCTURES  We co-sponsor and make 
investments in affordable housing and sustainable energy 
projects that are designed to generate a return primarily through 
the realization of federal tax credits. In some instances, our 
investments in these structures may require that we fund future 
capital commitments at the discretion of the project sponsors. 
While the size of our investment in a single entity may at times 
exceed 50% of the outstanding equity interests, we do not 
consolidate these structures due to the project sponsor’s ability 
to manage the projects, which is indicative of power in them. 

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INVESTMENT FUNDS  We voluntarily waived a portion of our 
management fees for certain money market funds that are 
exempt from the consolidation analysis to ensure the funds 
maintained a minimum level of daily net investment income. 
The amount of fees waived in 2018, 2017 and 2016 was 
$45 million, $53 million, and $109 million, respectively. 

OTHER TRANSACTIONS WITH VIEs  Other VIEs include 
certain entities that issue auction rate securities (ARS) which are 
debt instruments with long-term maturities, that re-price more 
frequently, and preferred equities with no maturity. At 
December 31, 2018, we held no ARS issued by VIEs, compared 
with $400 million at December 31, 2017. We acquired the ARS 
pursuant to agreements entered into in 2008 and 2009. All ARS 
were sold during 2018. 

We did not consolidate the VIEs that issued the ARS 
because we did not have power over the activities of the VIEs. 

TRUST PREFERRED SECURITIES  VIEs that we wholly own 
issue debt securities or preferred equity to third-party investors. 
All of the proceeds of the issuance are invested in debt securities 
or preferred equity that we issue to the VIEs. The VIEs’ 
operations and cash flows relate only to the issuance, 
administration and repayment of the securities held by third 
parties. We do not consolidate these VIEs because the sole assets 
of the VIEs are receivables from us, even though we own all of 
the voting equity shares of the VIEs, have fully guaranteed the 
obligations of the VIEs and may have the right to redeem the 

Table 9.3:  Cash Flows From Sales and Securitization Activity 

third-party securities under certain circumstances. In our 
consolidated balance sheet at December 31, 2018 and 2017, we 
reported the debt securities issued to the VIEs as long-term 
junior subordinated debt with a carrying value of $2.0 billion at 
both dates, and the preferred equity securities issued to the VIEs 
as preferred stock with a carrying value of $2.5 billion at both 
dates. These amounts are in addition to the involvements in 
these VIEs included in the preceding table. 

In 2017, we redeemed $150 million of trust preferred 
securities which were partially included in Tier 2 capital (50% 
credit in 2017) in the transitional framework and were not 
included under the fully-phased framework under the Basel III 
standards. 

Loan Sales and Securitization Activity 
We periodically transfer consumer and CRE loans and other 
types of financial assets in securitization and whole loan sale 
transactions. We typically retain the servicing rights from these 
sales and may continue to hold other beneficial interests in the 
transferred financial assets. We may also provide liquidity to 
investors in the beneficial interests and credit enhancements in 
the form of standby letters of credit. Through these transfers we 
may be exposed to liability under limited amounts of recourse as 
well as standard representations and warranties we make to 
purchasers and issuers. Table 9.3 presents the cash flows for our 
transfers accounted for as sales in which we have a continuing 
involvement with the transferred financial assets. 

(in millions) 

2018 

Other 
financial 
assets 

Mortgage 
loans 

Proceeds from securitizations and whole loan sales 

$  193,721 

Fees from servicing rights retained 

Cash flows from other interests held (1) 

Repurchases of assets/loss reimbursements (2): 

Non-agency securitizations and whole loan transactions 

Agency securitizations (3) 

Servicing advances, net of repayments 

3,337 

698 

3

96 

(154) 

— 

— 

1 

— 

— 

— 

Year ended December 31, 

2017 

Other 
financial 
assets 

25 

— 

1 

—

—

— 

Mortgage 
loans 

252,723 

3,492 

2,898 

26 

133 

(218) 

2016 

Other 
financial 
assets 

347 

— 

1 

— 

— 

— 

Mortgage 
loans 

228,282 

3,352 

2,218 

12 

92 

(269) 

(1)  Cash flows from other interests held include principal and interest payments received on retained bonds and excess cash flows received on interest-only strips. 
(2)  Consists of cash paid to repurchase loans from investors and cash paid to investors to reimburse them for losses on individual loans that are already liquidated. In addition, 

during 2018 and 2017, we paid nothing to third-party investors to settle repurchase liabilities on pools of loans, compared with $11 million in 2016. 

(3)  Represent loans repurchased from GNMA, FNMA, and FHLMC under representation and warranty provisions included in our loan sales contracts. Excludes $7.8 billion in 

delinquent insured/guaranteed loans that we service and have exercised our option to purchase out of GNMA pools in 2018, compared with $8.6 billion and $9.9 billion in 
2017 and 2016, respectively. These loans are predominantly insured by the FHA or guaranteed by the VA. 

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Note 9:  Securitizations and Variable Interest Entities (continued) 

During 2018, 2017 and 2016, we transferred $17.9 billion, 
$16.7 billion and $18.3 billion, respectively, in carrying value of 
commercial mortgages to unconsolidated VIEs and third-party 
investors and recorded the transfers as sales. These transfers 
resulted in gains of $280 million in 2018, $359 million in 2017 
and $429 million in 2016, respectively, because the loans were 
carried at lower of cost or fair value (LOCOM). In connection 
with these transfers, in 2018 we recorded a servicing asset of 
$158 million, initially measured at fair value using a Level 3 
measurement technique, and securities of $81 million, classified 
as Level 2. In 2017, we recorded a servicing asset of $166 million 
and securities of $65 million. In 2016, we recorded a servicing 
asset of $270 million and securities of $258 million. 

Retained Interests from Unconsolidated VIEs 
Table 9.5 provides key economic assumptions and the sensitivity 
of the current fair value of residential mortgage servicing rights 
and other interests held to immediate adverse changes in those 
assumptions. “Other interests held” relate to residential and 
commercial mortgage loan securitizations. Residential 
mortgage-backed securities retained in securitizations issued 
through GSEs, such as FNMA, FHLMC and GNMA, are excluded 
from the table because these securities have a remote risk of 
credit loss due to the GSE guarantee. These securities also have 
economic characteristics similar to GSE mortgage-backed 
securities that we purchase, which are not included in the table. 
Subordinated interests include only those bonds whose credit 
rating was below AAA by a major rating agency at issuance. 
Senior interests include only those bonds whose credit rating 
was AAA by a major rating agency at issuance. The information 
presented excludes trading positions held in inventory. 

In 2018, 2017, and 2016, we recognized net gains of 

$270 million, $701 million and $524 million, respectively, from 
transfers accounted for as sales of financial assets, in which we 
have a continuing involvement with the transferred assets. These 
net gains largely relate to commercial mortgage securitizations, 
and residential mortgage securitizations where the loans were 
not already carried at fair value. 

Sales with continuing involvement during 2018, 2017 and 
2016 largely related to securitizations of residential mortgages 
that are sold to the government-sponsored entities (GSEs), 
including FNMA, FHLMC and GNMA (conforming residential 
mortgage securitizations). During 2018, 2017 and 2016 we 
transferred $177.8 billion, $213.6 billion and $236.6 billion, 
respectively, in fair value of residential mortgages to 
unconsolidated VIEs and third-party investors and recorded the 
transfers as sales. Substantially all of these transfers did not 
result in a gain or loss because the loans were already carried at 
fair value. In connection with all of these transfers, in 2018 we 
recorded a $1.9 billion servicing asset, measured at fair value 
using a Level 3 measurement technique, securities of 
$5.0 billion, classified as Level 2, and a $17 million liability for 
repurchase losses which reflects management’s estimate of 
probable losses related to various representations and 
warranties for the loans transferred, initially measured at fair 
value. In 2017, we recorded a $2.1 billion servicing asset, 
securities of $1.4 billion and a $24 million liability. In 2016, we 
recorded a $2.1 billion servicing asset, securities of $4.4 billion 
and a $36 million liability. 

Table 9.4 presents the key weighted-average assumptions 
we used to measure residential mortgage servicing rights at the 
date of securitization. 

Table 9.4:  Residential Mortgage Servicing Rights 

Residential mortgage servicing rights 

2018 

2017 

2016 

Year ended December 31, 

Prepayment speed (1) 

Discount rate 

Cost to service ($ per loan) (2)  $ 

10.6% 

7.4 

128 

11.5 

7.0 

132 

11.7 

6.5 

132 

(1)  The prepayment speed assumption for residential mortgage servicing rights 
includes a blend of prepayment speeds and default rates. Prepayment speed 
assumptions are influenced by mortgage interest rate inputs as well as our 
estimation of drivers of borrower behavior. 
Includes costs to service and unreimbursed foreclosure costs, which can vary 
period to period depending on the mix of modified government-guaranteed 
loans sold to GNMA. 

(2) 

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Table 9.5:  Retained Interests from Unconsolidated VIEs 

($ in millions, except cost to service amounts) 

Fair value of interests held at December 31, 2018 

Expected weighted-average life (in years) 

Key economic assumptions: 

Prepayment speed assumption (3) 

Decrease in fair value from: 

10% adverse change 

25% adverse change 

Discount rate assumption 

Decrease in fair value from: 

100 basis point increase 

200 basis point increase 

Cost to service assumption ($ per loan) 

Decrease in fair value from: 

10% adverse change 

25% adverse change 

Credit loss assumption 

Decrease in fair value from: 

10% higher losses 

25% higher losses 

Fair value of interests held at December 31, 2017 

Expected weighted-average life (in years) 

Key economic assumptions: 

Prepayment speed assumption (3) 

Decrease in fair value from: 

10% adverse change 

25% adverse change 

Discount rate assumption 

Decrease in fair value from: 

100 basis point increase 

200 basis point increase 

Cost to service assumption ($ per loan) 

Decrease in fair value from: 

10% adverse change 

25% adverse change 

Credit loss assumption 

Decrease in fair value from: 

10% higher losses 

25% higher losses 

Residential 
mortgage
servicing 
rights (1) 

$  14,649 

6.5 

Other interests held 

Commercial (2)

Interest-only 
strips 

Subordinated 
bonds 

16 

3.6 

668 

7.0 

Senior 
bonds 

309 

5.7 

9.9% 

17.7 

$ 

530 

1,301 

1 

1 

8.1% 

14.5 

$ 

615 

1,176 

106 

316 

787 

— 

1 

$ 

$  13,625 

6.2 

19 

3.3 

10.5 % 

20.0 

$ 

565 

1,337 

1 

2 

6.9 % 

14.8 

— 

1 

$ 

652 

1,246 

143 

467 

1,169 

4.3 

37 

72 

5.1% 

2 

5 

596 

6.7 

4.1 

32 

61 

$ 

1.8 % 

— 

— 

3.7 

14 

28 

— 

— 

— 

468 

5.2 

3.1 

20 

39 

— 

— 

— 

(1)  See narrative following this table for a discussion of commercial mortgage servicing rights. 
(2)  Prepayment speed assumptions do not significantly impact the value of commercial mortgage securitization bonds as the underlying commercial mortgage loans experience 

significantly lower prepayments due to certain contractual restrictions, impacting the borrower’s ability to prepay the mortgage. 

(3)  The prepayment speed assumption for residential mortgage servicing rights includes a blend of prepayment speeds and default rates. Prepayment speed assumptions are 

influenced by mortgage interest rate inputs as well as our estimation of drivers of borrower behavior. 

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Note 9:  Securitizations and Variable Interest Entities (continued) 

In addition to residential mortgage servicing rights (MSRs) 

included in the previous table, we have a small portfolio of 
commercial MSRs with a fair value of $2.3 billion and 
$2.0 billion at December 31, 2018 and 2017, respectively. The 
nature of our commercial MSRs, which are carried at LOCOM, is 
different from our residential MSRs. Prepayment activity on 
serviced loans does not significantly impact the value of 
commercial MSRs because, unlike residential mortgages, 
commercial mortgages experience significantly lower 
prepayments due to certain contractual restrictions, impacting 
the borrower’s ability to prepay the mortgage. Additionally, for 
our commercial MSR portfolio, we are typically master/primary 
servicer, but not the special servicer, who is separately 
responsible for the servicing and workout of delinquent and 
foreclosed loans. It is the special servicer, similar to our role as 
servicer of residential mortgage loans, who is affected by higher 
servicing and foreclosure costs due to an increase in delinquent 
and foreclosed loans. Accordingly, prepayment speeds and costs 
to service are not key assumptions for commercial MSRs as they 
do not significantly impact the valuation. The primary economic 
driver impacting the fair value of our commercial MSRs is 
forward interest rates, which are derived from market 
observable yield curves used to price capital markets 
instruments. Market interest rates significantly affect interest 
earned on custodial deposit balances. The sensitivity of the 
current fair value to an immediate adverse 25% change in the 
assumption about interest earned on deposit balances at 
December 31, 2018 and 2017, results in a decrease in fair value 
of $320 million and $278 million, respectively. See Note 10 

Table 9.6:  Off-Balance Sheet Loans Sold or Securitized 

(Mortgage Banking Activities) for further information on our 
commercial MSRs. 

The sensitivities in the preceding paragraph and table are 
hypothetical and caution should be exercised when relying on 
this data. Changes in value based on variations in assumptions 
generally cannot be extrapolated because the relationship of the 
change in the assumption to the change in value may not be 
linear. Also, the effect of a variation in a particular assumption 
on the value of the other interests held is calculated 
independently without changing any other assumptions. In 
reality, changes in one factor may result in changes in others (for 
example, changes in prepayment speed estimates could result in 
changes in the credit losses), which might magnify or counteract 
the sensitivities. 

Off-Balance Sheet Loans 
Table 9.6 presents information about the principal balances of 
off-balance sheet loans that were sold or securitized, including 
residential mortgage loans sold to FNMA, FHLMC, GNMA and 
other investors, for which we have some form of continuing 
involvement (including servicer). Delinquent loans include loans 
90 days or more past due and loans in bankruptcy, regardless of 
delinquency status. For loans sold or securitized where servicing 
is our only form of continuing involvement, we would only 
experience a loss if we were required to repurchase a delinquent 
loan or foreclosed asset due to a breach in representations and 
warranties associated with our loan sale or servicing contracts. 

(in millions) 

Commercial: 

Real estate mortgage 

Total commercial 

Consumer: 

Total loans 

Delinquent loans and
foreclosed assets (1) 

Net charge-offs 

Year ended 

December 31, 

December 31, 

December 31, 

2018 

2017 

2018 

2017 

2018 

2017 

$ 

105,173 

100,875 

105,173 

100,875 

1,008 

1,008 

2,839 

2,839 

739 

739 

466 

466 

1,027 

1,027 

735 

735 

Real estate 1-4 family first mortgage 

1,097,128 

1,126,208 

8,947 

13,393 

Total consumer 

1,097,128 

1,126,208 

8,947 

13,393 

Total off-balance sheet sold or securitized loans (2) 

$  1,202,301 

1,227,083 

9,955 

16,232 

1,205 

1,762 

(1) 

Includes $675 million and $1.2 billion of commercial foreclosed assets and $582 million and $879 million of consumer foreclosed assets at December 31, 2018 and 2017, 
respectively. 

(2)  At December 31, 2018 and 2017, the table includes total loans of $1.1 trillion at both dates, delinquent loans of $6.4 billion and $9.1 billion, and foreclosed assets of 

$442 million and $619 million, respectively, for FNMA, FHLMC and GNMA. Net charge-offs exclude loans sold to FNMA, FHLMC and GNMA as we do not service or manage 
the underlying real estate upon foreclosure and, as such, do not have access to net charge-off information. 

198 

Wells Fargo & Company 

198

  
 
Transactions with Consolidated VIEs and Secured 
Borrowings 
Table 9.7 presents a summary of financial assets and liabilities 
for asset transfers accounted for as secured borrowings and 
involvements with consolidated VIEs. Carrying values of 
“Assets” are presented using GAAP measurement methods, 
which may include fair value, credit impairment or other 

adjustments, and therefore in some instances will differ from 
“Total VIE assets.” For VIEs that obtain exposure synthetically 
through derivative instruments, the remaining notional amount 
of the derivative is included in “Total VIE assets.” On the 
consolidated balance sheet, we separately disclose the 
consolidated assets of certain VIEs that can only be used to settle 
the liabilities of those VIEs. 

Table 9.7:  Transactions with Consolidated VIEs and Secured Borrowings 

Total VIE 
assets 

Assets 

Liabilities 

Noncontrolling
interests 

Net assets 

Carrying value 

(in millions) 

December 31, 2018 

Secured borrowings: 

Municipal tender option bond securitizations 

$ 

Residential mortgage securitizations 

Total secured borrowings 

Consolidated VIEs: 

Commercial and industrial loans and leases 

Nonconforming residential mortgage loan securitizations 

Commercial real estate loans 

Structured asset finance 

Investment funds 

Other 

627 

95 

722 

8,215 

1,947 

3,957 

— 

155 

14 

523 

94 

617 

8,204 

1,732 

3,957 

— 

155 

14 

(501) 

(93)

(594) 

(477) 

(521) 

— 

— 

(5) 

(4) 

Total consolidated VIEs 

14,288 

14,062 

(1,007) 

Total secured borrowings and consolidated VIEs 

$  15,010 

14,679 

(1,601) 

December 31, 2017 

Secured borrowings: 

Municipal tender option bond securitizations 

$ 

Residential mortgage securitizations 

Total secured borrowings 

Consolidated VIEs: 

Commercial and industrial loans and leases 

Nonconforming residential mortgage loan securitizations 

Commercial real estate loans 

Structured asset finance 

Investment funds 

Other 

Total consolidated VIEs 

Total secured borrowings and consolidated VIEs 

We have raised financing through the securitization of 
certain financial assets in transactions with VIEs accounted for 
as secured borrowings. We also consolidate VIEs where we are 
the primary beneficiary. In certain transactions, we provide 
contractual support in the form of limited recourse and liquidity 
to facilitate the remarketing of short-term securities issued to 
third-party investors. Other than this limited contractual 
support, the assets of the VIEs are the sole source of repayment 
of the securities held by third parties. 

MUNICIPAL TENDER OPTION BOND SECURITIZATIONS  As 
part of our normal investment portfolio activities, we consolidate 
municipal bond trusts that hold highly rated, long-term, fixed-
rate municipal bonds, the majority of which are rated AA or 
better. Our residual interests in these trusts generally allow us to 
capture the economics of owning the securities outright, and 
constructively make decisions that significantly impact the 
economic performance of the municipal bond vehicle, primarily 
by directing the sale of the municipal bonds owned by the 

658 

113 

771 

9,116 

2,515 

2,378 

10 

305 

100 

14,424 

$ 

15,195 

565 

110 

675 

8,626 

2,212 

2,378 

6 

305 

90 

13,617 

14,292 

(532)

(111)

(643)

(915) 

(694) 

— 

(4) 

(2) 

(1) 

(1,616) 

(2,259) 

vehicle. In addition, the residual interest owners have the right 
to receive benefits and bear losses that are proportional to 
owning the underlying municipal bonds in the trusts. The trusts 
obtain financing by issuing floating-rate trust certificates that 
reprice on a weekly or other basis to third-party investors. Under 
certain conditions, if we elect to terminate the trusts and 
withdraw the underlying assets, the third-party investors are 
entitled to a small portion of any unrealized gain on the 
underlying assets. We may serve as remarketing agent and/or 
liquidity provider for the trusts. The floating-rate investors have 
the right to tender the certificates at specified dates, often with 
as little as seven days’ notice. Should we be unable to remarket 
the tendered certificates, we are generally obligated to purchase 
them at par under standby liquidity facilities unless the bond’s 
credit rating has declined below investment grade or there has 
been an event of default or bankruptcy of the issuer and insurer. 

— 

 — 

— 

(14) 

— 

— 

— 

(15) 

(5)

(34) 

(34) 

 — 

 —

 — 

(29) 

— 

— 

— 

(230) 

(24) 

(283) 

(283) 

22 

1 

23 

7,713 

1,211 

3,957 

— 

135 

 5 

13,021 

13,044 

33 

 (1)

32 

7,682 

1,518 

2,378 

2 

73 

65 

11,718 

11,750 

199

Wells Fargo & Company 

199 

  
 
 
  
 
 
Note 9:  Securitizations and Variable Interest Entities (continued) 

COMMERCIAL AND INDUSTRIAL LOANS AND LEASES  In 
conjunction with the GE Capital business acquisitions, on 
March 1, 2016, we acquired certain consolidated SPE entities. 
The most significant of these SPEs is a revolving master trust 
entity that purchases dealer floorplan loans and issues senior 
and subordinated notes. The senior notes are held by third 
parties and the subordinated notes and residual equity interests 
are held by us. At December 31, 2018 and 2017, total assets held 
by the master trust were $6.7 billion and $7.6 billion, 
respectively, and the outstanding senior notes were $299 million 
and $773 million, respectively. The other SPEs acquired 
included securitization term trust entities, which purchased 
vendor finance lease and loan assets and issued notes to 
investors, and an SPE that engages in leasing activities to 
specific vendors. The securitization term trusts were dissolved 
during 2017. The remaining other SPE held $1.5 billion and $1.4 
billion in total assets at December 31, 2018 and 2017, 
respectively. We are the primary beneficiary of these acquired 
SPEs due to our ability to direct the significant activities of the 
SPEs, such as our role as servicer, and because we hold variable 
interests that are considered significant. 

NONCONFORMING RESIDENTIAL MORTGAGE LOAN 
SECURITIZATIONS  We have consolidated certain of our 
nonconforming residential mortgage loan securitizations in 
accordance with consolidation accounting guidance. We have 
determined we are the primary beneficiary of these 
securitizations because we have the power to direct the most 
significant activities of the entity through our role as primary 
servicer and also hold variable interests that we have determined 
to be significant. The nature of our variable interests in these 
entities may include beneficial interests issued by the VIE, 
mortgage servicing rights and recourse or repurchase reserve 
liabilities. The beneficial interests issued by the VIE that we hold 
include either subordinate or senior securities held in an amount 
that we consider potentially significant. 

200 

Wells Fargo & Company 

200

 
Note 10:  Mortgage Banking Activities 

Mortgage banking activities, included in the Community 
Banking and Wholesale Banking operating segments, consist of 
residential and commercial mortgage originations, sale activity 
and servicing. 

We apply the amortization method to commercial MSRs and 

apply the fair value method to residential MSRs. Table 10.1 
presents the changes in MSRs measured using the fair value 
method. 

Table 10.1:  Analysis of Changes in Fair Value MSRs 

(in millions) 

Fair value, beginning of year 

Purchases 

Servicing from securitizations or asset transfers (1) 

Sales and other (2) 

Net additions 

Changes in fair value: 

Due to changes in valuation model inputs or assumptions: 

Mortgage interest rates (3) 

Servicing and foreclosure costs (4) 

Discount rates (5) 

Prepayment estimates and other (6) 

Net changes in valuation model inputs or assumptions 

Changes due to collection/realization of expected cash flows over time 

Total changes in fair value 

Fair value, end of year 

Year ended December 31, 

2018 

2017 

2016 

$  13,625 

12,959 

12,415 

— 

2,010 

541 

2,263 

— 

2,204 

(71) 

(23) 

(65) 

1,939 

2,781 

2,139 

1,337 

818 

(830) 

(365) 

960 

(103) 

96 

13 

(132) 

(126) 

543 

106 

— 

(84) 

565 

(1,875) 

(1,989) 

(2,160) 

(915) 

(2,115) 

(1,595) 

$  14,649 

13,625 

12,959 

(1) 
(2) 

(3) 

(4) 

Includes impacts associated with exercising our right to repurchase delinquent loans from GNMA loan securitization pools. 
Includes sales and transfers of MSRs, which can result in an increase of total reported MSRs if the sales or transfers are related to nonperforming loan portfolios or 
portfolios with servicing liabilities. 
Includes prepayment speed changes as well as other valuation changes due to changes in mortgage interest rates (such as changes in estimated interest earned on 
custodial deposit balances). 
Includes costs to service and unreimbursed foreclosure costs. The amount for the year ended December 31, 2018, reflects updated information obtained regarding market 
participants’ views of servicing and foreclosure costs. 

(5)  Reflects discount rate assumption change, excluding portion attributable to changes in mortgage interest rates. The amount for the year ended December 31, 2018, 

reflects updated information obtained regarding market participants’ views of discount rates. 

(6)  Represents changes driven by other valuation model inputs or assumptions including prepayment speed estimation changes and other assumption updates. Prepayment 

speed estimation changes are influenced by observed changes in borrower behavior and other external factors that occur independent of interest rate changes. 

Table 10.2 presents the changes in amortized MSRs. 

Table 10.2:  Analysis of Changes in Amortized MSRs 

(in millions) 

Balance, beginning of year 

Purchases 

Servicing from securitizations or asset transfers 

Amortization 

Balance, end of year (1) 

Fair value of amortized MSRs: 

Beginning of year 

End of year 

Year ended December 31, 

2018 

$ 

1,424 

127 

158 

2017 

1,406 

115 

166 

2016 

1,308 

97 

270 

(266) 

(263) 

(269) 

$ 

1,443 

1,424 

1,406 

$ 

2,025 

2,288 

1,956 

2,025 

1,680 

1,956 

(1)  Commercial amortized MSRs are evaluated for impairment purposes by the following risk strata: agency (GSEs) for multi-family properties and non-agency. There was no 

valuation allowance recorded for the periods presented on the commercial amortized MSRs. 

201

Wells Fargo & Company 

201 

  
 
  
 
Note 10:  Mortgage Banking Activities  (continued) 

We present the components of our managed servicing 
portfolio in Table 10.3 at unpaid principal balance for loans 
serviced and subserviced for others and at book value for owned 
loans serviced. 

Table 10.3:  Managed Servicing Portfolio 

(in billions) 

Residential mortgage servicing: 

Serviced for others 

Owned loans serviced 

Subserviced for others 

Total residential servicing 

Commercial mortgage servicing: 

Serviced for others 

Owned loans serviced 

Subserviced for others 

Total commercial servicing 

Total managed servicing portfolio 

Total serviced for others 

Ratio of MSRs to related loans serviced for others 

Table 10.4 presents the components of mortgage banking 

noninterest income. 

Table 10.4:  Mortgage Banking Noninterest Income 

(in millions) 

Servicing income, net: 

Servicing fees: 

Contractually specified servicing fees 

Late charges 

Ancillary fees 

Unreimbursed direct servicing costs (1) 

Net servicing fees 

Changes in fair value of MSRs carried at fair value: 

Dec 31,
2018 

Dec 31, 
2017 

$  1,164 

1,209 

334 

4 

342 

3 

1,502 

1,554 

543 

121 

9 

673 

$  2,175 

$  1,707 

0.94% 

495 

127 

9 

631 

2,185 

1,704 

0.88 

Year ended December 31, 

2018 

2017 

2016 

$ 

3,613 

3,603 

3,778 

162 

182 

172 

199 

180 

229 

(331) 

(582) 

(819) 

3,626 

3,392 

3,368 

Due to changes in valuation model inputs or assumptions (2) 

(A) 

960 

(126) 

565 

Changes due to collection/realization of expected cash flows over time 

Total changes in fair value of MSRs carried at fair value 

Amortization 

Net derivative gains (losses) from economic hedges (3) 

(B) 

Total servicing income, net 

Net gains on mortgage loan origination/sales activities 

Total mortgage banking noninterest income 

Market-related valuation changes to MSRs, net of hedge results (2)(3) 

(A)+(B) 

(1,875) 

(1,989) 

(2,160) 

(915) 

(2,115) 

(1,595) 

(266) 

(1,072) 

1,373 

1,644 

3,017 

(112) 

$ 

$ 

(263) 

413 

1,427 

2,923 

4,350 

287 

(269) 

261 

1,765 

4,331 

6,096 

826 

Includes costs associated with foreclosures, unreimbursed interest advances to investors, and other interest costs. 

(1) 
(2)  Refer to the analysis of changes in fair value MSRs presented in Table 10.1 in this Note for more detail. 
(3)  Represents results from economic hedges used to hedge the risk of changes in fair value of MSRs. See Note 17 (Derivatives) for additional discussion and detail. 

202 

Wells Fargo & Company 

202

  
 
 
  
 
Note 11:  Intangible Assets 

Table 11.1 presents the gross carrying value of intangible assets 
and accumulated amortization. 

Table 11.1:  Intangible Assets 

December 31, 2018 

December 31, 2017 

Gross 
carrying 
value 

Accumulated 
amortization 

Net 
carrying 
value 

Gross 
carrying 
value 

Accumulated 
amortization 

Net carrying
value 

(in millions) 

Amortized intangible assets (1): 

MSRs (2) 

Core deposit intangibles 

Customer relationship and other intangibles 

$ 

4,161 

(2,718) 

1,443 

12,834 

3,994 

(12,834) 

(3,449) 

— 

545 

Total amortized intangible assets 

$ 

20,989 

(19,001) 

1,988 

Unamortized intangible assets: 

MSRs (carried at fair value) (2) 

$ 

14,649 

Goodwill 

Trademark 

26,418 

14 

(1)  Excludes fully amortized intangible assets. 
(2)  See Note 10 (Mortgage Banking Activities) for additional information on MSRs. 

(2,452) 

(12,065) 

(3,153) 

(17,670) 

1,424 

769 

841 

3,034 

3,876 

12,834 

3,994 

20,704 

13,625 

26,587 

14 

Table 11.2 provides the current year and estimated future 

amortization expense for amortized intangible assets. We based 
our projections of amortization expense shown below on existing 

asset balances at December 31, 2018. Future amortization 
expense may vary from these projections. 

Table 11.2:  Amortization Expense for Intangible Assets 

(in millions) 

Year ended December 31, 2018 (actual) 

Estimate for year ended December 31, 

2019 

2020 

2021 

2022 

2023 

Amortized MSRs 

Core deposit 
intangibles 

Customer 
relationship and
other 
intangibles (1) 

$ 

$ 

266 

769 

299 

260 

233 

200 

178 

150 

— 

— 

— 

— 

— 

116 

97 

83 

69 

59 

Total 

1,334 

376 

330 

283 

247 

209 

(1)  The year ended December 31, 2018, balance includes $10 million for lease intangible amortization. 

203

Wells Fargo & Company 

203 

 
  
 
 
  
 
 
Note 11:  Intangible Assets  (continued) 

Table 11.3 shows the allocation of goodwill to our reportable 

operating segments. 

Table 11.3:  Goodwill 

(in millions) 

December 31, 2016 

Reclassification of goodwill held for sale to other assets (2) 

Reduction in goodwill related to divested businesses and other (2) 

Goodwill from business combinations 

December 31, 2017 (1) 

Reclassification of goodwill held for sale to other assets 

Reduction in goodwill related to divested businesses and other 

Community
Banking 

Wholesale 
Banking 

$ 

16,849 

— 

— 

— 

$ 

16,849 

(155) 

(9) 

8,585 

(116) 

(14) 

— 

8,455 

— 

(5)

Wealth and 
Investment 
Management 

Consolidated 
Company 

1,259 

26,693 

— 

— 

24 

(116) 

(14) 

24 

1,283 

26,587 

— 

— 

(155) 

(14)

December 31, 2018 (1) 

$ 

16,685 

8,450 

1,283 

26,418 

(1)  At December 31, 2017, other assets included Goodwill classified as held-for-sale of $13 million related to the sales agreement for Wells Fargo Shareowner Services. At 

December 31, 2018, there was no Goodwill classified as held-for-sale in other assets. 

(2)  The prior period has been revised to conform with the current period presentation. 

We assess goodwill for impairment at a reporting unit level, 

which is one level below the operating segments. Our goodwill 
was not impaired at December 31, 2018 and 2017. The fair values 
exceeded the carrying amount of our respective reporting units 
by approximately 42% to 544% at December 31, 2018. See 
Note 26 (Operating Segments) for further information on 
management reporting. 

204 

Wells Fargo & Company 

204

  
 
 
 
 
Note 12:  Deposits 

Table 12.1 presents a summary of the time certificates of deposit 
(CDs) and other time deposits issued by domestic and foreign 
offices. 

The contractual maturities of the domestic time deposits 

with a denomination of $100,000 or more are presented in 
Table 12.3. 

Table 12.1:  Time Certificates of Deposits and Other Time 
Deposits 

Table 12.3:  Contractual Maturities of Domestic Time Deposits 

(in millions) 

Three months or less 

After three months through six months 

After six months through twelve months 

After twelve months 

Total 

2018 

$ 

13,724 

12,292 

12,945 

3,504 

$ 

42,465 

Demand deposit overdrafts of $624 million and 

$371 million were included as loan balances at December 31, 
2018 and 2017, respectively. 

(in billions) 

Dec 31, 

Dec 31, 

2018 

2017 

Total domestic and foreign 

$ 

130.6 

128.6 

Domestic: 

$100,000 or more 

$250,000 or more 

Foreign: 

$100,000 or more 

$250,000 or more 

42.5 

37.1 

4.6 

4.6 

52.7 

46.9 

13.4 

13.4 

Substantially all CDs and other time deposits issued by 

domestic and foreign offices were interest bearing and a 
significant portion of our foreign time deposits with a 
denomination of $100,000 or more have maturities of less than 
7 days. 

The contractual maturities of these deposits are presented 

in Table 12.2. 

Table 12.2:  Contractual Maturities of CDs and Other Time 
Deposits 

(in millions) 

December 31, 2018 

2019 

2020 

2021 

2022 

2023 

Thereafter 

Total 

$ 

88,435 

25,986 

6,324 

3,320 

2,868 

3,712 

$ 

130,645 

205

Wells Fargo & Company 

205 

  
  
 
  
 
Note 13:  Short-Term Borrowings 

Table 13.1 shows selected information for short-term 
borrowings, which generally mature in less than 30 days. We 
pledge certain financial instruments that we own to collateralize 
repurchase agreements and other securities financings. For 

additional information, see the “Pledged Assets” section of 
Note 15 (Guarantees, Pledged Assets and Collateral, and Other 
Commitments). 

Table 13.1:  Short-Term Borrowings 

(in millions) 

As of December 31, 

Federal funds purchased and securities sold under agreements to

repurchase 

Commercial paper 

Amount 

2018 

Rate 

Amount 

2017 

Rate 

Amount 

2016 

Rate 

$ 

92,430 

2.65% 

$ 

88,684 

1.30% 

$ 

78,124 

0.17% 

— 

— 

— 

— 

120 

Other short-term borrowings 

13,357 

1.63 

14,572 

0.72 

18,537 

Total 

Year ended December 31, 

Average daily balance 

Federal funds purchased and securities sold under agreements to

repurchase 

Commercial paper 

Other short-term borrowings 

Total 

Maximum month-end balance 

$ 

105,787 

2.52 

$  103,256 

1.22 

$ 

96,781 

$ 

90,348 

1.78 

$ 

82,507 

0.90 

$ 

99,955 

— 

— 

16 

13,919 

0.79 

16,399 

0.95 

0.13 

256 

14,976 

$ 

104,267 

1.65 

$ 

98,922 

0.77 

$  115,187 

Federal funds purchased and securities sold under agreements to

repurchase (1) 

Commercial paper (2) 

Other short-term borrowings (3) 

$ 

93,918 

N/A 

$ 

91,604 

N/A 

$  109,645 

— 

16,924 

N/A

N/A 

78 

19,439 

N/A 

N/A 

519 

18,537 

N/A- Not applicable 
(1)  Highest month-end balance in each of the last three years was November 2018, November 2017 and October 2016. 
(2)  There were no month-end balances in 2018; highest month-end balance in the remaining years was January 2017 and March 2016. 
(3)  Highest month-end balance in each of the last three years was January 2018, February 2017 and December 2016. 

0.93 

0.28 

0.19 

0.33 

0.86 

0.02 

0.29 

N/A 

N/A 

N/A 

206 

Wells Fargo & Company 

206

  
 
 
 
Note 14:  Long-Term Debt 

We issue long-term debt denominated in multiple currencies, 
largely in U.S. dollars. Our issuances have both fixed and 
floating interest rates. As a part of our overall interest rate risk 
management strategy, we often use derivatives to manage our 
exposure to interest rate risk. We also use derivatives to manage 
our exposure to foreign currency risk. As a result, approximately 
half of the long-term debt presented below is hedged in a fair 
value or cash flow hedge relationship. See Note 17 (Derivatives) 
for further information on qualifying hedge contracts. 

Table 14.1:  Long-Term Debt 

Table 14.1 presents a summary of our long-term debt 

carrying values, reflecting unamortized debt discounts and 
premiums, and purchase accounting adjustments, where 
applicable. The interest rates displayed represent the range of 
contractual rates in effect at December 31, 2018. These interest 
rates do not include the effects of any associated derivatives 
designated in a hedge accounting relationship. 

(in millions) 

Maturity date(s) 

Stated interest rate(s) 

Wells Fargo & Company (Parent only) 

December 31, 

2018 

2017 

Senior 

Fixed-rate notes (1) 

Floating-rate notes 

FixFloat notes 

Structured notes (2) 

Total senior debt - Parent 

Subordinated 

Fixed-rate notes (3) 

Total subordinated debt - Parent 

Junior subordinated 

Fixed-rate notes - hybrid trust securities 

Floating-rate notes 

Total junior subordinated debt - Parent (4) 

Total long-term debt - Parent (3) 

Wells Fargo Bank, N.A. and other bank entities (Bank) 

Senior 

Fixed-rate notes 

Floating-rate notes 

FixFloat notes 

Fixed-rate advances - Federal Home Loan Bank (FHLB) (5) 

Floating-rate advances - FHLB (5) 

Structured notes (2) 

Capital leases 

Total senior debt - Bank 

Subordinated 

Fixed-rate notes 

Total subordinated debt - Bank 

Junior subordinated 

Floating-rate notes 

Total junior subordinated debt - Bank (4) 

Long-term debt issued by VIE - Fixed rate (6) 

Long-term debt issued by VIE - Floating rate (6) 

Mortgage notes and other debt (7) 

Total long-term debt - Bank 

(continued on following page) 

2019-2045 

2019-2048 

2028 

2019-2056 

0.38-6.75% 

$ 

77,742 

0.10-4.08% 

19,553 

3.58% 

2,901 

7,984 

84,652 

22,463 

2,961 

7,442 

108,180 

117,518 

2023-2046 

3.45-7.57% 

2029-2036 

2027 

5.95-7.95% 

2.94-3.44% 

25,428 

25,428 

27,132 

27,132 

1,308 

308 

1,616 

1,369 

299 

1,668 

135,224 

146,318 

2019-2023 

2019-2053 

2021 

2019-2031 

2019-2021 

2019-2037 

2019-2029 

1.75-3.63% 

14,222 

2.33-3.57% 

3.33% 

3.83-7.50% 

6,617 

1,998 

51 

7,732 

4,317 

— 

62 

2.44-3.28% 

53,825 

47,825 

2.87-17.78% 

1,646 

36 

743 

39 

78,395 

60,718 

2023-2038 

5.25-7.74% 

2027 

3.09-3.19% 

2020-2047 

2020-2047 

2019-2057 

6.00% 

2.46-13.02% 

0.20-9.20% 

6,637 

5,199 

5,199 

352 

352 

160 

656 

5,408 

5,408 

342 

342 

268 

1,211 

7,291 

91,399 

75,238 

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Note 14:  Long-Term Debt (continued) 

(continued from previous page) 

(in millions) 

Other consolidated subsidiaries 

Senior 

Fixed-rate notes 

Structured notes (2) 

Maturity date(s) 

Stated interest rate(s) 

December 31, 

2018 

2017 

Total senior debt - Other consolidated subsidiaries 

Mortgage notes and other (7) 

2026 

4.08% 

Total long-term debt - Other consolidated subsidiaries 

Total long-term debt 

6 

2,389 

32 

2,421 

1 

3,391 

73 

3,464 

$  229,044 

225,020 

2019-2023 

2021-2028 

2.94-3.46% 

2,383 

3,390 

(1) 
(2) 

(3) 

Includes $59 million of outstanding zero coupon callable notes at December 31, 2018. 
Included in the table are certain structured notes that have coupon or repayment terms linked to the performance of debt or equity securities, an embedded equity, 
commodity, or currency index, or basket of indices accounted for separately from the note as a free-standing derivative, and the maturity may be accelerated based on the 
value of a referenced index or security. For information on embedded derivatives, see the “Derivatives Not Designated as Hedging Instruments” section in Note 17 
(Derivatives). In addition, a major portion consists of zero coupon callable notes where interest is paid as part of the final redemption amount. 
Includes fixed-rate subordinated notes issued by the Parent at a discount of $131 million and $133 million in 2018 and 2017, respectively, and debt issuance costs of 
$2 million in both 2018 and 2017, to effect a modification of Wells Fargo Bank, NA notes. These subordinated notes are carried at their par amount on the balance sheet of 
the Parent presented in Note 27 (Parent-Only Financial Statements). In addition, Parent long-term debt presented in Note 27 also includes affiliate related issuance costs of 
$278 million and $323 million in 2018 and 2017, respectively. 

(4)  Represents junior subordinated debentures held by unconsolidated wholly-owned trusts formed for the sole purpose of issuing trust preferred securities. See Note 9 

(Securitizations and Variable Interest Entities) for additional information on our trust preferred security structures. 

(5)  At December 31, 2018 and 2017, FHLB advances were secured by residential loan collateral. 
(6)  For additional information on VIEs, see Note 9 (Securitizations and Variable Interest Entities). 
(7)  A major portion related to securitizations and secured borrowings, see Note 9 (Securitizations and Variable Interest Entities). 

We issue long-term debt in a variety of maturities and 
currencies to achieve cost-efficient funding and to maintain an 
appropriate maturity profile. Long-term debt of $229.0 billion at 
December 31, 2018, increased $4.0 billion from December 31, 
2017. We issued $47.6 billion of long-term debt in 2018. 

The aggregate carrying value of long-term debt that matures 

(based on contractual payment dates) as of December 31, 2018, 
in each of the following five years and thereafter is presented in 
Table 14.2. 

Table 14.2:  Maturity of Long-Term Debt 

(in millions) 

2019 

2020 

2021 

2022 

2023 

Thereafter 

Total 

December 31, 2018 

Wells Fargo & Company (Parent Only) 

Senior notes 

Subordinated notes 

Junior subordinated notes 

Total long-term debt - Parent 

Wells Fargo Bank, N.A. and other bank entities (Bank) 

Senior notes 

Subordinated notes 

Junior subordinated notes 

Securitizations and other bank debt 

Total long-term debt - Bank 

Other consolidated subsidiaries 

Senior notes 

Securitizations and other bank debt 

Total long-term debt - Other consolidated subsidiaries 

$ 

6,713 

13,459 

17,923 

17,772 

10,932 

41,381 

108,180 

— 

— 

— 

— 

— 

— 

— 

— 

3,544 

21,884 

25,428 

— 

1,616 

1,616 

6,713 

13,459 

17,923 

17,772 

14,476 

64,881 

135,224 

36,653 

18,498 

20,218 

— 

— 

— 

— 

— 

— 

2,084 

1,647 

574 

38,737 

20,145 

20,792 

1,097 

— 

1,097 

— 

— 

— 

920 

— 

920 

40 

— 

— 

268 

308 

— 

— 

— 

2,807 

1,043 

— 

119 

179 

78,395 

4,156 

5,199 

352 

352 

2,761 

7,453 

3,969 

7,448 

91,399 

367 

— 

367 

5 

32 

37 

2,389 

32 

2,421 

Total long-term debt 

$  46,547 

33,604 

39,635 

18,080 

18,812 

72,366 

229,044 

As part of our long-term and short-term borrowing 

arrangements, we are subject to various financial and 
operational covenants. Some of the agreements under which 
debt has been issued have provisions that may limit the merger 
or sale of certain subsidiary banks and the issuance of capital 
stock or convertible securities by certain subsidiary banks. At 
December 31, 2018, we were in compliance with all the 
covenants. 

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Note 15:  Guarantees, Pledged Assets and Collateral, and Other Commitments 

Guarantees are contracts that contingently require us to make 
payments to a guaranteed party based on an event or a change in 
an underlying asset, liability, rate or index. Guarantees are 
generally in the form of standby letters of credit, securities 

lending and other indemnifications, written put options, 
recourse obligations, and other types of arrangements. Table 15.1 
shows carrying value, maximum exposure to loss on our 
guarantees and the related non-investment grade amounts. 

Table 15.1:  Guarantees – Carrying Value and Maximum Exposure to Loss 

(in millions) 

December 31, 2018 

Carrying 
value of 

Expires in 
obligation  one year or 
less 

(asset) 

Maximum exposure to loss 

Expires 
after one 
year 
through 
three years 

Expires
after three 
years 
through 
five years 

Expires 
after five 
years 

Non-
investment 
grade 

Total 

Written put options (3) 

(455) 

14,758 

12,706 

Standby letters of credit (1) 

$ 

Securities lending and other

indemnifications (2) 

Written put options (3) 

Loans and MLHFS sold with recourse (4) 

Factoring guarantees 

Other guarantees 

Total guarantees 

December 31, 2017 

Standby letters of credit (1) 

Securities lending and other indemnifications

(2) 

$ 

$ 

Loans and MLHFS sold with recourse (4) 

Factoring guarantees 

Other guarantees 

Total guarantees 

40 

— 

14,636 

7,897 

3,398 

497 

26,428 

8,027 

— 

1 

— 

1,044 

1,045 

1 

(185) 

17,243 

10,502 

54 

— 

1 

104 

889 

— 

653 

— 

— 

3,066 

1,207 

— 

3 

400 

31,211 

21,732 

10,163 

12,127 

9,079 

— 

2,959 

889 

2,962 

751 

1 

(90) 

32,872 

19,053 

7,674 

15,063 

74,662 

39,591 

15,357 

7,908 

3,068 

645 

26,978 

8,773 

39 

—

—

— 

51 

— 

1 

165 

747 

7 

533 

— 

— 

2

3,890 

934 

— 

2 

809

1,038 

9,385 

— 

4,175 

811 

32,392 

11,017 

747 

4,184 

2 

19,087 

8,155 

668 

7 

$ 

(364) 

31,034 

21,147 

7,896 

16,052 

76,129 

36,692 

(1)  Total maximum exposure to loss includes direct pay letters of credit (DPLCs) of $7.5 billion and $8.1 billion at December 31, 2018 and 2017, respectively. We issue DPLCs 
to provide credit enhancements for certain bond issuances. Beneficiaries (bond trustees) may draw upon these instruments to make scheduled principal and interest 
payments, redeem all outstanding bonds because a default event has occurred, or for other reasons as permitted by the agreement. We also originate multipurpose lending 
commitments under which borrowers have the option to draw on the facility in one of several forms, including as a standby letter of credit. Total maximum exposure to loss 
includes the portion of these facilities for which we have issued standby letters of credit under the commitments. 
Includes indemnifications provided to certain third-party clearing agents. Outstanding customer obligations under these arrangements were $70 million and $92 million 
with related collateral of $974 million and $717 million at December 31, 2018 and 2017, respectively. Estimated maximum exposure to loss was $1.0 billion at 
December 31, 2018, and $809 million at December 31, 2017. 

(2) 

(3)  Written put options, which are in the form of derivatives, are also included in the derivative disclosures in Note 17 (Derivatives). Carrying value net asset position is a result 

of certain deferred premium option trades. 

(4)  Represent recourse provided, predominantly to the GSEs, on loans sold under various programs and arrangements. Under these arrangements, we repurchased $3 million 

and $5 million of loans associated with these agreements during 2018 and 2017, respectively. 

“Maximum exposure to loss” and “Non-investment grade” 

are required disclosures under GAAP. Non-investment grade 
represents those guarantees on which we have a higher risk of 
being required to perform under the terms of the guarantee. If 
the underlying assets under the guarantee are non-investment 
grade (that is, an external rating that is below investment grade 
or an internal credit default grade that is equivalent to a below 
investment grade external rating), we consider the risk of 
performance to be high. Internal credit default grades are 
determined based upon the same credit policies that we use to 
evaluate the risk of payment or performance when making loans 
and other extensions of credit. Credit quality indicators we 
usually consider in evaluating risk of payments or performance 
are described in Note 6 (Loans and Allowance for Credit Losses). 
Maximum exposure to loss represents the estimated loss 

that would be incurred under an assumed hypothetical 
circumstance, despite what we believe is a remote possibility, 
where the value of our interests and any associated collateral 
declines to zero. Maximum exposure to loss estimates in Table 
15.1 do not reflect economic hedges or collateral we could use to 
offset or recover losses we may incur under our guarantee 
agreements. Accordingly, this required disclosure is not an 

indication of expected loss. We believe the carrying value, which 
is either fair value for derivative-related products or the 
allowance for lending-related commitments, is more 
representative of our exposure to loss than maximum exposure 
to loss. 

STANDBY LETTERS OF CREDIT  We issue standby letters of 
credit, which include performance and financial guarantees, for 
customers in connection with contracts between our customers 
and third parties. Standby letters of credit are agreements where 
we are obligated to make payment to a third party on behalf of a 
customer if the customer fails to meet their contractual 
obligations. We consider the credit risk in standby letters of 
credit and commercial and similar letters of credit in 
determining the allowance for credit losses. 

SECURITIES LENDING AND OTHER INDEMNIFICATIONS  As 
a securities lending agent, we lend debt and equity securities 
from participating institutional clients’ portfolios to third-party 
borrowers. These arrangements are for an indefinite period of 
time, and we indemnify our clients against default by the 
borrower in returning these lent securities. This indemnity is 

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Note 15:  Guarantees, Pledged Assets and Collateral, and Other Commitments (continued) 

supported by collateral received from the borrowers and is 
generally in the form of cash or highly liquid securities that are 
marked to market daily. 

We use certain third-party clearing agents to clear and settle 

transactions on behalf of some of our institutional brokerage 
customers. We indemnify the clearing agents against loss that 
could occur for non-performance by our customers on 
transactions that are not sufficiently collateralized. Transactions 
subject to the indemnifications may include customer 
obligations related to the settlement of margin accounts and 
short positions, such as written call options and securities 
borrowing transactions. 

We enter into other types of indemnification agreements in 

the ordinary course of business under which we agree to 
indemnify third parties against any damages, losses and 
expenses incurred in connection with legal and other 
proceedings arising from relationships or transactions with us. 
These relationships or transactions include those arising from 
service as a director or officer of the Company, underwriting 
agreements relating to our securities, acquisition agreements 
and various other business transactions or arrangements. 
Because the extent of our obligations under these agreements 
depends entirely upon the occurrence of future events, we are 
unable to determine our potential future liability under these 
agreements. We do, however, record a liability for residential 
mortgage loans that we expect to repurchase pursuant to various 
representations and warranties. 

WRITTEN PUT OPTIONS  Written put options are contracts 
that give the counterparty the right to sell to us an underlying 
instrument held by the counterparty at a specified price and may 
include options, floors, caps and credit default swaps. These 
written put option contracts generally permit net settlement. 
While these derivative transactions expose us to risk if the option 
is exercised, we manage this risk by entering into offsetting 
trades or by taking short positions in the underlying instrument. 
We offset market risk related to put options written to customers 
with cash securities or other offsetting derivative transactions. 
Additionally, for certain of these contracts, we require the 
counterparty to pledge the underlying instrument as collateral 
for the transaction. Our ultimate obligation under written put 
options is based on future market conditions and is only 
quantifiable at settlement. See Note 17 (Derivatives) for 
additional information regarding written derivative contracts. 

LOANS AND MLHFS SOLD WITH RECOURSE  In certain sales 
and securitizations of loans, including mortgage loans, we 
provide recourse to the buyer whereby we are required to 
indemnify the buyer for any loss on the loan up to par value plus 
accrued interest. We provide recourse, predominantly to GSEs, 
on loans sold under various programs and arrangements. 
Substantially all of these programs and arrangements require 
that we share in the loans’ credit exposure for their remaining 
life by providing recourse to the GSE, up to 33.33% of actual 
losses incurred on a pro-rata basis in the event of borrower 
default. Under the remaining recourse programs and 
arrangements, if certain events occur within a specified period of 
time from transfer date, we have to provide limited recourse to 
the buyer to indemnify them for losses incurred for the 
remaining life of the loans. The maximum exposure to loss 
reported in Table 15.1 represents the outstanding principal 
balance of the loans sold or securitized that are subject to 
recourse provisions or the maximum losses per the contractual 
agreements. However, we believe the likelihood of loss of the 
entire balance due to these recourse agreements is remote, and 
amounts paid can be recovered in whole or in part from the sale 
of collateral. We also provide representation and warranty 
guarantees on loans sold under the various recourse programs 
and arrangements. Our loss exposure relative to these 
guarantees is separately considered and provided for, as 
necessary, in determination of our liability for loan repurchases 
due to breaches of representation and warranties. 

FACTORING GUARANTEES  Under certain factoring 
arrangements, we may be required to purchase trade receivables 
from third parties, if receivable debtors default on their payment 
obligations. 

OTHER GUARANTEES  We are members of exchanges and 
clearing houses that we use to clear our trades and those of our 
customers. It is common that all members in these organizations 
are required to collectively guarantee the performance of other 
members. Our obligations under the guarantees are based on 
either a fixed amount or a multiple of the collateral we are 
required to maintain with these organizations. We have not 
recorded a liability for these arrangements as of the dates 
presented in Table 15.1 because we believe the likelihood of loss 
is remote. 

We also have contingent performance arrangements related 
to various customer relationships and lease transactions. We are 
required to pay the counterparties to these agreements if third 
parties default on certain obligations. 

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Pledged Assets 
As part of our liquidity management strategy, we pledge various 
assets to secure trust and public deposits, borrowings and letters 
of credit from the FHLB and FRB, securities sold under 
agreements to repurchase (repurchase agreements), securities 
lending arrangements, and for other purposes as required or 
permitted by law or insurance statutory requirements. The types 
of collateral we pledge include securities issued by federal 
agencies, GSEs, domestic and foreign companies and various 
commercial and consumer loans. Table 15.2 provides the total 
carrying amount of pledged assets by asset type and pledged off-

balance sheet securities for securities financings. The table 
excludes pledged consolidated VIE assets of $14.1 billion and 
$13.6 billion at December 31, 2018 and 2017, respectively, which 
can only be used to settle the liabilities of those entities. The 
table also excludes $617 million and $675 million in assets 
pledged in transactions with VIE’s accounted for as secured 
borrowings at December 31, 2018 and 2017, respectively. See 
Note 9 (Securitizations and Variable Interest Entities) for 
additional information on consolidated VIE assets and secured 
borrowings. 

Table 15.2:  Pledged Assets 

(in millions) 

Held for trading: 

Debt securities 

Equity securities 

Dec 31, 

2018 

$ 

96,616 

9,695 

Dec 31, 

2017 

96,993 

12,161 

       Total pledged assets held for trading (1) 

106,311 

109,154 

Not held for trading: 

Debt securities and other (2) 

Mortgage loans held for sale and loans (3) 

    Total pledged assets not held for trading 

Total pledged assets 

62,438 

453,894 

516,332 

$ 

622,643 

73,592 

469,554 

543,146 

652,300 

(2) 

(1)  Consists of pledged assets held for trading of $45.5 billion and $41.9 billion at December 31, 2018 and 2017, respectively, and off-balance sheet securities of $60.8 billion 
and $67.3 billion as of the same dates, respectively, that are pledged as collateral for repurchase agreements and other securities financings. Total pledged assets held for 
trading includes $106.2 billion and $109.0 billion at December 31, 2018 and 2017, respectively, that permit the secured parties to sell or repledge the collateral. 
Includes carrying value of $4.2 billion and $5.0 billion (fair value of $4.1 billion and $5.0 billion) in collateral for repurchase agreements at December 31, 2018 and 2017, 
respectively, which are pledged under agreements that do not permit the secured parties to sell or repledge the collateral. Also includes $68 million and $64 million in 
collateral pledged under repurchase agreements at December 31, 2018 and 2017, respectively, that permit the secured parties to sell or repledge the collateral. 
Substantially all other pledged securities are pursuant to agreements that do not permit the secured party to sell or repledge the collateral. 
Includes mortgage loans held for sale of $7.4 billion and $2.6 billion at December 31, 2018 and 2017, respectively. Substantially all of the total mortgage loans held for 
sale and loans are pledged under agreements that do not permit the secured parties to sell or repledge the collateral. Amounts exclude $1.2 billion and $2.2 billion at 
December 31, 2018 and 2017, respectively, of pledged loans recorded on our balance sheet representing certain delinquent loans that are eligible for repurchase from 
GNMA loan securitizations. 

(3) 

Securities Financing Activities 
We enter into resale and repurchase agreements and securities 
borrowing and lending agreements (collectively, “securities 
financing activities”) typically to finance trading positions 
(including securities and derivatives), acquire securities to cover 
short trading positions, accommodate customers’ financing 
needs, and settle other securities obligations. These activities are 
conducted through our broker-dealer subsidiaries and to a lesser 
extent through other bank entities. Most of our securities 
financing activities involve high quality, liquid securities such as 
U.S. Treasury securities and government agency securities, and 
to a lesser extent, less liquid securities, including equity 
securities, corporate bonds and asset-backed securities. We 
account for these transactions as collateralized financings in 
which we typically receive or pledge securities as collateral. We 
believe these financing transactions generally do not have 
material credit risk given the collateral provided and the related 
monitoring processes. 

OFFSETTING OF SECURITIES FINANCING ACTIVITIES  Table 
15.3 presents resale and repurchase agreements subject to 
master repurchase agreements (MRA) and securities borrowing 
and lending agreements subject to master securities lending 
agreements (MSLA). We account for transactions subject to 
these agreements as collateralized financings, and those with a 
single counterparty are presented net on our balance sheet, 
provided certain criteria are met that permit balance sheet 
netting. Most transactions subject to these agreements do not 

meet those criteria and thus are not eligible for balance sheet 
netting. 

Collateral we pledged consists of non-cash instruments, 
such as securities or loans, and is not netted on the balance sheet 
against the related liability. Collateral we received includes 
securities or loans and is not recognized on our balance sheet. 
Collateral pledged or received may be increased or decreased 
over time to maintain certain contractual thresholds, as the 
assets underlying each arrangement fluctuate in value. 
Generally, these agreements require collateral to exceed the 
asset or liability recognized on the balance sheet. The following 
table includes the amount of collateral pledged or received 
related to exposures subject to enforceable MRAs or MSLAs. 
While these agreements are typically over-collateralized, U.S. 
GAAP requires disclosure in this table to limit the reported 
amount of such collateral to the amount of the related 
recognized asset or liability for each counterparty. 

In addition to the amounts included in Table 15.3, we also 
have balance sheet netting related to derivatives that is disclosed 
in Note 17 (Derivatives). 

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Note 15:  Guarantees, Pledged Assets and Collateral, and Other Commitments (continued) 

Table 15.3:  Offsetting – Securities Financing Activities 

(in millions) 

Assets: 

Resale and securities borrowing agreements 

Gross amounts recognized 

Gross amounts offset in consolidated balance sheet (1) 

Net amounts in consolidated balance sheet (2) 

Collateral not recognized in consolidated balance sheet (3) 

Net amount (4) 

Liabilities: 

Repurchase and securities lending agreements 

Gross amounts recognized (5) 

Gross amounts offset in consolidated balance sheet (1) 

Net amounts in consolidated balance sheet (6) 

Collateral pledged but not netted in consolidated balance sheet (7) 

Net amount (8) 

Dec 31, 

2018 

Dec 31, 

2017 

$ 

112,662 

(15,258) 

97,404 

(96,734) 

$ 

670 

$ 

106,248 

(15,258) 

90,990 

(90,798) 

$ 

192 

121,135 

(23,188) 

97,947 

(96,829) 

1,118 

111,488 

(23,188) 

88,300 

(87,918) 

382 

(1)  Represents recognized amount of resale and repurchase agreements with counterparties subject to enforceable MRAs that have been offset in the consolidated balance 

sheet. 

(2)  At December 31, 2018 and 2017, includes $80.1 billion and $78.9 billion, respectively, classified on our consolidated balance sheet in federal funds sold and securities 

purchased under resale agreements. Balance also includes securities purchased under long-term resale agreements (generally one year or more) classified in loans, which 
totaled $17.3 billion and $19.0 billion, at December 31, 2018 and 2017, respectively. 

(3)  Represents the fair value of collateral we have received under enforceable MRAs or MSLAs, limited for table presentation purposes to the amount of the recognized asset 

due from each counterparty. At December 31, 2018 and 2017, we have received total collateral with a fair value of $123.1 billion and $130.8 billion, respectively, all of 
which we have the right to sell or repledge. These amounts include securities we have sold or repledged to others with a fair value of $60.8 billion at December 31, 2018, 
and $66.3 billion at December 31, 2017. 

(4)  Represents the amount of our exposure that is not collateralized and/or is not subject to an enforceable MRA or MSLA. 
(5)  For additional information on underlying collateral and contractual maturities, see the “Repurchase and Securities Lending Agreements” section in this Note. 
(6)  Amount is classified in short-term borrowings on our consolidated balance sheet. 
(7)  Represents the fair value of collateral we have pledged, related to enforceable MRAs or MSLAs, limited for table presentation purposes to the amount of the recognized 

liability owed to each counterparty. At December 31, 2018 and 2017, we have pledged total collateral with a fair value of $108.8 billion and $113.6 billion, respectively, of 
which, the counterparty does not have the right to sell or repledge $4.4 billion as of December 31, 2018, and $5.2 billion as of December 31, 2017. 

(8)  Represents the amount of our obligation that is not covered by pledged collateral and/or is not subject to an enforceable MRA or MSLA. 

REPURCHASE AND SECURITIES LENDING AGREEMENTS 
Securities sold under repurchase agreements and securities 
lending arrangements are effectively short-term collateralized 
borrowings. In these transactions, we receive cash in exchange 
for transferring securities as collateral and recognize an 
obligation to reacquire the securities for cash at the transaction’s 
maturity. These types of transactions create risks, including 
(1) the counterparty may fail to return the securities at maturity, 
(2) the fair value of the securities transferred may decline below 
the amount of our obligation to reacquire the securities, and 
therefore create an obligation for us to pledge additional 
amounts, and (3) the counterparty may accelerate the maturity 
on demand, requiring us to reacquire the security prior to 
contractual maturity. We attempt to mitigate these risks by the 
fact that most of our securities financing activities involve highly 
liquid securities, we underwrite and monitor the financial 
strength of our counterparties, we monitor the fair value of 
collateral pledged relative to contractually required repurchase 
amounts, and we monitor that our collateral is properly returned 
through the clearing and settlement process in advance of our 
cash repayment. Table 15.4 provides the underlying collateral 
types of our gross obligations under repurchase and securities 
lending agreements. 

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Table 15.4:  Underlying Collateral Types of Gross Obligations 

(in millions) 

Repurchase agreements: 

Securities of U.S. Treasury and federal agencies (1) 

Securities of U.S. States and political subdivisions 

Federal agency mortgage-backed securities (1) 

Non-agency mortgage-backed securities 

Corporate debt securities (1) 

Asset-backed securities 

Equity securities 

Other (1) 

Total repurchases 

Securities lending: 

Securities of U.S. Treasury and federal agencies 

Federal agency mortgage-backed securities 

Corporate debt securities 

Equity securities (2) 

Other 

Total securities lending 

Dec 31, 

2018 

$ 

38,408 

159 

47,241 

1,875 

6,191 

2,074 

992 

340 

Dec 31, 

2017 

40,507 

92 

45,336 

1,324 

8,020 

2,034 

838 

1,602 

97,280 

99,753 

222 

2 

389 

8,349 

6 

8,968 

186 

— 

619 

10,930 

— 

11,735 

111,488 

Total repurchases and securities lending 

$ 

106,248 

(1)  Amounts for December 31, 2017, have been revised to conform with the current period classification of certain collateral. 
(2)  Equity securities are generally exchange traded and either re-hypothecated under margin lending agreements or obtained through contemporaneous securities borrowing 

transactions with other counterparties. 

Table 15.5 provides the contractual maturities of our gross 
obligations under repurchase and securities lending agreements. 

Table 15.5:  Contractual Maturities of Gross Obligations 

Overnight/ 
continuous 

Up to 30 
days 

30-90 days 

>90 days 

Total gross
obligation 

(in millions) 

December 31, 2018 

Repurchase agreements 

Securities lending 

$ 

86,574 

8,669 

Total repurchases and securities lending (1) 

$ 

95,243 

December 31, 2017 

Repurchase agreements 

Securities lending 

Total repurchases and securities lending (1) 

$ 

$ 

83,780 

9,634 

93,414 

3,244 

— 

3,244 

7,922 

584 

8,506 

2,153 

299 

2,452 

3,286 

1,363 

4,649 

5,309 

— 

97,280 

8,968 

5,309 

106,248 

4,765 

154 

4,919 

99,753 

11,735 

111,488 

(1)  Securities lending is executed under agreements that allow either party to terminate the transaction without notice, while repurchase agreements have a term structure to 
them that technically matures at a point in time. The overnight/continuous repurchase agreements require election of both parties to roll the trade rather than the election 
to terminate the arrangement as in securities lending. 

OTHER COMMITMENTS  To meet the financing needs of our 
customers, we may enter into commitments to purchase debt 
and equity securities to provide capital for their funding, 
liquidity or other future needs. As of December 31, 2018 and 
2017, we had commitments to purchase debt securities of 
$335 million and $194 million, respectively, and commitments 
to purchase equity securities of $2.5 billion and $2.2 billion, 
respectively. 

As part of maintaining our memberships in certain clearing 
organizations, we are required to stand ready to provide liquidity 
meant to sustain market clearing activity in the event unforeseen 
events occur or are deemed likely to occur. This includes 
commitments we have entered into to purchase securities under 
resale agreements from a central clearing organization that, at 
its option, require us to provide funding under such agreements. 
We do not have any outstanding amounts funded, and the 
amount of our unfunded contractual commitment was 

$9.8 billion and $2.8 billion as of December 31, 2018 and 2017, 
respectively. 

The Parent fully and unconditionally guarantees the 
payment of principal, interest, and any other amounts that may 
be due on securities that its 100% owned finance subsidiary, 
Wells Fargo Finance LLC, may issue. These guaranteed liabilities 
were $5 million and $0 million at December 31, 2018 and 2017, 
respectively. These guarantees rank on parity with all of the 
Parent’s other unsecured and unsubordinated indebtedness. 

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Note 16:  Legal Actions 

Wells Fargo and certain of our subsidiaries are involved in a 
number of judicial, regulatory, arbitration, and other 
proceedings concerning matters arising from the conduct of our 
business activities, and many of those proceedings expose Wells 
Fargo to potential financial loss. These proceedings include 
actions brought against Wells Fargo and/or our subsidiaries with 
respect to corporate-related matters and transactions in which 
Wells Fargo and/or our subsidiaries were involved. In addition, 
Wells Fargo and our subsidiaries may be requested to provide 
information or otherwise cooperate with government authorities 
in the conduct of investigations of other persons or industry 
groups. 

Although there can be no assurance as to the ultimate 
outcome, Wells Fargo and/or our subsidiaries have generally 
denied, or believe we have a meritorious defense and will deny, 
liability in all significant legal actions pending against us, 
including the matters described below, and we intend to defend 
vigorously each case, other than matters we describe as having 
settled. We establish accruals for legal actions when potential 
losses associated with the actions become probable and the costs 
can be reasonably estimated. For such accruals, we record the 
amount we consider to be the best estimate within a range of 
potential losses that are both probable and estimable; however, 
if we cannot determine a best estimate, then we record the low 
end of the range of those potential losses. The actual costs of 
resolving legal actions may be substantially higher or lower than 
the amounts accrued for those actions. 

ATM ACCESS FEE LITIGATION  In October 2011, plaintiffs filed 
a putative class action, Mackmin, et al. v. Visa, Inc. et al., 
against Wells Fargo & Company, Wells Fargo Bank, N.A., Visa, 
MasterCard, and several other banks in the United States 
District Court for the District of Columbia. Plaintiffs allege that 
the Visa and MasterCard requirement that if an ATM operator 
charges an access fee on Visa and MasterCard transactions, then 
that fee cannot be greater than the access fee charged for 
transactions on other networks, violates antitrust rules. Plaintiffs 
seek treble damages, restitution, injunctive relief, and attorneys’ 
fees where available under federal and state law. Two other 
antitrust cases that make similar allegations were filed in the 
same court, but these cases did not name Wells Fargo as a 
defendant. On February 13, 2013, the district court granted 
defendants’ motions to dismiss the three actions. Plaintiffs 
appealed the dismissals and, on August 4, 2015, the United 
States Court of Appeals for the District of Columbia Circuit 
vacated the district court’s decisions and remanded the three 
cases to the district court for further proceedings. On June 28, 
2016, the United States Supreme Court granted defendants’ 
petitions for writ of certiorari to review the decisions of the 
United States Court of Appeals for the District of Columbia. On 
November 17, 2016, the United States Supreme Court dismissed 
the petitions as improvidently granted, and the three cases 
returned to the district court for further proceedings. 

AUTOMOBILE LENDING MATTERS  On April 20, 2018, the 
Company entered into consent orders with the Office of the 
Comptroller of the Currency (OCC) and the Consumer Financial 
Protection Bureau (CFPB) to resolve, among other things, 
investigations by the agencies into the Company’s compliance 
risk management program and its past practices involving 
certain automobile collateral protection insurance (CPI) policies 
and, as discussed below, certain mortgage interest rate lock 

extensions. The consent orders require remediation to customers 
and the payment of a total of $1.0 billion in civil money penalties 
to the agencies. In July 2017, the Company announced a plan to 
remediate customers who may have been financially harmed due 
to issues related to automobile CPI policies purchased through a 
third-party vendor on their behalf. Multiple putative class action 
cases alleging, among other things, unfair and deceptive 
practices relating to these CPI policies, have been filed against 
the Company and consolidated into one multi-district litigation 
in the United States District Court for the Central District of 
California. A putative class of shareholders also filed a securities 
fraud class action against the Company and its executive officers 
alleging material misstatements and omissions of CPI-related 
information in the Company’s public disclosures. Former team 
members have also alleged retaliation for raising concerns 
regarding automobile lending practices. In addition, the 
Company has identified certain issues related to the unused 
portion of guaranteed automobile protection (GAP) waiver or 
insurance agreements between the customer and dealer and, by 
assignment, the lender, which will result in remediation to 
customers in certain states. Allegations related to the CPI and 
GAP programs are among the subjects of shareholder derivative 
lawsuits pending in federal and state court in California. The 
court dismissed the state court action in September 2018, but 
plaintiffs filed an amended complaint in November 2018. 
Subject to full documentation and court approval, the parties 
have reached agreements in principle to resolve the shareholder 
derivative lawsuits pursuant to which the Company will pay 
plaintiffs’ attorneys’ fees and undertake certain business and 
governance practices. These and other issues related to the 
origination, servicing, and/or collection of consumer automobile 
loans, including related insurance products, have also subjected 
the Company to formal or informal inquiries, investigations, or 
examinations from federal and state government agencies. In 
December 2018, the Company entered into an agreement with 
all 50 state Attorneys General and the District of Columbia to 
resolve an investigation into the Company’s retail sales practices, 
CPI and GAP, and mortgage interest rate lock matters, pursuant 
to which the Company paid $575 million. 

CONSUMER DEPOSIT ACCOUNT RELATED REGULATORY 
INVESTIGATION  The CFPB is conducting an investigation into 
whether customers were unduly harmed by the Company’s 
procedures regarding the freezing (and, in many cases, closing) 
of consumer deposit accounts after the Company detected 
suspected fraudulent activity (by third-parties or account 
holders) that affected those accounts. A former team member 
has brought a state court action alleging retaliation for raising 
concerns about these procedures. 

FIDUCIARY AND CUSTODY ACCOUNT FEE CALCULATIONS 
Federal government agencies are conducting formal or informal 
inquiries, investigations, or examinations regarding fee 
calculations within certain fiduciary and custody accounts in the 
Company’s investment and fiduciary services business, which is 
part of the wealth management business within WIM. The 
Company has determined that there have been instances of 
incorrect fees being applied to certain assets and accounts, 
resulting in both overcharges and undercharges to customers. 

FOREIGN EXCHANGE BUSINESS  Federal government 
agencies, including the United States Department of Justice 
(Department of Justice), are investigating or examining certain 

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activities in the Company’s foreign exchange business. The 
Company has accrued amounts to remediate customers that may 
have received pricing inconsistent with commitments made to 
those customers, and to rebate customers where historic pricing, 
while consistent with contracts entered into with those 
customers, does not conform to the Company’s recently 
implemented standards and pricing. 

INTERCHANGE LITIGATION  Plaintiffs representing a putative 
class of merchants have filed putative class actions, and 
individual merchants have filed individual actions, against 
Wells Fargo Bank, N.A., Wells Fargo & Company, Wachovia 
Bank, N.A., and Wachovia Corporation regarding the 
interchange fees associated with Visa and MasterCard payment 
card transactions. Visa, MasterCard, and several other banks and 
bank holding companies are also named as defendants in these 
actions. These actions have been consolidated in the United 
States District Court for the Eastern District of New York. The 
amended and consolidated complaint asserts claims against 
defendants based on alleged violations of federal and state 
antitrust laws and seeks damages, as well as injunctive relief. 
Plaintiff merchants allege that Visa, MasterCard, and payment 
card issuing banks unlawfully colluded to set interchange rates. 
Plaintiffs also allege that enforcement of certain Visa and 
MasterCard rules and alleged tying and bundling of services 
offered to merchants are anticompetitive. Wells Fargo and 
Wachovia, along with other defendants and entities, are parties 
to Loss and Judgment Sharing Agreements, which provide that 
they, along with other entities, will share, based on a formula, in 
any losses from the Interchange Litigation. On July 13, 2012, 
Visa, MasterCard, and the financial institution defendants, 
including Wells Fargo, signed a memorandum of understanding 
with plaintiff merchants to resolve the consolidated class action 
and reached a separate settlement in principle of the 
consolidated individual actions. The settlement payments to be 
made by all defendants in the consolidated class and individual 
actions totaled approximately $6.6 billion before reductions 
applicable to certain merchants opting out of the settlement. The 
class settlement also provided for the distribution to class 
merchants of 10 basis points of default interchange across all 
credit rate categories for a period of 8 consecutive months. The 
district court granted final approval of the settlement, which was 
appealed to the United States Court of Appeals for the Second 
Circuit by settlement objector merchants. Other merchants 
opted out of the settlement and are pursuing several individual 
actions. On June 30, 2016, the Second Circuit vacated the 
settlement agreement and reversed and remanded the 
consolidated action to the United States District Court for the 
Eastern District of New York for further proceedings. On 
November 23, 2016, prior class counsel filed a petition to the 
United States Supreme Court, seeking review of the reversal of 
the settlement by the Second Circuit, and the Supreme Court 
denied the petition on March 27, 2017. On November 30, 2016, 
the district court appointed lead class counsel for a damages 
class and an equitable relief class. The parties have entered into 
a settlement agreement to resolve the money damages class 
claims pursuant to which defendants will pay a total of 
approximately $6.2 billion, which includes approximately 
$5.3 billion of funds remaining from the 2012 settlement and 
$900 million in additional funding. The Company’s allocated 
responsibility for the additional funding is approximately 
$94.5 million. The court granted preliminary approval of the 
settlement in January 2019, and scheduled a final approval 
hearing for November 7, 2019. Several of the opt-out litigations 
were settled during the pendency of the Second Circuit appeal 

while others remain pending. Discovery is proceeding in the opt-
out litigations and the equitable relief class case. 

LOW INCOME HOUSING TAX CREDITS  Federal government 
agencies have undertaken formal or informal inquiries or 
investigations regarding the manner in which the Company 
purchased, and negotiated the purchase of, certain federal low 
income housing tax credits in connection with the financing of 
low income housing developments. 

MORTGAGE BANKRUPTCY LOAN MODIFICATION 
LITIGATION  Plaintiffs, representing a putative class of 
mortgage borrowers who were debtors in Chapter 13 bankruptcy 
cases, filed a putative class action, Cotton, et al. v. Wells Fargo, 
et al., against Wells Fargo & Company and Wells Fargo Bank, 
N.A. in the United States Bankruptcy Court for the Western 
District of North Carolina on June 7, 2017. Plaintiffs allege that 
Wells Fargo improperly and unilaterally modified the mortgages 
of borrowers who were debtors in Chapter 13 bankruptcy 
cases. Plaintiffs allege that Wells Fargo implemented these 
modifications by improperly filing mortgage payment change 
notices in Chapter 13 bankruptcy cases, in violation of 
bankruptcy rules and process. The amended complaint asserts 
claims based on, among other things, alleged fraud, violations of 
bankruptcy rules and laws, and unfair and deceptive trade 
practices. The amended complaint seeks monetary damages, 
attorneys’ fees, and declaratory and injunctive relief. The parties 
have entered into a settlement agreement pursuant to which the 
Company will pay $13.5 million to resolve the claims. On 
October 24, 2018, the court granted preliminary approval of the 
settlement and scheduled a final fairness hearing for March 4, 
2019. 

MORTGAGE INTEREST RATE LOCK RELATED REGULATORY 
INVESTIGATION  On April 20, 2018, the Company entered into 
consent orders with the OCC and CFPB to resolve, among other 
things, investigations by the agencies into the Company’s 
compliance risk management program and its past practices 
involving certain automobile CPI policies and certain mortgage 
interest rate lock extensions. The consent orders require 
remediation to customers and the payment of a total of 
$1.0 billion in civil money penalties to the agencies. On 
October 4, 2017, the Company announced plans to reach out to 
all home lending customers who paid fees for mortgage rate lock 
extensions requested from September 16, 2013, through 
February 28, 2017, and to provide refunds, with interest, to 
customers who believe they should not have paid those fees. The 
Company was named in a putative class action, filed in the 
United States District Court for the Northern District of 
California, alleging violations of federal and state consumer 
fraud statutes relating to mortgage rate lock extension fees. The 
Company filed a motion to dismiss and the court granted the 
motion. Subsequently, a putative class action was filed in the 
United States District Court for the District of Oregon, raising 
similar allegations. The Company filed a motion to dismiss this 
action. In addition, former team members have asserted claims, 
including in pending litigation, that they were terminated for 
raising concerns regarding mortgage interest rate lock extension 
practices. Allegations related to mortgage interest rate lock 
extension fees are also among the subjects of two shareholder 
derivative lawsuits filed in California state court. This matter has 
also subjected the Company to formal or informal inquiries, 
investigations or examinations from other federal and state 
government agencies. In December 2018, the Company entered 
into an agreement with all 50 state Attorneys General and the 

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Note 16:  Legal Actions (continued) 

District of Columbia to resolve an investigation into the 
Company’s retail sales practices, CPI and GAP, and mortgage 
interest rate lock matters, pursuant to which the Company paid 
$575 million. 

MORTGAGE LOAN MODIFICATION LITIGATION  Plaintiffs 
representing a putative class of mortgage borrowers have filed 
separate putative class actions, Hernandez v. Wells Fargo, et al., 
and Coordes v. Wells Fargo, et al., against Wells Fargo Bank, 
N.A. in the United States District Court for the Northern District 
of California and the United States District Court for the District 
of Washington, respectively. Plaintiffs allege that Wells Fargo 
improperly denied mortgage loan modifications or repayment 
plans to customers in the foreclosure process due to the 
overstatement of foreclosure attorneys’ fees that were included 
for purposes of determining whether a customer in the 
foreclosure process qualified for a mortgage loan modification or 
repayment plan. 

MORTGAGE RELATED REGULATORY INVESTIGATIONS 
Federal and state government agencies, including the 
Department of Justice, have been investigating or examining 
certain mortgage related activities of Wells Fargo and 
predecessor institutions. Wells Fargo, for itself and for 
predecessor institutions, has responded, or continues to 
respond, to requests from these agencies seeking information 
regarding the origination, underwriting, and securitization of 
residential mortgages, including sub-prime mortgages. These 
agencies have advanced theories of purported liability with 
respect to certain of these activities. An agreement, pursuant to 
which the Company paid $2.09 billion, was reached in August 
2018 to resolve the Department of Justice investigation, which 
related to certain 2005-2007 residential mortgage-backed 
securities activities. In addition, the Company reached an 
agreement with the Attorney General of the State of Illinois in 
November 2018 pursuant to which the Company paid 
$17 million in restitution to certain Illinois state pension funds 
to resolve a claim relating to certain residential mortgage-backed 
securities activities. Other financial institutions have entered 
into similar settlements with these agencies, the nature of which 
related to the specific activities of those financial institutions, 
including the imposition of significant financial penalties and 
remedial actions. 

OFAC RELATED INVESTIGATION  The Company has self-
identified an issue whereby certain foreign banks utilized a 
Wells Fargo software-based solution to conduct import/export 
trade-related financing transactions with countries and entities 
prohibited by the Office of Foreign Assets Control (OFAC) of the 
United States Department of the Treasury. We do not believe any 
funds related to these transactions flowed through accounts at 
Wells Fargo as a result of the aforementioned conduct. The 
Company has made voluntary self-disclosures to OFAC and is 
cooperating with an inquiry from the Department of Justice. 

ORDER OF POSTING LITIGATION  Plaintiffs filed a series of 
putative class actions against Wachovia Bank, N.A. and 
Wells Fargo Bank, N.A., as well as many other banks, 
challenging the “high to low” order in which the banks post debit 
card transactions to consumer deposit accounts. Most of these 
actions were consolidated in multi-district litigation proceedings 
(MDL proceedings) in the United States District Court for the 
Southern District of Florida. The court in the MDL proceedings 
has certified a class of putative plaintiffs, and Wells Fargo moved 
to compel arbitration of the claims of unnamed class members. 

The court denied the motions to compel arbitration in October 
2016, and Wells Fargo appealed this decision to the United 
States Court of Appeals for the Eleventh Circuit. In May 2018, 
the Eleventh Circuit ruled in Wells Fargo’s favor and found that 
Wells Fargo had not waived its arbitration rights and remanded 
the case to the district court for further proceedings. Plaintiffs 
filed a petition for rehearing to the Eleventh Circuit, which was 
denied in August 2018. Plaintiffs petitioned for certiorari from 
the United States Supreme Court, and that petition was denied 
in January 2019. 

RETAIL SALES PRACTICES MATTERS  Federal, state, and 
local government agencies, including the Department of 
Justice, the United States Securities and Exchange 
Commission (SEC), and the United States Department of 
Labor; state attorneys general, including the New York 
Attorney General; and prosecutors’ offices, as well as 
Congressional committees, have undertaken formal or 
informal inquiries, investigations or examinations arising out 
of certain retail sales practices of the Company that were the 
subject of settlements with the CFPB, the OCC, and the Office 
of the Los Angeles City Attorney announced by the Company 
on September 8, 2016. These matters are at varying stages. 
The Company has responded, and continues to respond, to 
requests from a number of the foregoing. In October 2018, the 
Company entered into an agreement to resolve the New York 
Attorney General’s investigation pursuant to which the 
Company paid $65 million to the State of New York. In 
December 2018, the Company entered into an agreement with 
all 50 state Attorneys General and the District of Columbia to 
resolve an investigation into the Company’s retail sales 
practices, CPI and GAP, and mortgage interest rate lock 
matters, pursuant to which the Company paid $575 million. 
The Company has also engaged in preliminary and/or 
exploratory resolution discussions with the Department of 
Justice and the SEC, although there can be no assurance as to 
the outcome of these discussions. 

In addition, a number of lawsuits have also been filed by 
non-governmental parties seeking damages or other remedies 
related to these retail sales practices. First, various class 
plaintiffs purporting to represent consumers who allege that 
they received products or services without their authorization or 
consent have brought separate putative class actions against the 
Company in the United States District Court for the Northern 
District of California and various other jurisdictions. In 
April 2017, the Company entered into a settlement agreement in 
the first-filed action, Jabbari v. Wells Fargo Bank, N.A., to 
resolve claims regarding certain products or services provided 
without authorization or consent for the time period May 1, 
2002 to April 20, 2017. Pursuant to the settlement, the Company 
will pay $142 million for remediation, attorneys’ fees, and 
settlement fund claims administration. In the unlikely event that 
the $142 million settlement total is not enough to provide 
remediation, pay attorneys’ fees, pay settlement fund claims 
administration costs, and have at least $25 million left over to 
distribute to all class members, the Company will contribute 
additional funds to the settlement. In addition, in the unlikely 
event that the number of unauthorized accounts identified by 
settlement class members in the claims process and not disputed 
by the claims administrator exceeds plaintiffs’ 3.5 million 
account estimate, the Company will proportionately increase the 
$25 million reserve so that the ratio of reserve to unauthorized 
accounts is no less than what was implied by plaintiffs’ estimate 
at the time of the district court’s preliminary approval of the 
settlement in July 2017. The district court issued an order 

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216

 
granting final approval of the settlement on June 14, 2018. 
Several appeals of the district court’s order granting final 
approval of the settlement have been filed with the United States 
Court of Appeals for the Ninth Circuit. Second, Wells Fargo 
shareholders brought a consolidated securities fraud class action 
in the United States District Court for the Northern District of 
California alleging certain misstatements and omissions in the 
Company’s disclosures related to sales practices matters. The 
Company entered into a settlement agreement to resolve this 
matter pursuant to which the Company paid $480 million. The 
district court issued an order granting final approval of the 
settlement on December 20, 2018. Third, Wells Fargo 
shareholders have brought numerous shareholder derivative 
lawsuits asserting breach of fiduciary duty claims, among others, 
against current and former directors and officers for their 
alleged failure to detect and prevent sales practices issues. These 
actions have been filed or transferred to the United States 
District Court for the Northern District of California and 
California state court for coordinated proceedings. An additional 
lawsuit asserting similar claims in Delaware state court has been 
stayed. Subject to full documentation and court approval, the 
parties have reached an agreement in principle to resolve the 
shareholder derivative lawsuits pursuant to which insurance 
carriers will pay the Company approximately $240 million for 
alleged damage to the Company, and the Company will pay 
plaintiffs’ attorneys’ fees. Fourth, multiple employment litigation 
matters have been brought against Wells Fargo, including an 
Employee Retirement Income Security Act (ERISA) class action 
in the United States District Court for the District of Minnesota 
on behalf of 401(k) plan participants that has been dismissed 
and is now on appeal; a class action in the United States District 
Court for the Northern District of California on behalf of team 
members who allege that they protested sales practice 
misconduct and/or were terminated for not meeting sales goals 
that has now been dismissed, and we have entered into a 
framework with plaintiffs’ counsel to address individual claims 
that have been asserted; various wage and hour class actions 
brought in federal and state court in California (which have been 
settled), New Jersey, and Pennsylvania on behalf of non-exempt 
branch based team members alleging that sales pressure 
resulted in uncompensated overtime; and multiple single 
plaintiff Sarbanes-Oxley Act complaints and state law 
whistleblower actions filed with the United States Department of 
Labor or in various state courts alleging adverse employment 
actions for raising sales practice misconduct issues. 

RMBS TRUSTEE LITIGATION  In November 2014, a group of 
institutional investors (Institutional Investor Plaintiffs), 
including funds affiliated with BlackRock, Inc., filed a putative 
class action in the United States District Court for the Southern 
District of New York against Wells Fargo Bank, N.A., alleging 
claims against the Company in its capacity as trustee for a 
number of residential mortgage-backed securities (RMBS) trusts 
(Federal Court Complaint). Similar complaints have been filed 
against other trustees in various courts, including in the 
Southern District of New York, in New York state court, and in 
other states, by RMBS investors. The Federal Court Complaint 
alleges that Wells Fargo Bank, N.A., as trustee, caused losses to 
investors and asserts causes of action based upon, among other 
things, the trustee’s alleged failure to notify and enforce 
repurchase obligations of mortgage loan sellers for purported 
breaches of representations and warranties, notify investors of 
alleged events of default, and abide by appropriate standards of 
care following alleged events of default. Plaintiffs seek money 
damages in an unspecified amount, reimbursement of expenses, 

and equitable relief. In December 2014 and December 2015, 
certain other investors filed four complaints alleging similar 
claims against Wells Fargo Bank, N.A. in the Southern District of 
New York (Related Federal Cases), and the various cases 
pending against Wells Fargo are proceeding before the same 
judge. On January 19, 2016, the Southern District of New York 
entered an order in connection with the Federal Court 
Complaint dismissing claims related to certain of the trusts at 
issue (Dismissed Trusts). The Company’s motion to dismiss the 
Federal Court Complaint and the complaints for the Related 
Federal Cases was granted in part and denied in part in March 
2017. In May 2017, the Company filed third-party complaints 
against certain investment advisors affiliated with the 
Institutional Investor Plaintiffs seeking contribution with respect 
to claims alleged in the Federal Court Complaint (Third-Party 
Claims). The investment advisors have moved to dismiss those 
complaints. On April 17, 2018, the Southern District of New York 
denied class certification in the Related Federal Case brought by 
Royal Park Investments SA/NV (Royal Park Action). 

A complaint raising similar allegations to those in the 
Federal Court Complaint was filed in May 2016 in New York 
state court by a different plaintiff investor. In December 2016, 
the Institutional Investor Plaintiffs filed a new putative class 
action complaint in New York state court in respect of 261 RMBS 
trusts, including the Dismissed Trusts, for which Wells Fargo 
Bank, N.A. serves or served as trustee (State Court Action). 

In July 2017, certain of the plaintiffs from the State Court 

Action filed a civil complaint relating to Wells Fargo Bank, 
N.A.’s setting aside reserves for legal fees and expenses in 
connection with the liquidation of eleven RMBS trusts at issue 
in the State Court Action (Declaratory Judgment Action). The 
complaint seeks, among other relief, declarations that 
Wells Fargo Bank, N.A. is not entitled to indemnification, the 
advancement of funds, or the taking of reserves from trust 
funds for legal fees and expenses it incurs in defending the 
claims in the State Court Action. In November 2017, the 
Company’s motion to dismiss the complaint was granted. 
Plaintiffs filed a notice of appeal in January 2018. 

In November 2018, the Institutional Investor Plaintiffs 

and the Company entered into a settlement agreement 
pursuant to which, among other terms, the Company will pay 
$43 million to resolve the Federal Court Complaint and the 
State Court Action. The settlement will also resolve the Third 
Party Claims and the Declaratory Judgment Action. The New 
York state court has scheduled a fairness hearing on the 
settlement for May 6, 2019. In addition, Royal Park 
Investments SA/NV and Wells Fargo Bank, N.A. have reached 
an agreement resolving the Royal Park Action. Other than the 
Royal Park Action, the Related Federal Cases are not covered 
by these settlement agreements. 

SEMINOLE TRIBE TRUSTEE LITIGATION  The Seminole Tribe 
of Florida filed a complaint in Florida state court alleging that 
Wells Fargo, as trustee, charged excess fees in connection with 
the administration of a minor’s trust and failed to invest the 
assets of the trust prudently. The complaint was later amended 
to include three individual current and former beneficiaries as 
plaintiffs and to remove the Tribe as a party to the case. In 
December 2016, the Company filed a motion to dismiss the 
amended complaint on the grounds that the Tribe is a necessary 
party and that the individual beneficiaries lack standing to bring 
claims. The motion was denied in June 2018. Trial is scheduled 
for October 2019. 

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Note 16:  Legal Actions (continued) 

WHOLESALE BANKING CONSENT ORDER INVESTIGATION 
On November 19, 2015, the Company entered into a consent 
order with the OCC, pursuant to which the Wholesale Banking 
group was required to implement customer due diligence 
standards that include collection of current beneficial ownership 
information for certain business customers. The Company is 
responding to inquiries from various federal government 
agencies regarding potentially inappropriate conduct in 
connection with the collection of beneficial ownership 
information. 

OUTLOOK  As described above, the Company establishes 
accruals for legal actions when potential losses associated with 
the actions become probable and the costs can be reasonably 
estimated. The high end of the range of reasonably possible 
potential losses in excess of the Company’s accrual for probable 
and estimable losses was approximately $2.7 billion as of 
December 31, 2018. The increase in the high end of the range 
from September 30, 2018, was due to a variety of matters, 
including the Company’s existing retail sales practices matters. 
The outcomes of legal actions are unpredictable and subject to 
significant uncertainties, and it is inherently difficult to 
determine whether any loss is probable or even possible. It is 
also inherently difficult to estimate the amount of any loss and 
there may be matters for which a loss is probable or reasonably 
possible but not currently estimable. Accordingly, actual losses 
may be in excess of the established accrual or the range of 
reasonably possible loss. Wells Fargo is unable to determine 
whether the ultimate resolution of the retail sales practices 
matters will have a material adverse effect on its consolidated 
financial condition. Based on information currently available, 
advice of counsel, available insurance coverage, and established 
reserves, Wells Fargo believes that the eventual outcome of other 
actions against Wells Fargo and/or its subsidiaries will not, 
individually or in the aggregate, have a material adverse effect on 
Wells Fargo’s consolidated financial condition. However, it is 
possible that the ultimate resolution of a matter, if unfavorable, 
may be material to Wells Fargo’s results of operations for any 
particular period. 

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Note 17:  Derivatives 

We use derivatives to manage exposure to market risk, including 
interest rate risk, credit risk and foreign currency risk, and to 
assist customers with their risk management objectives. We 
designate certain derivatives as hedging instruments in a 
qualifying hedge accounting relationship (fair value or cash flow 
hedge). Our remaining derivatives consist of economic hedges 
that do not qualify for hedge accounting and derivatives held for 
customer accommodation trading or other purposes. 

Our asset/liability management approach to interest rate, 

foreign currency and certain other risks includes the use of 
derivatives. Such derivatives are typically designated as fair 
value or cash flow hedges, or economic hedges. We use 
derivatives to help minimize significant, unplanned fluctuations 
in earnings, fair values of assets and liabilities, and cash flows 
caused by interest rate, foreign currency and other market risk 
volatility. This approach involves modifying the repricing 
characteristics of certain assets and liabilities so that changes in 
interest rates, foreign currency and other exposures, which may 
cause the hedged assets and liabilities to gain or lose fair value, 
do not have a significantly adverse effect on the net interest 
margin, cash flows and earnings. In a fair value or economic 
hedge, the effect of change in fair value will generally be offset by 
the unrealized gain or loss on the derivatives linked to the 
hedged assets and liabilities. In a cash flow hedge, where we 
manage the variability of cash payments due to interest rate 
fluctuations by the effective use of derivatives linked to hedged 
assets and liabilities, the hedged asset or liability is not adjusted 
and the unrealized gain or loss on the derivative is recorded in 
other comprehensive income. 

We also offer various derivatives, including interest rate, 
commodity, equity, credit and foreign exchange contracts, as an 
accommodation to our customers as part of our trading 
businesses. These derivative transactions, which involve our 
engaging in market-making activities or acting as an 
intermediary, are conducted in an effort to help customers 
manage their market risks. We usually offset our exposure from 
such derivatives by entering into other financial contracts, such 
as separate derivative or security transactions. These customer 
accommodations and any offsetting derivatives are treated as 
customer accommodation trading and other derivatives in our 
disclosures. Additionally, embedded derivatives that are 
required to be accounted for separately from their host contracts 
are included in the customer accommodation trading and other 
derivatives disclosures as applicable. 

Table 17.1 presents the total notional or contractual 

amounts and fair values for our derivatives. Derivative 
transactions can be measured in terms of the notional amount, 
but this amount is not recorded on the balance sheet and is not, 
when viewed in isolation, a meaningful measure of the risk 
profile of the instruments. The notional amount is generally not 
exchanged, but is used only as the basis on which interest and 
other payments are determined. 

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Note 17:  Derivatives (continued) 

Table 17.1:  Notional or Contractual Amounts and Fair Values of Derivatives 

December 31, 2018 

December 31, 2017 

Notional or 

Fair value 

Notional or 

Fair value 

contractual 

Asset 

Liability 

contractual 

Asset 

Liability 

(in millions) 

amount  derivatives  derivatives 

amount 

derivatives 

derivatives 

Derivatives designated as hedging instruments 

Interest rate contracts (1) 

Foreign exchange contracts (1) 

Total derivatives designated as

 qualifying hedging instruments 

Derivatives not designated as hedging instruments 

$  177,511 

34,176 

2,237 

573 

636 

209,677 

1,376 

34,135 

2,492 

1,482 

1,092 

1,137 

2,810 

2,012 

3,974 

2,229 

Economic hedges: 

Interest rate contracts (2) 

Equity contracts 

Foreign exchange contracts 

Credit contracts - protection purchased 

Subtotal 

Customer accommodation trading and 

other derivatives: 

Interest rate contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts - protection sold 

Credit contracts - protection purchased 

Subtotal 

Total derivatives not designated as hedging instruments 

Total derivatives before netting 

Netting (3) 

Total 

173,215 

13,920 

19,521 

100

849 

1,362 

225 

27 

369 

220,558 

79 

80 

— 

12,315 

15,976 

111

2,463 

528 

159 

716 

78 

37 

990 

201 

138 

309 

— 

648 

9,162,821 

15,349 

15,303 

6,434,673 

14,979 

14,179 

66,173 

217,890 

364,982 

11,741 

20,880 

1,588 

6,183 

5,916 

76 

175 

2,336 

5,931 

5,657 

182 

98 

62,530 

213,750 

362,896 

9,021 

17,406 

29,287 

29,507 

31,750 

30,035 

34,560 

32,047 

2,354 

6,291 

7,413 

147 

207 

31,391 

32,381 

36,355 

1,335 

8,363 

7,122 

214 

208 

31,421 

32,069 

34,298 

(23,790) 

(23,548) 

(24,127) 

(25,502) 

$  10,770 

8,499 

12,228 

8,796 

(1)  Notional amounts presented at December 31, 2017, exclude $500 million of interest rate contracts for certain derivatives that are combined for designation as a hedge in a 
single relationship. No such hedging relationships existed at December 31, 2018. The notional amount for foreign exchange contracts at December 31, 2018 and 2017, 
excludes $11.2 billion and $13.5 billion, respectively for certain derivatives that are combined for designation as a hedge on a single relationship. 
Includes economic hedge derivatives used to hedge the risk of changes in the fair value of residential MSRs, MLHFS, loans, derivative loan commitments and other interests 
held. 

(2) 

(3)  Represents balance sheet netting of derivative asset and liability balances, related cash collateral and portfolio level counterparty valuation adjustments. See the next table 

in this Note for further information. 

220 

Wells Fargo & Company 

220

  
 
Table 17.2 provides information on the gross fair values of 

derivative assets and liabilities, the balance sheet netting 
adjustments and the resulting net fair value amount recorded on 
our balance sheet, as well as the non-cash collateral associated 
with such arrangements. We execute substantially all of our 
derivative transactions under master netting arrangements and 
reflect all derivative balances and related cash collateral subject 
to enforceable master netting arrangements on a net basis within 
the balance sheet. The “Gross amounts recognized” column in 
the following table includes $30.9 billion and $28.4 billion of 
gross derivative assets and liabilities, respectively, at 
December 31, 2018, and $30.0 billion and $29.9 billion, 
respectively, at December 31, 2017, with counterparties subject 
to enforceable master netting arrangements that are carried on 
the balance sheet net of offsetting amounts. The remaining gross 
derivative assets and liabilities of $3.7 billion and $3.6 billion, 
respectively, at December 31, 2018, and $6.4 billion and 
$4.4 billion, respectively, at December 31, 2017, include those 
with counterparties subject to master netting arrangements for 
which we have not assessed the enforceability because they are 
with counterparties where we do not currently have positions to 
offset, those subject to master netting arrangements where we 
have not been able to confirm the enforceability and those not 
subject to master netting arrangements. As such, we do not net 
derivative balances or collateral within the balance sheet for 
these counterparties. 

We determine the balance sheet netting adjustments based 
on the terms specified within each master netting arrangement. 
We disclose the balance sheet netting amounts within the 
column titled “Gross amounts offset in consolidated balance 
sheet.” Balance sheet netting adjustments are determined at the 
counterparty level for which there may be multiple contract 
types. For disclosure purposes, we allocate these netting 
adjustments to the contract type for each counterparty 

proportionally based upon the “Gross amounts recognized” by 
counterparty. As a result, the net amounts disclosed by contract 
type may not represent the actual exposure upon settlement of 
the contracts. 

We do not net non-cash collateral that we receive and 
pledge on the balance sheet. For disclosure purposes, we present 
the fair value of this non-cash collateral in the column titled 
“Gross amounts not offset in consolidated balance sheet 
(Disclosure-only netting)” within the table. We determine and 
allocate the Disclosure-only netting amounts in the same 
manner as balance sheet netting amounts. 

The “Net amounts” column within Table 17.2 represents the 

aggregate of our net exposure to each counterparty after 
considering the balance sheet and Disclosure-only netting 
adjustments. We manage derivative exposure by monitoring the 
credit risk associated with each counterparty using counterparty 
specific credit risk limits, using master netting arrangements 
and obtaining collateral. Derivative contracts executed in over-
the-counter markets include bilateral contractual arrangements 
that are not cleared through a central clearing organization but 
are typically subject to master netting arrangements. The 
percentage of our bilateral derivative transactions outstanding at 
period end in such markets, based on gross fair value, is 
provided within the following table. Other derivative contracts 
executed in over-the-counter or exchange-traded markets are 
settled through a central clearing organization and are excluded 
from this percentage. In addition to the netting amounts 
included in the table, we also have balance sheet netting related 
to resale and repurchase agreements that are disclosed within 
Note 15 (Guarantees, Pledged Assets and Collateral, and Other 
Commitments). 

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Note 17:  Derivatives (continued) 

Table 17.2:  Gross Fair Values of Derivative Assets and Liabilities 

Gross 
amounts 
offset in 
consolidated 
balance 
sheet (1) 

Gross amounts 
not offset in 
consolidated 
balance sheet 
(Disclosure-only 
netting) (2) 

Net amounts in 
consolidated 
balance sheet 

Gross amounts 
recognized 

Percent 
exchanged in 
over-the-counter 
market (3) 

Net 
amounts 

(in millions) 

December 31, 2018 

Derivative assets 

Interest rate contracts 

$ 

18,435 

(12,029) 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts-protection sold 

Credit contracts-protection purchased 

1,588 

7,545 

6,714 

76 

202 

(849) 

(5,318) 

(5,355) 

(73)

(166) 

6,406 

739 

2,227 

1,359 

 3

36 

(80) 

6,326 

(4) 

735 

(755) 

1,472 

(35) 

1,324 

 —

(1)

3

 35

Total derivative assets 

$ 

34,560 

(23,790) 

10,770 

(875) 

9,895 

90% 

57 

78 

100 

 12 

78

Derivative liabilities 

Interest rate contracts 

$ 

16,308 

(13,152) 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts-protection sold 

Credit contracts-protection purchased 

2,336 

6,010 

7,113 

182 

98 

(727) 

(3,877) 

(5,522) 

(180) 

(90) 

3,156 

1,609 

2,133 

1,591 

2 

8 

(567) 

2,589 

92% 

(8) 

1,601 

(110) 

2,023 

(188) 

1,403 

(2)

— 

 —

8

Total derivative liabilities 

$ 

32,047 

(23,548) 

8,499 

(875) 

7,624 

December 31, 2017 

Derivative assets 

Interest rate contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts-protection sold 

Credit contracts-protection purchased 

Total derivative assets 

Derivative liabilities 

Interest rate contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts-protection sold 

Credit contracts-protection purchased 

$ 

17,630 

(11,929) 

2,354 

7,007 

8,973 

147 

244 

(966) 

(4,233) 

(6,656) 

(145) 

(198)

5,701 

1,388 

2,774 

2,317 

2 

 46

(145) 

(4) 

(596) 

(25) 

— 

  (3) 

5,556 

1,384 

2,178 

2,292 

2 

43 

$ 

$ 

36,355 

(24,127) 

12,228 

(773) 

11,455 

15,472 

(13,226) 

1,335 

8,501 

8,568 

214 

208 

(648) 

(4,041) 

(7,189) 

(204)

(194)

2,246 

687 

4,460 

1,379 

 10

 14

(1,078) 

1,168 

99 % 

(1) 

(400) 

(204) 

  (9)

  —

686 

4,060 

1,175 

1

14

76 

85 

100 

 85 

  9

85 

75 

100 

67

 11

99 % 

88 

76 

100 

10 

89 

Total derivative liabilities 

$ 

34,298 

(25,502) 

8,796 

(1,692) 

7,104 

(1)  Represents amounts with counterparties subject to enforceable master netting arrangements that have been offset in the consolidated balance sheet, including related cash 

collateral and portfolio level counterparty valuation adjustments. Counterparty valuation adjustments were $353 million and $245 million related to derivative assets and 
$152 million and $95 million related to derivative liabilities as of December 31, 2018 and 2017, respectively. Cash collateral totaled $3.7 billion and $3.6 billion, netted 
against derivative assets and liabilities, respectively, at December 31, 2018, and $2.7 billion and $4.2 billion, respectively, at December 31, 2017. 

(2)  Represents the fair value of non-cash collateral pledged and received against derivative assets and liabilities with the same counterparty that are subject to enforceable 
master netting arrangements. U.S. GAAP does not permit netting of such non-cash collateral balances in the consolidated balance sheet but requires disclosure of these 
amounts. 

(3)  Represents derivatives executed in over-the-counter markets not settled through a central clearing organization. Over-the-counter percentages are calculated based on 

Gross amounts recognized as of the respective balance sheet date. The remaining percentage represents derivatives settled through a central clearing organization, which 
are executed in either over-the-counter or exchange-traded markets. 

222 

Wells Fargo & Company 

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Fair Value and Cash Flow Hedges 
For fair value hedges, we use interest rate swaps to convert 
certain of our fixed-rate long-term debt and time certificates of 
deposit to floating rates to hedge our exposure to interest rate 
risk. We also enter into cross-currency swaps, cross-currency 
interest rate swaps and forward contracts to hedge our exposure 
to foreign currency risk and interest rate risk associated with the 
issuance of non-U.S. dollar denominated long-term debt. In 
addition, we use interest rate swaps, cross-currency swaps, 
cross-currency interest rate swaps and forward contracts to 
hedge against changes in fair value of certain investments in 
available-for-sale debt securities due to changes in interest rates, 
foreign currency rates, or both. We also use interest rate swaps 
to hedge against changes in fair value for certain mortgage loans 
held for sale. 

For cash flow hedges, we use interest rate swaps to hedge the 
variability in interest payments received on certain floating-rate 
commercial loans and paid on certain floating-rate debt due to 
changes in the contractually specified interest rate. 

We estimate $293 million pre-tax of deferred net losses 
primarily related to cash flow hedges in OCI at December 31, 
2018, will be reclassified into net interest income during the next 
twelve months. The deferred losses expected to be reclassified 
into net interest income are primarily related to discontinued 
hedges of floating rate loans. We are hedging our foreign 
exposure to the variability of future cash flows for all forecasted 
transactions for a maximum of 8 years. 

Table 17.3 shows the net gains (losses) related to derivatives 

in fair value and cash flow hedging relationships. 

Table 17.3: Gains (Losses) Recognized in Consolidated Statement of Income on Fair Value and Cash Flow Hedging Relationships  (1) 

(in millions) 

Year ended December 31, 2018 

Net interest income 

Noninterest 
Income 

Debt 
securities 

Mortgage
loans held 

Loans 

for sale  Deposits 

Long-term
debt 

Other 

Total 

Total amounts presented in the consolidated statement

of income 

$  14,406  43,974 

777 

(5,622) 

(6,703) 

2,473 

49,305 

Gains (losses) on fair value hedging relationships 

Interest rate contracts 

Amounts related to interest settlements on 

derivatives (2) 

Recognized on derivatives 

Recognized on hedged items 

Foreign exchange contracts 

Amounts related to interest settlements on 

derivatives (2)(3) 

Recognized on derivatives (4) 

Recognized on hedged items 

Net income (expense) recognized on fair value

hedges 

Gains (losses) on cash flow hedging relationships 

Interest contracts 

Realized gains (losses) (pre tax) reclassified from

cumulative OCI into net income (5) 

Foreign exchange contracts 

Realized gains (losses) (pre-tax) reclassified from

cumulative OCI into net income (5) 

Net income (expense) recognized on cash flow

hedges 

(continued on following page) 

(187) 

845 

— 

1 

(3) 

15 

(41) 

292 

27 

(1,923) 

(877) 

(1) 

(22) 

(33) 

1,843 

— 

— 

— 

61 

(1,035) 

910 

33 

7 

(1)

(180) 

— 

— 

 — 

— 

— 

— 

— 

— 

— 

— 

(434) 

135 

(82) 

— 

(401) 

(1,204) 

(1,062) 

1,114 

1,031 

(10) 

(47) 

(169) 

(90) 

(496) 

— 

(292) 

— 

— 

1 

— 

(291) 

— 

— 

— 

(292) 

$ 

— 

— 

— 

— 

(3)

(2) 

 —

— 

 (3)

(294) 

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Wells Fargo & Company 

223 

 
 
 
Note 17:  Derivatives (continued) 

(continued from previous page) 

(in millions) 

Year ended December 31, 2017 

Net interest income 

Noninterest 
Income 

Debt 
securities 

Mortgage
loans held 

Loans 

for sale  Deposits 

Long-
term debt 

Other 

Total 

Total amounts presented in the consolidated statement of

income 

$  12,946 

41,388 

786 

(3,013) 

(5,157) 

1,603 

48,553 

Gains (losses) on fair value hedging relationships 

Interest rate contracts 

Amounts related to interest settlements on derivatives (2) 

Recognized on derivatives 

Recognized on hedged items 

Foreign exchange contracts 

Amounts related to interest settlements on derivatives (2)(3) 

Recognized on derivatives (4) 

Recognized on hedged items 

         Net income (expense) recognized on fair value hedges 

Gains (losses) on cash flow hedging relationships 

Interest contracts 

Realized gains (losses) (pre tax) reclassified from cumulative

OCI into net income (5) 

Foreign exchange contracts 

Realized gains (losses) (pre-tax) reclassified from cumulative

OCI into net income (5) 

         Net income (expense) recognized on cash flow hedges 

$ 

(469) 

(43) 

(52) 

14 

13 

(10) 

(547) 

(1) 

1 

(1) 

— 

— 

— 

(1) 

(5) 

(5) 

(4) 

— 

— 

— 

(14) 

36 

(20) 

36 

1,286 

(912) 

938 

(210) 

(230) 

255 

— 

— 

— 

52 

— 

— 

— 

— 

847 

(979) 

917 

(196) 

3,118 

2,901 

(2,855) 

(2,610)

1,127 

263 

880 

— 

551 

— 

— 

(8) 

— 

543 

— 

— 

— 

551 

— 

— 

— 

— 

— 

(8) 

— 

— 

— 

543 

Year ended December 31, 2016 

Total amounts presented in the consolidated statement of

income 

Gains (losses) on fair value hedging relationships 

Interest rate contracts 

$  11,244 

39,505 

784 

(1,395) 

(3,830) 

1,289 

47,597 

Amounts related to interest settlements on derivatives (2) 

(582) 

Recognized on derivatives 

Recognized on hedged items 

Foreign exchange contracts 

Amounts related to interest settlements on derivatives (2)(3) 

Recognized on derivatives 

Recognized on hedged items 

— 

— 

9 

— 

— 

         Net income (expense) recognized on fair value hedges 

(573) 

— 

— 

— 

— 

— 

— 

— 

Gains (losses) on cash flow hedging relationships 

Interest contracts 

Realized gains (losses) (pre tax) reclassified from cumulative

OCI into net income (5) 

Gains (losses) (before tax) recognized in income for hedge

ineffectiveness 

Foreign exchange contracts 

Realized gains (losses) (pre-tax) reclassified from cumulative

OCI into net income (5) 

         Net income (expense) recognized on cash flow hedges 

$ 

— 

1,043 

— 

— 

— 

— 

— 

1,043 

(6) 

— 

— 

— 

— 

— 

(6) 

— 

— 

— 

— 

62 

— 

— 

— 

— 

— 

62 

— 

— 

— 

— 

1,830 

— 

1,304 

— 

— 

31 

— 

— 

(2,175) 

(2,175) 

2,157 

2,157 

— 

40 

(274) 

(274) 

286 

286

1,861 

(6) 

1,338 

(14) 

— 

— 

(14) 

— 

1,029 

(1) 

(1) 

— 

(1) 

— 

1,028 

(1)  Year ended December 31, 2016, gain or loss amounts and presentation location were not conformed to new hedge accounting guidance that we adopted in 2017. 
(2) 
(3) 

Includes changes in fair value due to the passage of time associated with the non-zero fair value amount at hedge inception. 
Includes $(2) million, $(3) million and $(13) million for years ended December 31, 2018, 2017, and 2016, respectively, of the time value component recognized as net 
interest income (expense) on forward derivatives hedging foreign currency available-for-sale securities and long-term debt that were excluded from the assessment of 
hedge effectiveness. 

(4)  For certain fair value hedges of foreign currency risk, changes in fair value of cross-currency swaps attributable to changes in cross-currency basis spreads are excluded 

from the assessment of hedge effectiveness and recorded in other comprehensive income. See Note 25 (Other Comprehensive Income) for the amounts recognized in other 
comprehensive income. 

(5)  See Note 25 (Other Comprehensive Income) for details of amounts reclassified to net income. 

224 

Wells Fargo & Company 

224

Table 17.4 shows the carrying amount and associated 
cumulative basis adjustment related to the application of hedge 
accounting that is included in the carrying amount of hedged 
assets and liabilities in fair value hedging relationships. 

Table 17.4:  Hedged Items in Fair Value Hedging Relationship 

(in millions) 

December 31, 2018 

Hedged Items Currently Designated 

Hedged Items No Longer Designated (1) 

Carrying Amount  Hedge Accounting Basis 
Adjustment 
Assets/(Liabilities) (3) 

of Assets/ 
(Liabilities) (2)(4) 

Carrying Amount of 
Assets/(Liabilities) (4) 

Hedge Accounting
Basis Adjustment
Assets/(Liabilities) 

Available-for-sale debt securities (5) 

$ 

37,857 

Loans 

Mortgage loans held for sale 

Deposits 

Long-term debt 

December 31, 2017 

— 

448 

(56,535) 

(104,341) 

Available-for-sale debt securities (5) 

$ 

32,498 

Loans 

Mortgage loans held for sale 

Deposits 

Long-term debt 

140 

465 

(23,679) 

(128,950) 

(157) 

—

7 

115 

(742) 

870 

(1) 

(1) 

158 

4,938 

—

— 

— 

(25,539) 

5,221 

— 

— 

— 

(2,154) 

(1,953) 

238 

— 

— 

— 

366 

343 

— 

— 

— 

16 

(1)  Represents hedged items no longer designated in qualifying fair value hedging relationships for which an associated basis adjustment exists at the balance sheet date. 
(2)  Does not include the carrying amount of hedged items where only foreign currency risk is the designated hedged risk. The carrying amount excluded for debt securities is 

$1.6 billion and for long-term debt is $(6.3) billion as of December 31, 2018, and $1.5 billion for debt securities and for long-term debt is $(7.7) billion as of December 31, 
2017. 

(3)  The balance includes $1.4 billion and $66 million of debt securities and long-term debt cumulative basis adjustments as of December 31, 2018, respectively, and 

$2.1 billion and $297 million of debt securities and long-term debt cumulative basis adjustments as of December 31, 2017, respectively, on terminated hedges whereby the 
hedged items have subsequently been re-designated into existing hedges. 

(4)  Represents the full carrying amount of the hedged asset or liability item as of the balance sheet date, except for circumstances in which only a portion of the asset or 

liability was designated as the hedged item in which case only the portion designated is presented. 

(5)  Carrying amount represents the amortized cost. 

Derivatives Not Designated as Hedging Instruments 
We use economic hedge derivatives to hedge the risk of changes 
in the fair value of certain residential MLHFS, residential MSRs 
measured at fair value, derivative loan commitments and other 
interests held. We also use economic hedge derivatives to 
mitigate the periodic earnings volatility caused by mismatches 
between the changes in fair value of the hedged item and 
hedging instrument recognized on our fair value accounting 
hedges. The resulting gain or loss on these economic hedge 
derivatives is reflected in mortgage banking noninterest income, 
net gains (losses) from equity securities and other noninterest 
income. 

The derivatives used to hedge MSRs measured at fair value, 

which include swaps, swaptions, constant maturity mortgages, 
forwards, Eurodollar and Treasury futures and options 
contracts, resulted in net derivative gains (losses) of 
$(1.1) billion, $413 million, and $261 million in 2018, 2017, and 
2016, respectively, which are included in mortgage banking 
noninterest income. The aggregate fair value of these derivatives 
was a net asset of $757 million at December 31, 2018, and a net 
asset of $89 million at December 31, 2017. The change in fair 
value of these derivatives for each period end is due to changes 
in the underlying market indices and interest rates as well as the 
purchase and sale of derivative financial instruments throughout 
the period as part of our dynamic MSR risk management 
process. 

Loan commitments for mortgage loans that we intend to sell 

are considered derivatives. Our interest rate exposure on these 
derivative loan commitments, as well as residential MLHFS, is 
hedged with economic hedge derivatives such as swaps, forwards 
and options, Eurodollar futures and options, and Treasury 
futures, forwards and options contracts. The derivative loan 
commitments, economic hedge derivatives and residential 

MLHFS are carried at fair value with changes in fair value 
included in mortgage banking noninterest income. For the fair 
value measurement of derivative loan commitments we include, 
at inception and during the life of the loan commitment, the 
expected net future cash flows related to the associated servicing 
of the loan. Fair value changes subsequent to inception are based 
on changes in fair value of the underlying loan resulting from the 
exercise of the commitment and changes in the probability that 
the loan will not fund within the terms of the commitment 
(referred to as a fall-out factor). The value of the underlying loan 
is affected by changes in interest rates and the passage of time. 
However, changes in investor demand can also cause changes in 
the value of the underlying loan value that cannot be hedged. 
The aggregate fair value of derivative loan commitments on the 
balance sheet was a net positive fair value of $60 million and 
$17 million at December 31, 2018 and 2017, respectively, and is 
included in the caption “Interest rate contracts” under 
“Customer accommodation trading and other derivatives” in 
Table 17.1. 

We also enter into various derivatives as an accommodation 

to our customers as part of our trading businesses. These 
derivatives are not linked to specific assets and liabilities on the 
balance sheet or to forecasted transactions in an accounting 
hedge relationship and, therefore, do not qualify for hedge 
accounting. We also enter into derivatives for risk management 
that do not otherwise qualify for hedge accounting. They are 
carried at fair value with changes in fair value recorded in 
noninterest income. 

Customer accommodation trading and other derivatives also 

include embedded derivatives that are required to be accounted 
for separately from their host contract. We periodically issue 
hybrid long-term notes and CDs where the performance of the 
hybrid instrument notes is linked to an equity, commodity or 

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Wells Fargo & Company 

225 

  
Note 17:  Derivatives (continued) 

currency index, or basket of such indices. These notes contain 
explicit terms that affect some or all of the cash flows or the 
value of the note in a manner similar to a derivative instrument 
and therefore are considered to contain an “embedded” 
derivative instrument. The indices on which the performance of 
the hybrid instrument is calculated are not clearly and closely 
related to the host debt instrument. The “embedded” derivative 
is separated from the host contract and accounted for as a 
derivative. Additionally, we may invest in hybrid instruments 
that contain embedded derivatives, such as credit derivatives, 

that are not clearly and closely related to the host contract. In 
such instances, we either elect fair value option for the hybrid 
instrument or separate the embedded derivative from the host 
contract and account for the host contract and derivative 
separately. 

Table 17.5 shows the net gains (losses), recognized by 
income statement lines, related to derivatives not designated as 
hedging instruments. 

Table 17.5: Gains (Losses) on Derivatives Not Designated as Hedging Instruments 

(in millions) 

Mortgage banking 

Net gains (losses)  Net gains (losses)
from trading
activities 

from equity 
securities 

Noninterest income 

Other 

Total 

Year ended December 31, 2018 

Net gains (losses) recognized on
economic hedges derivatives: 

Interest rate contracts (1) 

$ 

(215) 

(215) 

(408) 

— 

— 

—

— 

— 

— 

— 

—

(352) 

— 

(408) 

— 

 —

— 

— 

— 

— 

— 

 —

— 

— 

— 

— 

 —

— 

446 

4,499 

638 

1 

83 

 —

(15) 

4 

669 

 —

658 

— 

(403) 

— 

— 

— 

 —

(230) 

(404) 

669 

 —

35 

94 

4,096 

638 

1 

83 

 —

5,667 

(403) 

4,912 

Interest rate contracts (3) 

(352) 

Equity contracts 

Foreign exchange contracts 

Credit contracts

Subtotal (2) 

Net gains (losses) recognized on

customer accommodation trading
and other derivatives: 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Commodity contracts 

Other

Subtotal 

Net gains (losses) recognized
related to derivatives not 
designated as hedging
instruments 

(Continued on following page) 

$ 

(567) 

(408) 

5,667 

255 

4,947 

226 

Wells Fargo & Company 

226

 
 
 
 
 
(continued from previous page) 

(in millions) 

Mortgage banking 

Net gains (losses) 
from equity 
securities 

Net gains (losses)
from trading 
activities 

Noninterest income 

Other 

Total 

Year ended December 31, 2017 

Net gains (losses) recognized on
economic hedges derivatives: 

Interest rate contracts (1) 

$ 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Subtotal (2) 

Net gains (losses) recognized on

customer accommodation trading and
other derivatives: 

Interest rate contracts (3) 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Commodity contracts 

Other

Subtotal 

Net gains (losses) recognized related to
derivatives not designated as hedging
instruments 

$ 

Year ended December 31, 2016 

Net gains (losses) recognized on
economic hedges derivatives: 

448 

— 

— 

— 

448 

614 

— 

— 

— 

— 

—————

614 

— 

(1,483) 

— 

— 

(1,483) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

160 

(3,932) 

638 

(81) 

178 

(3,037) 

(75) 

17 

(866) 

5 

(919) 

— 

1 

— 

— 

— 

1 

373 

(1,466) 

(866) 

5 

(1,954) 

774 

(3,931) 

638 

(81) 

178 

(2,422) 

1,062 

(1,483) 

(3,037) 

(918) 

(4,376) 

Interest rate contracts (1) 

$ 

1,029 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Subtotal (2) 

Net gains (losses) recognized on

customer accommodation trading and
other derivatives: 
Interest contracts (3) 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Commodity contracts 

Other 

Subtotal 

Net gains (losses) recognized related to
derivatives not designated as hedging
instruments 

$ 

— 

— 

— 

1,029 

818 

— 

— 

— 

— 

— 

818 

— 

125 

— 

— 

125 

— 

— 

— 

— 

— 

—

— 

— 

— 

— 

— 

— 

255 

(1,643) 

1,077 

(105) 

216 

11 

(189) 

(51) 

(11) 

954 

21 

913 

— 

— 

— 

— 

— 

—

— 

978 

114 

954 

21 

2,067 

1,073 

(1,643) 

1,077 

(105) 

216 

11 

629 

1,847 

125 

(189) 

913 

2,696 

(1) 
(2) 

Includes gains (losses) on the derivatives used as economic hedges of MSRs measured at fair value, derivative loan commitments and mortgages held for sale. 
Includes hedging gains (losses) of $9 million, $(71) million, and $(8) million for the years ended December 31, 2018, 2017, and 2016, respectively, which partially offset 
hedge accounting ineffectiveness. 

(3)  Amounts presented in mortgage banking noninterest income are gains (losses) on derivative loan commitments. 

Credit Derivatives 
Credit derivative contracts are arrangements whose value is 
derived from the transfer of credit risk of a reference asset or 
entity from one party (the purchaser of credit protection) to 
another party (the seller of credit protection). We use credit 
derivatives to assist customers with their risk management 
objectives. We may also use credit derivatives in structured 
product transactions or liquidity agreements written to special 
purpose vehicles. The maximum exposure of sold credit 
derivatives is managed through posted collateral, purchased 
credit derivatives and similar products in order to achieve our 
desired credit risk profile. This credit risk management provides 
an ability to recover a significant portion of any amounts that 
would be paid under the sold credit derivatives. We would be 

required to perform under the sold credit derivatives in the event 
of default by the referenced obligors. Events of default include 
events such as bankruptcy, capital restructuring or lack of 
principal and/or interest payment. In certain cases, other 
triggers may exist, such as the credit downgrade of the 
referenced obligors or the inability of the special purpose vehicle 
for which we have provided liquidity to obtain funding. 

Table 17.6 provides details of sold and purchased credit 

derivatives. 

227

Wells Fargo & Company 

227 

 
 
 
Fair value 
liability 

Protection 
sold (A) 

Protection 
sold - non-
investment 
grade 

Protection 
purchased with
identical 
underlyings (B) 

Net 
protection
sold (A)-(B) 

Other 
protection
purchased 

Range of 
maturities 

Notional amount 

Note 17:  Derivatives (continued) 

Table 17.6:  Sold and Purchased Credit Derivatives 

(in millions) 

December 31, 2018 

Credit default swaps on: 

Corporate bonds 

Structured products 

Credit protection on: 

Default swap index 

Commercial mortgage-backed securities index 

Asset-backed securities index 

Other 

$ 

59 

62 

1 

49 

9 

2 

2,037 

133 

3,618 

389 

42 

5,522 

Total credit derivatives 

$ 

182 

11,741 

December 31, 2017 

Credit default swaps on: 

Corporate bonds 

Structured products 

Credit protection on: 

Default swap index 

Commercial mortgage-backed securities index 

Asset-backed securities index 

Other 

$ 

35 

86 

— 

83 

9 

1 

Total credit derivatives 

$ 

214 

2,007 

267 

2,626 

423 

42 

3,656 

9,021 

Protection sold represents the estimated maximum 
exposure to loss that would be incurred under an assumed 
hypothetical circumstance, where the value of our interests and 
any associated collateral declines to zero, without any 
consideration of recovery or offset from any economic hedges. 
We believe this hypothetical circumstance to be an extremely 
remote possibility and accordingly, this required disclosure is 
not an indication of expected loss. The amounts under non-
investment grade represent the notional amounts of those credit 
derivatives on which we have a higher risk of being required to 
perform under the terms of the credit derivative and are a 
function of the underlying assets. 

We consider the risk of performance to be high if the 
underlying assets under the credit derivative have an external 
rating that is below investment grade or an internal credit 
default grade that is equivalent thereto. We believe the net 
protection sold, which is representative of the net notional 
amount of protection sold and purchased with identical 
underlyings, in combination with other protection purchased, is 
more representative of our exposure to loss than either non-
investment grade or protection sold. Other protection purchased 
represents additional protection, which may offset the exposure 
to loss for protection sold, that was not purchased with an 
identical underlying of the protection sold. 

Credit-Risk Contingent Features 
Certain of our derivative contracts contain provisions whereby if 
the credit rating of our debt were to be downgraded by certain 
major credit rating agencies, the counterparty could demand 
additional collateral or require termination or replacement of 
derivative instruments in a net liability position. The aggregate 
fair value of all derivative instruments with such credit-risk-
related contingent features that are in a net liability position was 
$7.4 billion at December 31, 2018, and $8.3 billion at 
December 31, 2017, respectively, for which we posted 
$5.6 billion and $7.1 billion, respectively, in collateral in the 
normal course of business. If the credit rating of our debt had 
been downgraded below investment grade, which is the credit-
risk-related contingent feature that if triggered requires the 

441 

128 

582 

109 

42 

5,327 

6,629 

510 

252 

540 

— 

— 

3,306 

4,608 

1,374 

121 

1,998 

363 

42 

— 

3,898 

1,575 

232 

308 

401 

42 

— 

2,558 

663 

12 

1,460 

113 

2019 - 2027 

2022 - 2047 

1,620 

2,896 

2019 - 2028 

26 

— 

5,522 

7,843 

51 

1 

2047 - 2058 

2045 - 2046 

12,561 

2018 - 2048 

17,082 

432 

35 

946 

153 

2018 - 2027 

2022 - 2047 

2,318 

3,932 

22 

— 

3,656 

6,463 

87 

1 

9,840 

14,959 

2018 - 2027 

2047 - 2058 

2045 - 2046 

2018 - 2031 

maximum amount of collateral to be posted, on December 31, 
2018, or December 31, 2017, we would have been required to 
post additional collateral of $1.8 billion or $1.2 billion, 
respectively, or potentially settle the contract in an amount equal 
to its fair value. Some contracts require that we provide more 
collateral than the fair value of derivatives that are in a net 
liability position if a downgrade occurs. 

Counterparty Credit Risk 
By using derivatives, we are exposed to counterparty credit risk 
if counterparties to the derivative contracts do not perform as 
expected. If a counterparty fails to perform, our counterparty 
credit risk is equal to the amount reported as a derivative asset 
on our balance sheet. The amounts reported as a derivative asset 
are derivative contracts in a gain position, and to the extent 
subject to legally enforceable master netting arrangements, net 
of derivatives in a loss position with the same counterparty and 
cash collateral received. We minimize counterparty credit risk 
through credit approvals, limits, monitoring procedures, 
executing master netting arrangements and obtaining collateral, 
where appropriate. To the extent the master netting 
arrangements and other criteria meet the applicable 
requirements, including determining the legal enforceability of 
the arrangement, it is our policy to present derivative balances 
and related cash collateral amounts net on the balance sheet. We 
incorporate credit valuation adjustments (CVA) to reflect 
counterparty credit risk in determining the fair value of our 
derivatives. Such adjustments, which consider the effects of 
enforceable master netting agreements and collateral 
arrangements, reflect market-based views of the credit quality of 
each counterparty. Our CVA calculation is determined based on 
observed credit spreads in the credit default swap market and 
indices indicative of the credit quality of the counterparties to 
our derivatives. 

228 

Wells Fargo & Company 

228

  
 
 
Note 18:  Fair Values of Assets and Liabilities 

We use fair value measurements to record fair value adjustments 
to certain assets and liabilities and to determine fair value 
disclosures. Assets and liabilities recorded at fair value on a 
recurring basis are presented in Table 18.2 in this Note. From 
time to time, we may be required to record fair value 
adjustments on a nonrecurring basis. These nonrecurring fair 
value adjustments typically involve application of LOCOM 
accounting, write-downs of individual assets or application of 
the measurement alternative for nonmarketable equity 
securities. Assets recorded on a nonrecurring basis are presented 
in Table 18.12 in this Note. 

Following is a discussion of the fair value hierarchy and the 

valuation methodologies we use for assets and liabilities 
recorded at fair value on a recurring or nonrecurring basis and 
for estimating fair value for financial instruments that are not 
recorded at fair value. 

FAIR VALUE HIERARCHY  We group our assets and liabilities 
measured at fair value in three levels based on the markets in 
which the assets and liabilities are traded and the reliability of 
the assumptions used to determine fair value. These levels are: 
• 

Level 1 – Valuation is based upon quoted prices for identical 
instruments traded in active markets. 
Level 2 – Valuation is based upon quoted prices for similar 
instruments in active markets, quoted prices for identical or 
similar instruments in markets that are not active, and 
model-based valuation techniques for which all significant 
assumptions are observable in the market. 
Level 3 – Valuation is generated from techniques that use 
significant assumptions that are not observable in the 
market. These unobservable assumptions reflect estimates 
of assumptions that market participants would use in 
pricing the asset or liability. Valuation techniques include 
use of option pricing models, discounted cash flow models 
and similar techniques.

• 

• 

 We do not classify equity securities in the fair value 

hierarchy if we use the non-published net asset value (NAV) per 
share (or its equivalent) that has been communicated to us as an 
investor as a practical expedient to measure fair value. We 
generally use NAV per share as the fair value measurement for 
certain nonmarketable equity fund investments. Marketable 
equity securities with published NAVs are classified in the fair 
value hierarchy. 

In the determination of the classification of financial 
instruments in Level 2 or Level 3 of the fair value hierarchy, we 
consider all available information, including observable market 
data, indications of market liquidity and orderliness, and our 
understanding of the valuation techniques and significant inputs 
used. For securities in inactive markets, we use a predetermined 
percentage to evaluate the impact of fair value adjustments 
derived from weighting both external and internal indications of 
value to determine if the instrument is classified as Level 2 or 
Level 3. Otherwise, the classification of Level 2 or Level 3 is 
based upon the specific facts and circumstances of each 
instrument or instrument category and judgments are made 
regarding the significance of the Level 3 inputs to the 
instruments’ fair value measurement in its entirety. If Level 3 
inputs are considered significant, the instrument is classified as 
Level 3. 

Assets 
SHORT-TERM FINANCIAL ASSETS  Short-term financial assets 
include cash and due from banks, interest-earning deposits with 
banks, federal funds sold and securities purchased under resale 
agreements and due from customers on acceptances (classified 
in Other Assets). These assets are carried at historical cost. The 
carrying amount is a reasonable estimate of fair value because of 
the relatively short time between the origination of the 
instrument and its expected realization. 

TRADING DEBT SECURITIES  Trading debt securities are 
recorded at fair value on a recurring basis. These securities are 
valued using internal trader prices that are subject to price 
verification procedures. The fair values derived using internal 
valuation techniques are verified against multiple pricing 
sources, including prices obtained from third- party vendors. 
Vendors compile prices from various sources and often apply 
matrix pricing for similar securities when no price is observable. 
We review pricing methodologies provided by the vendors in 
order to determine if observable market information is being 
used versus unobservable inputs. When evaluating the 
appropriateness of an internal trader price compared with 
vendor prices, considerations include the range and quality of 
vendor prices. Vendor prices are used to ensure the 
reasonableness of a trader price; however, valuing financial 
instruments involves judgments acquired from knowledge of a 
particular market. If a trader asserts that a vendor price is not 
reflective of market value, justification for using the trader price, 
including recent sales activity where possible, must be provided 
to and approved by the appropriate levels of management. 

AVAILABLE-FOR-SALE AND HELD-TO-MATURITY DEBT 
SECURITIES  Available-for-sale (AFS) debt securities are 
recorded at fair value on a recurring basis and held-to-maturity 
(HTM) debt securities are recorded at amortized cost. HTM debt 
securities are subject to impairment and fair value measurement 
is recorded if the fair value declines below amortized cost and we 
do not expect to recover the entire amortized cost basis of the 
security. Fair value measurement for AFS and HTM debt 
securities is based upon various sources of market pricing. We 
use quoted prices in active markets, where available, and classify 
such instruments within Level 1 of the fair value hierarchy. For 
example, highly liquid government securities, such as U.S. 
Treasuries, are classified as Level 1. When instruments are 
traded in secondary markets and quoted market prices do not 
exist for such securities, we generally rely on internal valuation 
techniques or on prices obtained from vendors (predominantly 
third-party pricing services), and accordingly, we classify these 
instruments as Level 2 or 3. 

AFS debt securities traded in secondary markets are 

typically valued using unadjusted vendor prices or vendor prices 
adjusted by weighting them with internal discounted cash flow 
techniques, these prices are reviewed and, if deemed 
inappropriate by a trader who has the most knowledge of a 
particular market, can be adjusted. These securities, which 
include those measured using unadjusted vendor prices, are 
generally classified as Level 2 and typically involve using quoted 
market prices for the same or similar securities, pricing models, 
discounted cash flow analyses using significant inputs 
observable in the market where available or a combination of 
multiple valuation techniques. Examples include certain 
residential and commercial MBS, other asset-backed securities 

229

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229 

 
 
 
 
Note 18:  Fair Values of Assets and Liabilities (continued) 

municipal bonds, U.S. government and agency MBS, and 
corporate debt securities. 

Debt security fair value measurements using significant 
inputs that are unobservable in the market due to limited activity 
or a less liquid market are classified as Level 3 in the fair value 
hierarchy. Such measurements include securities valued using 
internal models or a combination of multiple valuation 
techniques where the unobservable inputs are significant to the 
overall fair value measurement. Securities classified as Level 3 
include certain residential and commercial MBS, other asset-
backed securities, CDOs and certain CLOs, and certain residual 
and retained interests in residential mortgage loan 
securitizations. We value CDOs using the prices of similar 
instruments, the pricing of completed or pending third-party 
transactions or the pricing of the underlying collateral within the 
CDO. Where vendor prices are not readily available, we use 
management’s best estimate. 

MORTGAGE LOANS HELD FOR SALE (MLHFS)  MLHFS are 
carried at LOCOM or at fair value. We carry substantially all of 
our residential MLHFS portfolio at fair value. Fair value is based 
on quoted market prices, where available, or the prices for other 
mortgage whole loans with similar characteristics. As necessary, 
these prices are adjusted for typical securitization activities, 
including servicing value, portfolio composition, market 
conditions and liquidity. Predominantly all of our MLHFS are 
classified as Level 2. For the portion where market pricing data 
is not available, we use a discounted cash flow model to estimate 
fair value and, accordingly, classify as Level 3. 

LOANS HELD FOR SALE (LHFS)  LHFS are carried at LOCOM 
or at fair value. Loans used in our trading business are recorded 
at fair value on a recurring basis, and the fair value is based on 
current offerings in secondary markets for loans with similar 
characteristics. Loans that are subject to nonrecurring fair value 
adjustments are classified as Level 2. 

LOANS  For information on how we report the carrying value of 
loans, see Note 1 (Summary of Significant Accounting Policies). 
Although most loans are not recorded at fair value on a recurring 
basis, reverse mortgages are recorded at fair value on a recurring 
basis. In addition, we record nonrecurring fair value adjustments 
to loans to reflect partial write-downs that are based on the 
observable market price of the loan or current appraised value of 
the collateral. 

We provide fair value estimates that are based on an exit 

price notion in this disclosure for loans that are not recorded at 
fair value on a recurring or nonrecurring basis. The fair value 
estimates of these loans are differentiated by their financial 
characteristics, such as product classification, loan category, 
pricing features and remaining maturity. Prepayment and credit 
loss estimates are evaluated and used in the valuation process. 

DERIVATIVES  All derivatives are recorded at fair value on a 
recurring basis. Derivative valuation includes the use of available 
market prices for our exchange-traded derivatives, such as 
certain interest rate futures and option contracts, which we 
classify as Level 1. However, substantially all of our derivatives 
are traded in over-the-counter (OTC) markets where quoted 
market prices are not always readily available. Therefore we 
value most OTC derivatives using internal valuation techniques. 
Valuation techniques and inputs to internally-developed models 
depend on the type of derivative and nature of the underlying 
rate, price or index upon which the derivative’s value is based. 
Key inputs can include yield curves, credit curves, foreign 

exchange rates, prepayment rates, volatility measurements and 
correlation of such inputs. Where model inputs can be observed 
in a liquid market and the model does not require significant 
judgment, such derivatives are typically classified as Level 2 of 
the fair value hierarchy. Examples of derivatives classified as 
Level 2 include generic interest rate swaps, foreign currency 
swaps, commodity swaps, and certain option and forward 
contracts. When instruments are traded in less liquid markets 
and significant inputs are unobservable, such derivatives are 
classified as Level 3. Examples of derivatives classified as Level 3 
include complex and highly structured derivatives, certain credit 
default swaps, derivative loan commitments written for our 
mortgage loans that we intend to sell and long-dated equity 
options where volatility is not observable. Additionally, 
significant judgments are required when classifying financial 
instruments within the fair value hierarchy, particularly between 
Level 2 and 3, as is the case for certain derivatives. 

MORTGAGE SERVICING RIGHTS (MSRs) AND CERTAIN 
OTHER INTERESTS HELD IN SECURITIZATIONS  MSRs and 
certain other interests held in securitizations (e.g., interest-only 
strips) do not trade in an active market with readily observable 
prices. Accordingly, we determine the fair value of MSRs using a 
valuation model that calculates the present value of estimated 
future net servicing income cash flows. The model incorporates 
assumptions that market participants use in estimating future 
net servicing income cash flows, including estimates of 
prepayment speeds (including housing price volatility), discount 
rates, default rates, cost to service (including delinquency and 
foreclosure costs), escrow account earnings, contractual 
servicing fee income, ancillary income and late fees. Commercial 
MSRs are carried at LOCOM and, therefore, can be subject to 
fair value measurements on a nonrecurring basis. Changes in the 
fair value of MSRs occur primarily due to the collection/ 
realization of expected cash flows as well as changes in valuation 
inputs and assumptions. For other interests held in 
securitizations (such as interest-only strips), we use a valuation 
model that calculates the present value of estimated future cash 
flows. The model incorporates our own estimates of assumptions 
market participants use in determining the fair value, including 
estimates of prepayment speeds, discount rates, defaults and 
contractual fee income. Interest-only strips are recorded as 
trading assets. Our valuation approach is validated by our 
internal valuation model validation group. Fair value 
measurements of our MSRs and interest-only strips use 
significant unobservable inputs and, accordingly, we classify 
them as Level 3. 

EQUITY SECURITIES  Marketable equity securities and certain 
nonmarketable equity securities for which we have elected to 
account for under the fair value method are recorded at fair 
value on a recurring basis. Our remaining nonmarketable equity 
securities are accounted for using the equity method, cost 
method or measurement alternative. These securities can be 
subject to nonrecurring fair value adjustments to record 
impairment write-downs or, for equity securities accounted for 
under the measurement alternative, adjustments to the carrying 
value due to the occurrence of observable transactions. 
We use quoted prices to determine the fair value of 

marketable equity securities as the securities are publicly traded. 
Quoted prices are typically not available for nonmarketable 
equity securities. We therefore use other methods, such as 
market comparable pricing or discounted cash flow valuation 
techniques, to determine fair value for such securities. We use all 
available information in making this determination, which 

230 

Wells Fargo & Company 

230

 
 
 
 
includes observable transaction prices for the same or similar 
security, vendor prices, broker quotes, trading multiples of 
comparable public companies and discounted cash flow models. 
Where appropriate we make adjustments to observed market 
data to reflect the comparative differences between the market 
data and the attributes of our equity security, such as differences 
with public companies and other investment-specific 
considerations like liquidity, marketability or differences in 
terms of the instruments. Substantially all of our nonmarketable 
equity securities accounted for under the cost method include 
Federal Reserve Bank stock and Federal Home Loan Bank stock, 
of which their carrying value approximate their fair value. 

FORECLOSED ASSETS  Foreclosed assets are carried at net 
realizable value, which represents fair value less costs to sell. 
Fair value is generally based upon independent market prices or 
appraised values of the collateral and, accordingly, we classify 
foreclosed assets as Level 2. 

Liabilities 
DEPOSIT AND SHORT-TERM FINANCIAL LIABILITIES 
Deposit and short-term financial liabilities are recorded at 
historical cost. For this disclosure, we estimate the fair value of 
deposit liabilities with a contractual or defined maturity and 
short-term financial liabilities, which include federal funds 
purchased, securities sold under repurchase agreements, 
commercial paper and other short-term borrowings. The 
carrying value of our short-term financial liabilities is a 
reasonable estimate of their fair value because of the relatively 
short time between their origination and expected realization. 

OTHER LIABILITIES  Other liabilities recorded at fair value on 
a recurring basis predominantly include short sale liabilities. 
Short sale liabilities are predominantly classified as either Level 
1 or Level 2, generally depending upon whether the underlying 
securities have readily available quoted prices in active markets. 

LONG-TERM DEBT  Long-term debt is recorded at amortized 
cost. For this disclosure, we estimate the fair value of our long-
term debt, which is largely denominated in U.S. dollars that are 
issued with a fixed or floating rate at varying levels of seniority 
and maturity. 

Level 3 Asset and Liability Valuation Processes 
We generally determine fair value of our Level 3 assets and 
liabilities by using internally-developed models and, to a lesser 
extent, prices obtained from vendors, which predominantly 
consist of third-party pricing services. Our valuation processes 
vary depending on which approach is utilized. 

INTERNAL MODEL VALUATIONS  Our internally-developed 
models largely use discounted cash flow techniques. Use of such 
techniques requires determining relevant inputs, some of which 
are unobservable. Unobservable inputs are generally derived 
from historic performance of similar assets or determined from 
previous market trades in similar instruments. These 
unobservable inputs usually consist of discount rates, default 
rates, loss severity upon default, volatilities, correlations and 
prepayment rates, which are inherent within our Level 3 
instruments. Such inputs can be correlated to similar portfolios 
with known historic experience or recent trades where particular 
unobservable inputs may be implied, but due to the nature of 
various inputs being reflected within a particular trade, the value 
of each input is considered unobservable. We attempt to 

correlate each unobservable input to historic experience and 
other third-party data where available. 

Internal valuation models are subject to review prescribed 

within our model risk management policies and procedures, 
which include model validation. The purpose of model validation 
includes ensuring the model is appropriate for its intended use 
and the appropriate controls exist to help mitigate risk of invalid 
valuations. Model validation assesses the adequacy and 
appropriateness of the model, including reviewing its key 
components, such as inputs, processing components, logic or 
theory, output results and supporting model documentation. 
Validation also includes ensuring significant unobservable 
model inputs are appropriate given observable market 
transactions or other market data within the same or similar 
asset classes. This process ensures modeled approaches are 
appropriate given similar product valuation techniques and are 
in line with their intended purpose. 

We have ongoing monitoring procedures in place for our 

Level 3 assets and liabilities that use such internal valuation 
models. These procedures, which are designed to provide 
reasonable assurance that models continue to perform as 
expected after approved, include: 
• 

ongoing analysis and benchmarking to market transactions 
and other independent market data (including pricing 
vendors, if available); 
back-testing of modeled fair values to actual realized 
transactions; and 
review of modeled valuation results against expectations, 
including review of significant or unusual value fluctuations. 

• 

• 

We update model inputs and methodologies periodically to 

reflect these monitoring procedures. Additionally, procedures 
and controls are in place to ensure existing models are subject to 
periodic reviews, and we perform full model revalidations as 
necessary. 

All internal valuation models are subject to ongoing review 
by business-unit-level management, and all models are subject 
to additional oversight by a corporate-level risk management 
department. Corporate oversight responsibilities include 
evaluating the adequacy of business unit risk management 
programs, maintaining company-wide model validation policies 
and standards and reporting the results of these activities to 
management and our Corporate Model Risk Committee. This 
committee consists of senior executive management and reports 
on top model risk issues to the Company’s Risk Committee of the 
Board. 

VENDOR-DEVELOPED VALUATIONS  In certain limited 
circumstances, we obtain pricing from third-party vendors for 
the value of our Level 3 assets or liabilities. We have processes in 
place to approve such vendors to ensure information obtained 
and valuation techniques used are appropriate. Once these 
vendors are approved to provide pricing information, we 
monitor and review the results to ensure the fair values are 
reasonable and in line with market experience in similar asset 
classes. While the input amounts used by the pricing vendor in 
determining fair value are not provided, and therefore 
unavailable for our review, we do perform one or more of the 
following procedures to validate the prices received: 
• 
• 
• 

comparison to other pricing vendors (if available); 
variance analysis of prices; 
corroboration of pricing by reference to other independent 
market data, such as market transactions and relevant 
benchmark indices; 

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Wells Fargo & Company 

231 

 
 
 
 
 
 
Note 18:  Fair Values of Assets and Liabilities (continued) 

• 

• 

review of pricing by Company personnel familiar with 
market liquidity and other market-related conditions; and 
investigation of prices on a specific instrument-by-
instrument basis. 

Fair Value Measurements from Vendors 
For certain assets and liabilities, we obtain fair value 
measurements from vendors, which predominantly consist of 
third-party pricing services, and record the unadjusted fair value 
in our financial statements. For instruments where we utilize 
vendor prices to record the price of an instrument, we perform 
additional procedures (see the “Vendor-Developed Valuations” 

section). Methodologies employed, controls relied upon and 
inputs used by third-party pricing vendors are subject to 
additional review when such services are provided. This review 
may consist of, in part, obtaining and evaluating control reports 
issued and pricing methodology materials distributed. 

Table 18.1 presents unadjusted fair value measurements
provided by brokers or third-party pricing services by fair value
hierarchy level. Fair value measurements obtained from brokers
or third-party pricing services that we have adjusted to
determine the fair value recorded in our financial statements are
excluded from Table 18.1.

Table 18.1:  Fair Value Measurements by Brokers or Third-Party Pricing Services 

$ 

$ 

(in millions) 

December 31, 2018 

Trading debt securities 

Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions

Mortgage-backed securities

Other debt securities (1) 

Total available-for-sale debt securities 

Equity securities: 

Marketable

Nonmarketable

Total equity securities

Derivative assets 

Derivative liabilities 

Other liabilities (2) 

December 31, 2017 

Trading debt securities 

Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. states and political subdivisions

Mortgage-backed securities 

Other debt securities (1) 

Total available-for-sale debt securities 

Equity securities: 

Marketable

Nonmarketable

Total equity securities

Derivative assets 

Derivative liabilities 

Other liabilities (2) 

Level 1 

Level 2 

Level 3 

Level 1 

Level 2 

Level 3 

Brokers 

Third-party pricing services 

— 

— 

— 

— 

— 

— 

—

—

—

— 

— 

— 

— 

— 

—

— 

— 

— 

—

—

—

— 

— 

— 

— 

— 

— 

— 

45 

45 

 —

 —

 —

— 

— 

— 

— 

— 

 —

33 

307 

340 

 —

 —

 —

— 

— 

— 

— 

— 

— 

— 

129 

129 

 —

 —

 —

— 

— 

— 

— 

— 

 —

— 

1,158 

1,158 

 —

 —

 —

— 

— 

— 

899 

256 

10,399 

— 

— 

— 

2,949 

48,377

160,162 

44,292 

10,399 

255,780 

 —

 —

 —

17 

(12) 

— 

 158

 1

 159

— 

— 

— 

926 

215 

3,389 

 —

— 

— 

2,930 

50,401 

168,948 

44,465 

— 

— 

43

41 

758 

842 

 —

 —

 —

— 

— 

— 

— 

— 

49 

75 

22 

3,389 

266,744 

146 

 —

 —

 —

19 

(19) 

— 

 227

 —

 227

— 

— 

— 

 —

 —

 —

— 

— 

— 

(1) 
(2) 

Includes corporate debt securities, collateralized loan and other debt obligations, asset-backed securities, and other debt securities. 
Includes short sale liabilities and other liabilities. 

232 

Wells Fargo & Company 

232

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assets and Liabilities Recorded at Fair Value on a 
Recurring Basis 
Table 18.2 presents the balances of assets and liabilities recorded 
at fair value on a recurring basis. 

Table 18.2:  Fair Value on a Recurring Basis 

(in millions) 

December 31, 2018 
Trading debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
Collateralized loan obligations  
Corporate debt securities 
Mortgage-backed securities 
Asset-backed securities 
Other trading debt securities 

Total trading debt securities 

Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
Mortgage-backed securities: 
Federal agencies 
Residential 
Commercial 

Total mortgage-backed securities 

Corporate debt securities 
Collateralized loan and other debt obligations (1) 
Asset-backed securities: 

Automobile loans and leases 
Home equity loans 
Other asset-backed securities 

Total asset-backed securities 

Other debt securities 

Total available-for-sale debt securities 

Mortgage loans held for sale 
Loans held for sale 
Loans 
Mortgage servicing rights (residential) 
Derivative assets: 

Interest rate contracts 
Commodity contracts 
Equity contracts 
Foreign exchange contracts 
Credit contracts 

Netting 

Total derivative assets 

Equity securities - excluding securities at NAV: 

Marketable 

Nonmarketable 

Total equity securities 

 Total assets included in the fair value hierarchy 

Equity securities at NAV (4) 

Total assets recorded at fair value 

Derivative liabilities: 

Interest rate contracts 
Commodity contracts 
Equity contracts 
Foreign exchange contracts 
Credit contracts 

Netting 

Total derivative liabilities 

Short sale liabilities: 

Securities of U.S. Treasury and federal agencies 
Mortgage-backed securities 
Corporate debt securities 
Equity securities 
Other securities 

Total short sale liabilities 

Other liabilities 

Level 1 

Level 2 

Level 3 

Netting 

Total 

$ 

$ 

$ 

20,525 
— 
— 
— 
— 
— 
— 
20,525 

10,399 
— 

— 
— 
— 

— 
34 
— 

— 
— 
— 
— 

— 

10,433 
— 
— 
— 
— 

46 
— 
1,648 
17 
— 
— 

1,711 

23,205 

— 

23,205 

55,874 

(21) 
— 

(1,492) 
(12) 
— 
— 

(1,525) 

(11,850) 

— 
— 

(2,902) 

—

(14,752) 

— 

2,892 
3,272 
673 
10,723 
30,715 
893 
6 
49,174 

2,949 
48,820 

153,203 
2,775 
4,184 

160,162 
5,867 
34,543 

925 
112 
4,056 
5,093 

1 

257,435 
10,774 
1,409 
— 
— 

18,294 
1,535 
4,582 
6,689 
179 
— 

31,279 

757 

24 

781 

350,852 

(16,217) 
(2,287) 
(3,186) 
(7,067) 
(216) 

— 

(28,973) 

(411) 
(47) 
(4,505) 
(2) 
 (3)

(4,968) 

— 

— 
3 
237 
34 
— 
— 
16 
290 

— 
444 

— 
— 
41 

41 
370 
800 

— 
— 
389 
389 

— 

2,044  (2) 

997 
60 
244 
14,649 

95 
53 
1,315 
8 
99 
— 

1,570 

— 

5,468 

5,468 

25,322 

(70) 
(49) 
(1,332) 
(34) 
(64) 
— 

(1,549) 

— 
— 
— 
— 
 —

— 

(2) 

— 
— 
— 
— 
— 
— 
— 
— 

— 
— 

— 
— 
— 

— 
— 
— 

— 
— 
— 
— 

— 

— 
— 
— 
— 
— 

— 
— 
— 
— 
— 
(23,790)  (3) 

(23,790) 

— 

— 

— 

(23,790) 

— 
— 
— 
— 
— 
23,548  (3) 

23,548 

— 

— 
— 
—

— 

— 

23,417 
3,275 
910 
10,757 
30,715 
893 
22 
69,989 

13,348 
49,264 

153,203 
2,775 
4,225 

160,203 
6,271 
35,343 

925 
112 
4,445 

5,482 

1 

269,912 
11,771 
1,469 
244 
14,649 

18,435 
1,588 
7,545 
6,714 
278 

(23,790) 

10,770 

23,962 

5,492 

29,454

408,258 

102 

408,360 

(16,308) 
(2,336) 
(6,010) 
(7,113) 
(280) 

23,548 

(8,499) 

(12,261) 
(47) 
(4,505) 
(2,904) 
(3)

(19,720) 

(2) 

(28,221) 

Total liabilities recorded at fair value 

$ 

(16,277) 

(33,941) 

(1,551) 

23,548 

Includes collateralized debt obligations of $800 million. 

(1) 
(2)  A significant portion of the balance consists of securities that are investment grade based on ratings received from the ratings agencies or internal credit grades categorized 

as investment grade if external ratings are not available. The securities are classified as Level 3 due to limited market activity. 

(3)  Represents balance sheet netting of derivative asset and liability balances and related cash collateral. See Note 17 (Derivatives) for additional information. 
(4)  Consists of certain nonmarketable equity securities that are measured at fair value using NAV per share (or its equivalent) as a practical expedient and are excluded from 

the fair value hierarchy. 

(continued on following page) 

233

Wells Fargo & Company 

233 

  
 
 
 
 
 
Note 18:  Fair Values of Assets and Liabilities (continued) 

Level 1 

Level 2 

Level 3 

Netting 

Total 

(continued from previous page) 

(in millions) 

December 31, 2017 
Trading debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
Collateralized loan obligations  
Corporate debt securities 
Mortgage-backed securities 
Asset-backed securities 
Other trading debt securities 

Total trading debt securities 
Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
Mortgage-backed securities: 

Federal agencies 
Residential 
Commercial 

Total mortgage-backed securities 

Corporate debt securities 
Collateralized loan and other debt obligations (1) 
Asset-backed securities: 

Automobile loans and leases 
Home equity loans 
Other asset-backed securities 

Total asset-backed securities 

Other debt securities 

$ 

12,491 
— 
— 
— 
— 
— 
— 

12,491 

3,389 
— 

— 
— 
— 
— 

56 
— 

— 
— 
— 

— 

— 

2,383 
3,732 
565 
11,760 
25,273 
993 
20 

44,726 

2,930 
50,401 

160,219 
4,607 
4,490 
169,316 

7,203 
35,036 

553 
149 
4,380 

5,082 

— 

— 
3 
354 
31 
— 
— 
19 

407 

— 
925 

— 
1 
75 
76 

407 
1,020 

— 
— 
566 

566 

— 

Total available-for-sale debt securities 

3,445 

269,968 

2,994  (2) 

Mortgage loans held for sale 
Loans held for sale 
Loans 
Mortgage servicing rights (residential) 
Derivative assets: 

Interest rate contracts 
Commodity contracts 
Equity contracts 
Foreign exchange contracts 
Credit contracts 

Netting 

Total derivative assets 

Equity securities - excluding securities at NAV: 

Marketable 

Nonmarketable 

Total equity securities 

 Total assets included in the fair value hierarchy 

Equity securities at NAV (4) 

Total assets recorded at fair value 

Derivative liabilities: 

Interest rate contracts 
Commodity contracts 
Equity contracts 
Foreign exchange contracts 
Credit contracts 

Netting 

Total derivative liabilities 

Short sale liabilities: 

Securities of U.S. Treasury and federal agencies 
Mortgage-backed securities 
Corporate debt securities 
Equity securities 
Other securities 

Total short sale liabilities 

Other liabilities 

— 
— 
— 
— 

17 
— 
1,698 
19 
— 
— 

1,734 

33,931 

— 

33,931 

51,601 

(17) 
— 
(1,313) 
(19) 
— 
— 

(1,349) 

(10,420) 
— 
— 
(2,168) 
— 

(12,588) 

— 

$ 

$ 

15,118 
1,009 
— 
— 

17,479 
2,318 
3,970 
8,944 
269 
— 

32,980 

429 

46 

475 

364,276 

(15,392) 
(1,318) 
(5,338) 
(8,546) 
(336) 
— 

(30,930) 

(568) 
— 
(4,986) 
(45) 
(285) 

(5,884) 

— 

Total liabilities recorded at fair value 

$ 

(13,937) 

(36,814) 

998 
14 
376 
13,625 

134 
36 
1,339 
10 
122 
— 

1,641 

— 

4,821 

4,821 

24,876 

(63) 
(17) 
(1,850) 
(3) 
(86) 
— 

(2,019) 

— 
— 
— 
— 
— 

— 

(3) 

(2,022) 

— 
— 
— 
— 
— 
— 
— 

— 

— 
— 

— 
— 
— 
— 

— 
— 

— 
— 
— 

— 

— 

— 

— 
— 
— 
— 

— 
— 
— 
— 
— 
(24,127)  (3) 

(24,127) 

— 

— 

— 

(24,127) 

— 
— 
— 
— 
— 
25,502  (3) 

25,502 

— 
— 
— 
— 
— 

— 

— 

25,502 

14,874 
3,735 
919 
11,791 
25,273 
993 
39 

57,624 

6,319 
51,326 

160,219 
4,608 
4,565 
169,392 

7,666 
36,056 

553 
149 
4,946 

5,648 

— 

276,407 

16,116 
1,023 
376 
13,625 

17,630 
2,354 
7,007 
8,973 
391 
(24,127) 

12,228 

34,360 

4,867 

39,227

416,626 

— 

416,626 

(15,472) 
(1,335) 
(8,501) 
(8,568) 
(422) 
25,502 

(8,796) 

(10,988) 
— 
(4,986) 
(2,213) 
(285) 

(18,472) 

(3) 

(27,271) 

Includes collateralized debt obligations of $1.0 billion. 

(1) 
(2)  Balance primarily consists of securities that are investment grade based on ratings received from the ratings agencies or internal credit grades categorized as investment 

grade if external ratings are not available. The securities are classified as Level 3 due to limited market activity. 

(3)  Represents balance sheet netting of derivative asset and liability balances and related cash collateral. See Note 17 (Derivatives) for additional information. 
(4)  Consists of certain nonmarketable equity investments that are measured at fair value using NAV per share (or its equivalent) as a practical expedient and are excluded 

from the fair value hierarchy. 

Changes in Fair Value Levels 
We monitor the availability of observable market data to assess 
the appropriate classification of financial instruments within the 
fair value hierarchy and transfer between Level 1, Level 2, and 
Level 3 accordingly. Observable market data includes but is not 
limited to quoted prices and market transactions. Changes in 
economic conditions or market liquidity generally will drive 

changes in availability of observable market data. Changes in 
availability of observable market data, which also may result in 
changing the valuation technique used, are generally the cause of 
transfers between Level 1, Level 2, and Level 3. The amounts 
reported as transfers represent the fair value as of the beginning 
of the quarter in which the transfer occurred. 

234 

Wells Fargo & Company 

234

  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
The changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the year ended December 31, 2018, 

are presented in Table 18.3. 

Table 18.3:  Changes in Level 3 Fair Value Assets and Liabilities on a Recurring Basis – 2018 

Total net gains
(losses) included in 

Purchases,
sales,

Balance,
beginning
of period 

Net 
income 

Other 
compre-
hensive 
income 

issuances  Transfers  Transfers 
out of 
Level 3 
(3) 

and 
settlements, 
net (1) 

into 
Level 3 
(2) 

Net unrealized 
gains (losses)
included in 
income related 
to assets and 
liabilities held 
at period end  (4) 

Balance,
end of 
period 

(in millions) 

Year ended December 31, 2018 

Trading debt securities: 

Securities of U.S. states and 
political subdivisions 

Collateralized loan obligations 

Corporate debt securities 
Other trading debt securities 

Total trading debt securities 

Available-for-sale debt securities: 

Securities of U.S. states and 
political subdivisions 

Mortgage-backed securities: 

Residential 

Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other 

debt obligations 

Asset-backed securities: 

$ 

3 

354 

31 
19 

407 

925 

1 

75 

76 

407 

— 

(12) 

(1) 
(3) 

(16) 

8 

— 

— 

— 

4 

1,020 

72 

Other asset-backed securities 

Total asset-backed securities 

566 

566 

Total available-for-sale debt securities 

2,994 

Mortgage loans held for sale 

Loans held for sale 

Loans 

998 

14 

376 

5 

5 

89 

(27) 

2 

(1) 

Mortgage servicing rights (residential) (8) 

13,625 

(915) 

Net derivative assets and liabilities: 

Interest rate contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Other derivative contracts 

Total derivative contracts 

Equity securities: 

Marketable 

Nonmarketable (10) 

Total equity securities 

Short sale liabilities 

Other liabilities 

71 

19 

(511) 

7 

36 

— 

(397) 

3 

(108) 

(42) 

5 

— 

(378) 

(539) 

—

5,203 

5,203 

— 

(3) 

—

703 

703 

— 

1 

— 

— 

— 
— 

— 

(8) 

— 

(1) 

(1) 

(3) 

5 

(11) 

(11) 

(18) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

(101) 

16 
— 

(85) 

(137) 

(1) 

(33) 

(34) 

(38) 

(297) 

(171) 

(171) 

(677) 

(36) 

(36) 

(131) 

1,939 

351 

(11) 

522 

9 

(6) 

— 

865 

— 

(450) 

(450) 

— 

— 

— 

— 

— 
— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

72 

80 

— 

— 

— 

(7) 

(1) 

— 

— 

— 

(8) 

— 

16 

16 

— 

— 

— 

(4) 

(12) 
— 

(16) 

3 

237 

34 
16 

290 

(344) 

444 

— 

— 

— 

— 

— 

— 

— 

— 

41 

41 

370 

800 

389 

389 

(344) 

2,044 

(10) 

— 

— 

— 

— 

— 

81 

— 

— 

— 

81 

—

(4) 

(4) 

— 

— 

997 

60 

244 

14,649 

25 

4 

(17) 

(26) 

35 

— 

21 

— 

5,468 

5,468 

— 

(2) 

— 

(14) 

(1) 
— 

(15)  (5) 

— 

— 

(1) 

(1) 

— 

— 

(3) 

(3) 

(4)  (6) 

(22)  (7) 

1 

(11)  (7) 

960  (7) 

(42) 

(1) 

(169) 

(26) 

(1) 

— 

(239)  (9) 

— 

642 

642  (11) 

—  (5) 
—  (7) 

(1)  See Table 18.4 for detail. 
(2)  All assets and liabilities transferred into level 3 were previously classified within level 2. 
(3)  All assets and liabilities transferred out of level 3 are classified as level 2. 
(4)  Represents only net gains (losses) that are due to changes in economic conditions and management’s estimates of fair value and excludes changes due to the collection/ 

realization of cash flows over time. 
Included in net gains (losses) from trading activities in the income statement. 
Included in net gains (losses) from debt securities in the income statement. 
Included in mortgage banking and other noninterest income in the income statement. 

(5) 
(6) 
(7) 
(8)  For more information on the changes in mortgage servicing rights, see Note 10 (Mortgage Banking Activities). 
(9) 
(10)  Beginning balance includes $382 million of auction rate securities, which changed from the cost to fair value method of accounting in connection with our adoption of 

Included in mortgage banking, trading activities, equity securities and other noninterest income in the income statement. 

ASU 2016-01 in first quarter 2018. 

(11)  Included in net gains (losses) from equity securities in the income statement. 

(continued on following page) 

235

Wells Fargo & Company 

235 

 
  
 
Note 18:  Fair Values of Assets and Liabilities (continued) 

(continued from previous page) 

Table 18.4 presents gross purchases, sales, issuances and settlements related to the changes in Level 3 assets and liabilities 

measured at fair value on a recurring basis for the year ended December 31, 2018. 

Table 18.4:  Gross Purchases, Sales, Issuances and Settlements – Level 3 – 2018 

(in millions) 

Year ended December 31, 2018 

Trading debt securities: 

Purchases 

Sales 

Issuances 

Settlements 

Net 

Securities of U.S. states and political subdivisions

$

 —

Collateralized loan obligations 

Corporate debt securities 

Other trading debt securities 

Total trading debt securities 

Available-for-sale debt securities: 

Securities of U.S. states and political subdivisions 

Mortgage-backed securities: 

Residential 

Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other debt obligations 

Asset-backed securities: 

Other asset-backed securities 

Total asset-backed securities 

Total available-for-sale debt securities 

Mortgage loans held for sale 

Loans held for sale 

Loans 

Mortgage servicing rights (residential) (1) 

Net derivative assets and liabilities: 

Interest rate contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Other derivative contracts 

Total derivative contracts 

Equity securities: 

Marketable 

Nonmarketable 

Total equity securities 

Short sale liabilities 

Other liabilities 

408 

20 

— 

428 

— 

—

— 

— 

33 

61 

25 

25 

119 

87 

4 

8 

— 

— 

— 

3 

— 

12 

— 

15 

— 

— 

— 

— 

— 

 —

(348) 

(4) 

— 

(352) 

 —

— 

— 

— 

— 

 —

(161) 

— 

— 

(161) 

 —

(101) 

16 

— 

(85) 

(6) 

79 

(210) 

(137) 

 —

— 

— 

— 

(149) 

(12) 

(12) 

(167) 

(320) 

(40) 

— 

(71) 

— 

— 

(37) 

— 

(7) 

— 

(44) 

— 

(51) 

(51) 

— 

— 

 —

— 

— 

— 

— 

166 

166 

245 

353 

— 

17 

2,010 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

 (1)

(33) 

(34) 

(71) 

 (1)

(33) 

(34) 

(38) 

(209) 

(297) 

(350) 

(350) 

(874) 

(156) 

— 

(156) 

— 

351 

(11) 

556 

9 

(11) 

— 

894 

— 

(399) 

(399) 

— 

— 

(171) 

(171) 

(677) 

(36) 

(36) 

(131) 

1,939 

351 

(11) 

522 

9 

(6) 

— 

865 

— 

(450) 

(450) 

— 

— 

(1)  For more information on the changes in mortgage servicing rights, see Note 10 (Mortgage Banking Activities). 

236 

Wells Fargo & Company 

236

 
  
  
 
 
 
The changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the year ended December 31, 2017, 

are presented in Table 18.5. 

Table 18.5:  Changes in Level 3 Fair Value Assets and Liabilities on a Recurring Basis – 2017 

Total net gains 
(losses) included in 

Balance,
beginning
of period 

Net 
income 

Other 
compre-
hensive 
income 

Purchases,
sales, 
issuances 
and 
settlements, 
net (1) 

Transfers 
into 
Level 3  
(2) 

Transfers 
out of 
Level 3 
(3) 

Balance,
end of 
period 

Net unrealized 
gains (losses)
included in 
income related 
to assets and 
liabilities held 
at period end  (4) 

(in millions) 

Year ended December 31, 2017 

Trading debt securities: 

Securities of U.S. states and 

political subdivisions 

Collateralized loan obligations 

Corporate debt securities 

Other trading debt securities 

Total trading debt securities 

Available-for-sale debt securities: 

Securities of U.S. states and 

political subdivisions 

Mortgage-backed securities: 

Residential 

Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other 

debt obligations 

Asset-backed securities: 

Other asset-backed securities 

Total asset-backed securities 

$ 

3 

309 

34 

28 

374 

— 

3 

2 

(9) 

(4) 

1,140 

4 

1 

91 

92 

432 

879 

962 

962 

— 

(4) 

(4) 

(1) 

1 

1 

22 

(36) 

1 

(6) 

22 

103 

— 

— 

— 

— 

— 

5 

— 

— 

— 

23 

3 

3 

134 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

42 

(7) 

— 

35 

— 

— 

6 

— 

6 

— 

— 

(4) 

— 

(4) 

3 

354 

31 

19 

407 

1,105 

5 

(1,334) 

925 

— 

(12) 

(12) 

(47) 

16 

(400) 

(400) 

662 

(75) 

(3) 

(376) 

2,781 

(654) 

13 

(37) 

— 

(65) 

20 

— 

— 

— 

— 

— 

— 

— 

5 

134 

34 

— 

— 

— 

2 

(53) 

— 

— 

— 

(723) 

(51) 

— 

(2) 

(2) 

— 

— 

— 

1 

1 

— 

— 

— 

— 

— 

— 

— 

— 

— 

1 

75 

76 

407 

1,020 

566 

566 

(1,334) 

2,994 

998 

14 

376 

13,625 

71 

19 

(511) 

7 

36 

— 

(10) 

(18) 

— 

— 

— 

(2) 

45 

— 

— 

— 

43 

—

— 

— 

— 

— 

Total available-for-sale debt securities 

3,505 

Mortgage loans held for sale 

Loans held for sale 

Loans 

985 

— 

758 

Mortgage servicing rights (residential) (8) 

12,959 

(2,115) 

Net derivative assets and liabilities: 

Interest rate contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Other derivative contracts 

Total derivative contracts 

Equity securities: 

Marketable 

Nonmarketable 

Total equity securities 

Short sale liabilities 

Other liabilities 

121 

23 

604 

(17) 

(267) 

(199) 

12 

77 

(47) 

(81) 

—

3,259 

3,259 

— 

(4) 

(5) 

24 

27 

434 

—

1,563 

1,563 

— 

1 

— 

(13) 

2 

(4) 

(15)  (5) 

— 

— 

(11) 

(11) 

— 

— 

— 

— 

(11)  (6) 

(34)  (7) 

— 

(12)  (7) 

(126)  (7) 

(52) 

15 

(259) 

6 

(62) 

— 

(378) 

(352)  (9) 

— 

4,821 

4,821 

— 

(3) 

— 

1,569 

1,569  (10) 

—  (5) 

—  (7) 

(1)  See Table 18.6 for detail. 
(2)  All assets and liabilities transferred into level 3 were previously classified within level 2. 
(3)  All assets and liabilities transferred out of level 3 are classified as level 2. 
(4)  Represents only net gains (losses) that are due to changes in economic conditions and management’s estimates of fair value and excludes changes due to the collection/ 

realization of cash flows over time. 
Included in net gains (losses) from trading activities in the income statement. 
Included in net gains (losses) from debt securities in the income statement. 
Included in mortgage banking and other noninterest income in the income statement. 

(5) 
(6) 
(7) 
(8)  For more information on the changes in mortgage servicing rights, see Note 10 (Mortgage Banking Activities) 
(9) 
(10)  Included in net gains (losses) from equity securities in the income statement. 

Included in mortgage banking, trading activities, equity securities and other noninterest income in the income statement. 

(continued on following page) 

237

Wells Fargo & Company 

237 

 
  
Note 18:  Fair Values of Assets and Liabilities (continued) 

(continued from previous page) 

Table 18.6 presents gross purchases, sales, issuances and settlements related to the changes in Level 3 assets and liabilities 

measured at fair value on a recurring basis for the year ended December 31, 2017. 

Table 18.6:  Gross Purchases, Sales, Issuances and Settlements – Level 3 – 2017 

(in millions) 

Year ended December 31, 2017 

Trading debt securities: 

Securities of U.S. states and political subdivisions 

$ 

Collateralized loan obligations 

Corporate debt securities 

Other trading debt securities 

Total trading debt securities 

Available-for-sale debt securities: 

Securities of U.S. states and political subdivisions 

Mortgage-backed securities: 

Residential 

Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other debt obligations 

Asset-backed securities: 

Other asset-backed securities 

Total asset-backed securities 

Total available-for-sale debt securities 

Mortgage loans held for sale 

Loans held for sale 

Loans 

Mortgage servicing rights (residential) (1) 

Net derivative assets and liabilities: 

Interest rate contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Other derivative contracts 

Total derivative contracts 

Equity securities: 

Marketable 

Nonmarketable 

Total equity securities 

Short sale liabilities 

Other liabilities 

Purchases 

Sales 

Issuances 

Settlements 

Net 

37 

439 

25 

— 

501 

— 

— 

— 

— 

14 

135 

— 

— 

149 

79 

—

6 

541 

— 

— 

— 

— 

6 

— 

6 

— 

—

—

3

— 

(36) 

(250) 

(32) 

— 

(318) 

— 

— 

— 

— 

— 

(1) 

(147) 

— 

— 

(148) 

— 

42 

(7) 

— 

35 

(68) 

1,369 

(196) 

1,105 

— 

— 

— 

(4) 

— 

— 

— 

(72) 

(485) 

 (2)

(129) 

(24) 

— 

— 

(118) 

— 

(3) 

— 

(121) 

— 

 (2)

 (2)

 (3)

— 

— 

— 

— 

— 

— 

211 

211 

1,580 

489 

 —

19 

2,263 

— 

— 

— 

— 

— 

— 

— 

— 

 —

 —

 —

— 

— 

(12) 

(12) 

(57) 

(119) 

(611) 

(611) 

(995) 

(158) 

 (1)

(272) 

1 

— 

(12) 

(12) 

(47) 

16 

(400) 

(400) 

662 

(75) 

 (3)

(376) 

2,781 

(654) 

(654) 

13 

81 

— 

(68) 

20 

(608) 

— 

 —

 —

 —

— 

13 

(37) 

— 

(65) 

20 

(723) 

— 

 (2)

 (2)

 —

— 

(1)  For more information on the changes in mortgage servicing rights, see Note 10 (Mortgage Banking Activities). 

238 

Wells Fargo & Company 

238

 
  
 
 
 
 
The changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the year ended December 31, 2016, 

are presented in Table 18.7. 

Table 18.7:  Changes in Level 3 Fair Value Assets and Liabilities on a Recurring Basis – 2016 

Total net gains 
(losses) included in 

Balance,
beginning
of period 

Net 
income 

Other 
compre-
hensive 
income 

Purchases,
sales, 
issuances 
and 
settlements, 
net (1) 

Transfers 
into 
Level 3  
(2) 

Transfers 
out of 
Level 3  
(3) 

Balance,
end of 
period 

Net unrealized 
gains (losses)
included in 
income related 
to assets and 
liabilities held 
at period end  (4) 

(in millions) 

Year ended December 31, 2016 

Trading debt securities: 

Securities of U.S. states and 

political subdivisions 

Collateralized loan obligations 

Corporate debt securities 

Other trading debt securities 

Total trading debt securities 

Available-for-sale debt securities: 

Securities of U.S. states and 

political subdivisions 

Mortgage-backed securities: 

Residential 

Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other 

debt obligations 

Asset-backed securities: 

Other asset-backed securities 

Total asset-backed securities 

Total available-for-sale debt securities 

Mortgage loans held for sale 

Loans held for sale 

Loans 

$ 

8 

343 

56 

34 

441 

— 

(38) 

(7) 

(6) 

(51) 

— 

— 

— 

— 

— 

1,500 

6 

(25) 

1 

73 

74 

405 

565 

1,182 

1,182 

3,726 

1,082 

— 

5,316 

— 

— 

— 

21 

50 

2 

2 

79 

(19) 

— 

(59) 

Mortgage servicing rights (residential) (8) 

12,415 

(1,595) 

Net derivative assets and liabilities: 

Interest rate contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Other derivative contracts 

Total derivative contracts 

Equity securities: 

Marketable 

Nonmarketable 

Total equity securities 

Short sale liabilities 

Other liabilities 

288 

12 

(111) 

— 

(3) 

(58) 

128 

—

3,065 

3,065 

— 

(30) 

843 

10 

(80) 

(3) 

31 

11 

812 

— 

(30) 

(30) 

— 

1 

— 

1 

1 

35 

(1) 

(8) 

(8) 

2 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

(5) 

15 

(13) 

(1) 

(4) 

60 

— 

17 

17 

(29) 

265 

(214) 

(214) 

99 

(159) 

— 

(4,499) 

2,139 

(1,003) 

(2) 

(156) 

(1) 

49 

— 

(1,113) 

(1) 

224 

223 

— 

25 

— 

— 

— 

1 

1 

— 

(11) 

(2) 

— 

(13) 

3 

309 

34 

28 

374 

80 

(481) 

1,140 

— 

— 

— 

— 

— 

— 

— 

80 

98 

— 

— 

— 

— 

4 

21 

16 

— 

— 

41 

1

— 

1 

— 

— 

— 

— 

— 

— 

— 

— 

— 

1 

91 

92 

432 

879 

962 

962 

(481) 

3,505 

(17) 

— 

— 

— 

985 

— 

758 

12,959 

(7) 

(1) 

59 

— 

— 

— 

51 

— 

— 

— 

— 
— 

121 

23 

(267) 

12 

77 

(47) 

(81) 

— 

3,259 

3,259 

— 

(4) 

— 

(42) 

— 

1 

(41)  (5) 

— 

— 

(1) 

(1) 

(2) 

— 

(4) 

(4) 

(7)  (6) 

(24)  (7) 

— 

(24)  (7) 

565  (7) 

170 

11 

(176) 

(4) 

26 

11 

38  (9) 

— 

(30) 

(30)  (10) 

—  (5) 

—  (7) 

(1)  See Table 18.8 for detail. 
(2)  All assets and liabilities transferred into level 3 were previously classified within level 2. 
(3)  All assets and liabilities transferred out of level 3 are classified as level 2. 
(4)  Represents only net gains (losses) that are due to changes in economic conditions and management’s estimates of fair value and excludes changes due to the collection/ 

realization of cash flows over time. 
Included in net gains (losses) from trading activities in the income statement. 
Included in net gains (losses) from debt securities in the income statement. 
Included in mortgage banking and other noninterest income in the income statement. 

(5) 
(6) 
(7) 
(8)  For more information on the changes in mortgage servicing rights, see Note 10 (Mortgage Banking Activities). 
(9) 
(10)  Included in net gains (losses) from equity securities in the income statement. 

Included in mortgage banking, trading activities, equity securities and other noninterest income in the income statement. 

(continued on following page) 

239

Wells Fargo & Company 

239 

 
  
 
Note 18:  Fair Values of Assets and Liabilities (continued) 

(continued from previous page) 

Table 18.8 presents gross purchases, sales, issuances and settlements related to the changes in Level 3 assets and liabilities 

measured at fair value on a recurring basis for the year ended December 31, 2016. 

Table 18.8:  Gross Purchases, Sales, Issuances and Settlements – Level 3 – 2016 

Purchases 

Sales 

Issuances 

Settlements 

Net 

(in millions) 

Year ended December 31, 2016 

Trading debt securities: 

Securities of U.S. states and political subdivisions 

$ 

Collateralized loan obligations 

Corporate debt securities 

Other trading debt securities 

Total trading debt securities 

Available-for-sale debt securities: 

Securities of U.S. states and political subdivisions 

Mortgage-backed securities: 

Residential 

Commercial 

Total mortgage-backed securities 

Corporate debt securities 

Collateralized loan and other debt obligations 

Asset-backed securities: 

Other asset-backed securities 

Total asset-backed securities 

Total available-for-sale debt securities 

Mortgage loans held for sale 

Loans held for sale 

Loans 

Mortgage servicing rights (residential) (1) 

Net derivative assets and liabilities: 

Interest rate contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Other derivative contracts 

Total derivative contracts 

Equity securities: 

Marketable 

Nonmarketable 

Total equity securities 

Short sale liabilities 

Other liabilities 

2 

372 

37 

—

411 

28 

— 

22 

22 

36 

618 

50 

50 

754 

87 

— 

21 

— 

— 

—

29 

—

7

— 

36 

—

225 

225 

— 

— 

(2) 

(357) 

(50) 

 (1)

(410) 

— 

— 

— 

 —

— 

(5) 

— 

— 

 —

(5) 

(24) 

547 

(491) 

(5) 

15 

(13) 

 (1)

(4) 

60 

— 

17 

17 

(29) 

265 

(214) 

(214) 

99 

(159) 

— 

(4,499) 

2,139 

— 

(5) 

(5) 

(53) 

(299) 

(471) 

(471) 

(1,319) 

(193) 

— 

(1,031) 

1 

(1,003) 

(1,003) 

 (2)

(38) 

 (1)

 46

— 

 (2)

(156) 

 (1)

 49

— 

(998) 

(1,113) 

 —

(1) 

(1) 

— 

25 

 (1)

224 

223 

— 

25 

— 

— 

— 

(12) 

(54) 

(28) 

(28) 

(118) 

(618) 

— 

(3,791) 

(66) 

— 

 —

(147) 

 —

 (4) 

— 

(151) 

 (1)

— 

(1) 

— 

— 

— 

— 

— 

— 

— 

235 

235 

782 

565 

— 

302 

2,204 

— 

 —

— 

 —

—

— 

— 

 —

— 

— 

— 

— 

(1)  For more information on the changes in mortgage servicing rights, see Note 10 (Mortgage Banking Activities). 

Table 18.9 and Table 18.10 provide quantitative information 

In addition, the table excludes the valuation techniques and 

about the valuation techniques and significant unobservable 
inputs used in the valuation of substantially all of our Level 3 
assets and liabilities measured at fair value on a recurring basis 
for which we use an internal model. 

The significant unobservable inputs for Level 3 assets and 
liabilities that are valued using fair values obtained from third-
party vendors are not included in the table, as the specific inputs 
applied are not provided by the vendor (see discussion regarding 
vendor-developed valuations within the “Level 3 Asset and 
Liability Valuation Processes” section previously within this 
Note). 

significant unobservable inputs for certain classes of Level 3 
assets and liabilities measured using an internal model that we 
consider, both individually and in the aggregate, insignificant 
relative to our overall Level 3 assets and liabilities. We made this 
determination based upon an evaluation of each class, which 
considered the magnitude of the positions, nature of the 
unobservable inputs and potential for significant changes in fair 
value due to changes in those inputs. 

240 

Wells Fargo & Company 

240

  
 
 
 
 
 
Table 18.9:  Valuation Techniques – Recurring Basis – 2018 

($ in millions, except cost to service
amounts) 

Fair Value 
Level 3 

Valuation Technique(s) 

Significant
Unobservable Input 

Range of Inputs 

Weighted
Average (1) 

December 31, 2018 

Trading and available-for-sale debt
securities: 

Securities of U.S. states and 
political subdivisions: 

Government, healthcare and
other revenue bonds 

Collateralized loan and other debt 

obligations (2) 

Asset-backed securities: 

$ 

404 

Discounted cash flow 

Discount rate 

2.1  -

6.4  % 

3.4 

43 

298 

739 

Vendor priced 

Market comparable 
pricing 

Vendor priced 

Comparability
adjustment 

(13.5)  -

22.1 

3.2 

Diversified payment rights (3) 

171 

Discounted cash flow 

Other commercial and consumer 

198  (4) 

Discounted cash flow 

Discount rate 

Discount rate 

Weighted average life 

Mortgage loans held for sale (residential) 

20 

982 

Vendor priced 

Discounted cash flow 

Default rate 

3.4  -

4.6  -

1.1  -

0.0  -

1.1  -

0.0  -

3.2  -

6.2 

5.2 

1.5  yrs 

15.6  % 

6.6 

43.3 

13.4 

4.4 

4.7 

1.1 

0.8 

5.5 

23.4 

4.6 

(56.3)  -

(6.3) 

(36.3) 

3.4  -

2.9  -

0.0  -

62  -

7.1  -

9.0  -

6.4 

100.0 

34.8 

507 

15.3  % 

23.5 

Discount rate 

Loss severity 

Prepayment rate 

Comparability
adjustment 

Discount rate 

Prepayment rate 

Loss severity 

Cost to service per

loan (6)  $ 

Discount rate 

Prepayment rate (7) 

Default rate 

Loss severity 

Prepayment rate 

0.0  -

50.0  -

2.8  -

5.0 

50.0 

25.0 

4.2 

87.2 

10.2 

106 

8.1 

9.9 

2.0 

50.0 

13.8 

19.4 

18.5 

(7.8) 

1.8 

21.6 

21.8 

3.5 

1.3 

45.2 

Loans 

15 

Market comparable 
pricing 

244  (5) 

Discounted cash flow 

Mortgage servicing rights (residential) 

14,649 

Discounted cash flow 

Net derivative assets and (liabilities): 

Interest rate contracts 

(35) 

Discounted cash flow 

Interest rate contracts: derivative loan 

commitments 

60 

Discounted cash flow 

Fall-out factor 

1.0  -

99.0 

Initial-value 
servicing 

(36.6)  -

91.7  bps 

Equity contracts 

104 

Discounted cash flow 

Conversion factor 

(9.3)  -

0.0  % 

(121) 

Option model 

Correlation factor 

(77.0)  -

99.0  % 

Weighted average life 

1.0  -

3.0  yrs 

Volatility factor 

6.5  -

100.0 

Credit contracts 

3 

32 

Nonmarketable equity securities 

5,468 

Insignificant Level 3 assets, net of liabilities 

497  (8) 

Total level 3 assets, net of liabilities 

$  23,771  (9) 

Market comparable 
pricing 

Option model 

Market comparable 
pricing 

Comparability
adjustment 

Credit spread 

Loss severity 

Comparability
adjustment 

(15.5)  -

0.9  -

13.0  -

40.0 

21.5 

60.0 

(20.6)  -

(4.3) 

(15.8) 

(1)  Weighted averages are calculated using outstanding unpaid principal balance for cash instruments, such as loans and securities, and notional amounts for derivative 

instruments. 
Includes $800 million of collateralized debt obligations. 

(2) 
(3)  Securities backed by specified sources of current and future receivables generated from foreign originators. 
(4)  Predominantly consists of investments in asset-backed securities that are revolving in nature, for which the timing of advances and repayments of principal are uncertain. 
(5)  Consists of reverse mortgage loans. 
(6)  The high end of the range of inputs is for servicing modified loans. For non-modified loans the range is $62 - $204. 
(7) 

Includes a blend of prepayment speeds and expected defaults. Prepayment speeds are influenced by mortgage interest rates as well as our estimation of drivers of 
borrower behavior. 

(8)  Represents the aggregate amount of Level 3 assets and liabilities measured at fair value on a recurring basis that are individually and in the aggregate insignificant. The 
amount includes corporate debt securities, mortgage-backed securities, other trading positions, loans held for sale, other liabilities and certain net derivative assets and 
liabilities, such as commodity contracts and foreign exchange contracts. 

(9)  Consists of total Level 3 assets of $25.3 billion and total Level 3 liabilities of $1.6 billion, before netting of derivative balances. 

241

Wells Fargo & Company 

241 

  
Note 18:  Fair Values of Assets and Liabilities (continued) 

Table 18.10:  Valuation Techniques – Recurring Basis – 2017 

($ in millions, except cost to service amounts) 

December 31, 2017 

Trading and available-for-sale debt securities: 

Securities of U.S. states and 
political subdivisions: 

Government, healthcare and 
other revenue bonds 

Other municipal bonds 

Collateralized loan and other debt 

obligations (2) 

Asset-backed securities: 

Fair Value 
Level 3 

Valuation Technique(s) 

Significant
Unobservable Input 

Range of Inputs 

Weighted
Average (1) 

$ 

868 

11 

49 

354 

1,020 

Discounted cash flow 

Discounted cash flow 

Discount rate 

Discount rate 

1.7  -

4.7  -

5.8  % 

4.9 

2.7 

4.8 

Vendor priced 

Market comparable
pricing 

Vendor priced 

Comparability
adjustment 

(22.0)  -

19.5  % 

3.0 

Diversified payment rights (3) 

292 

Discounted cash flow 

Other commercial and consumer 

248 

(4) 

Discounted cash flow 

Mortgage loans held for sale (residential) 

26 

974 

24 

Vendor priced 

Discounted cash flow 

Market comparable
pricing 

Discount rate 

Discount rate 

Weighted average life 

Default rate 

Discount rate 

Loss severity 

Prepayment rate 

Comparability
adjustment 

2.4 

3.7 

2.0 

-

-

-

0.0  -

2.6  -

0.1  -

6.5  -

3.9 

5.2 

2.3  yrs 

7.1  % 

7.3 

41.4 

15.9 

3.1 

3.9 

2.1 

1.3 

5.6 

19.6 

9.1 

(56.3)  -

(6.3) 

(42.7) 

Loans 

376  (5) 

Discounted cash flow 

Discount rate 

3.1  -

7.5 

Prepayment rate 

8.7  -

100.0 

Loss severity 

0.0  -

33.9 

Mortgage servicing rights (residential) 

13,625 

Discounted cash flow 

Cost to service per
loan (6) 

Discount rate 

Prepayment rate (7) 

6.6  -

9.7  -

$ 

78  -

587 

Net derivative assets and (liabilities): 

Interest rate contracts 

54 

Discounted cash flow 

Default rate 

0.0  -

Loss severity 

50.0  -

Prepayment rate 

2.8  -

12.9  % 

20.5 

5.0 

50.0 

12.5 

Interest rate contracts: derivative loan 

commitments 

Equity contracts 

Credit contracts 

17 

102 

Discounted cash flow 

Fall-out factor 

1.0  -

99.0 

Discounted cash flow 

Conversion factor 

(9.7)  -

0.0  % 

Initial-value servicing 

(59.9)  -

101.1  bps 

(613) 

Option model 

Correlation factor 

(77.0)  -

98.0  % 

Weighted average life 

0.5  -

3.0  yrs 

(3) 

39 

Market comparable 
pricing 

Comparability 
adjustment 

(29.9)  -

Option model 

Credit spread 

0.0  -

Loss severity 

13.0  -

17.3 

63.7 

60.0 

Volatility factor 

5.7  -

95.5 

Nonmarketable equity securities 

8 

Discounted cash flow 

Discount rate 

10.0  -

10.0 

Volatility Factor 

0.5  -

1.9 

4.2 

91.9 

6.6 

143 

6.9 

10.5 

2.1 

50.0 

10.5 

15.2 

2.7 

(7.6) 

1.6 

24.2 

19.2 

(0.2) 

1.3 

50.7 

10.0 

1.4 

4,813 

Market comparable 
pricing 

Comparability 
adjustment 

(21.1)  -

(5.5) 

(15.0) 

Insignificant Level 3 assets, net of liabilities 

570  (8) 

Total level 3 assets, net of liabilities 

$  22,854  (9) 

(1)  Weighted averages are calculated using outstanding unpaid principal balance for cash instruments such as loans and securities, and notional amounts for derivative 

instruments. 
Includes $1.0 billion of collateralized debt obligations. 

(2) 
(3)  Securities backed by specified sources of current and future receivables generated from foreign originators. 
(4)  A significant portion of the balance consists of investments in asset-backed securities that are revolving in nature, for which the timing of advances and repayments of 

principal are uncertain. 

(5)  Consists of reverse mortgage loans. 
(6)  The high end of the range of inputs is for servicing modified loans. For non-modified loans the range is $78 - $252. 
(7) 

Includes a blend of prepayment speeds and expected defaults. Prepayment speeds are influenced by mortgage interest rates as well as our estimation of drivers of 
borrower behavior. 

(8)  Represents the aggregate amount of Level 3 assets and liabilities measured at fair value on a recurring basis that are individually and in the aggregate insignificant. The 

amount includes corporate debt securities, mortgage-backed securities, other trading positions, other liabilities and certain net derivative assets and liabilities, such as 
commodity contracts and foreign exchange contracts. 

(9)  Consists of total Level 3 assets of $24.9 billion and total Level 3 liabilities of $2.0 billion, before netting of derivative balances. 

242 

Wells Fargo & Company 

242

  
  
  
   
  
  
  
  
     
  
  
 
  
  
  
  
     
  
  
 
  
  
  
  
     
  
  
 
  
  
  
  
  
  
  
     
  
  
  
  
  
  
  
     
  
  
  
  
  
  
  
  
  
  
     
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
     
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
     
  
  
 
  
  
     
  
  
 
The valuation techniques used for our Level 3 assets and 

liabilities, as presented in the previous tables, are described as 
follows: 
•  Discounted cash flow – Discounted cash flow valuation 

techniques generally consist of developing an estimate of 
future cash flows that are expected to occur over the life of 
an instrument and then discounting those cash flows at a 
rate of return that results in the fair value amount. 
•  Market comparable pricing – Market comparable pricing 

valuation techniques are used to determine the fair value of 
certain instruments by incorporating known inputs, such as 
recent transaction prices, pending transactions, or prices of 
other similar investments that require significant 
adjustment to reflect differences in instrument 
characteristics. 

•  Option model – Option model valuation techniques are 
generally used for instruments in which the holder has a 
contingent right or obligation based on the occurrence of a 
future event, such as the price of a referenced asset going 
above or below a predetermined strike price. Option models 
estimate the likelihood of the specified event occurring by 
incorporating assumptions such as volatility estimates, price 
of the underlying instrument and expected rate of return. 
Vendor-priced – Prices obtained from third-party pricing 
vendors or brokers that are used to record the fair value of 
the asset or liability for which the related valuation 
technique and significant unobservable inputs are not 
provided. 

• 

Significant unobservable inputs presented in the previous 
tables are those we consider significant to the fair value of the 
Level 3 asset or liability. We consider unobservable inputs to be 
significant if by their exclusion the fair value of the Level 3 asset 
or liability would be impacted by a predetermined percentage 
change. We also consider qualitative factors, such as nature of 
the instrument, type of valuation technique used, and the 
significance of the unobservable inputs relative to other inputs 
used within the valuation. Following is a description of the 
significant unobservable inputs provided in the table. 
• 

Comparability adjustment – is an adjustment made to 
observed market data, such as a transaction price in order to 
reflect dissimilarities in underlying collateral, issuer, rating, 
or other factors used within a market valuation approach, 
expressed as a percentage of an observed price. 
Conversion Factor – is the risk-adjusted rate in which a 
particular instrument may be exchanged for another 
instrument upon settlement, expressed as a percentage 
change from a specified rate. 
Correlation factor – is the likelihood of one instrument 
changing in price relative to another based on an 
established relationship expressed as a percentage of 
relative change in price over a period over time. 

• 

• 

• 

• 

Cost to service – is the expected cost per loan of servicing a 
portfolio of loans, which includes estimates for 
unreimbursed expenses (including delinquency and 
foreclosure costs) that may occur as a result of servicing 
such loan portfolios. 
Credit spread – is the portion of the interest rate in excess of 
a benchmark interest rate, such as Overnight Index Swap 
(OIS), LIBOR or U.S. Treasury rates, that when applied to 
an investment captures changes in the obligor’s 
creditworthiness. 

•  Default rate – is an estimate of the likelihood of not 
collecting contractual amounts owed expressed as a 
constant default rate (CDR). 

•  Discount rate – is a rate of return used to calculate the 

present value of the future expected cash flow to arrive at 
the fair value of an instrument. The discount rate consists of 
a benchmark rate component and a risk premium 
component. The benchmark rate component, for example, 
OIS, LIBOR or U.S. Treasury rates, is generally observable 
within the market and is necessary to appropriately reflect 
the time value of money. The risk premium component 
reflects the amount of compensation market participants 
require due to the uncertainty inherent in the instruments’ 
cash flows resulting from risks such as credit and liquidity. 
Fall-out factor – is the expected percentage of loans 
associated with our interest rate lock commitment portfolio 
that are likely of not funding. 
Initial-value servicing – is the estimated value of the 
underlying loan, including the value attributable to the 
embedded servicing right, expressed in basis points of 
outstanding unpaid principal balance. 
Loss severity – is the estimated percentage of contractual 
cash flows lost in the event of a default. 
Prepayment rate – is the estimated rate at which forecasted 
prepayments of principal of the related loan or debt 
instrument are expected to occur, expressed as a constant 
prepayment rate (CPR). 
Volatility factor – is the extent of change in price an item is 
estimated to fluctuate over a specified period of time 
expressed as a percentage of relative change in price over a 
period over time. 

• 

• 

• 

• 

• 

•  Weighted average life – is the weighted average number of 
years an investment is expected to remain outstanding 
based on its expected cash flows reflecting the estimated 
date the issuer will call or extend the maturity of the 
instrument or otherwise reflecting an estimate of the timing 
of an instrument’s cash flows whose timing is not 
contractually fixed. 

243

Wells Fargo & Company 

243 

 
 
Note 18:  Fair Values of Assets and Liabilities (continued) 

Significant Recurring Level 3 Fair Value Asset and 
Liability Input Sensitivity 
We generally use discounted cash flow or similar internal 
modeling techniques to determine the fair value of our Level 3 
assets and liabilities. Use of these techniques requires 
determination of relevant inputs and assumptions, some of 
which represent significant unobservable inputs as indicated in 
the preceding tables. Accordingly, changes in these unobservable 
inputs may have a significant impact on fair value. 

Certain of these unobservable inputs will (in isolation) have 

a directionally consistent impact on the fair value of the 
instrument for a given change in that input. Alternatively, the 
fair value of the instrument may move in an opposite direction 
for a given change in another input. Where multiple inputs are 
used within the valuation technique of an asset or liability, a 
change in one input in a certain direction may be offset by an 
opposite change in another input having a potentially muted 
impact to the overall fair value of that particular instrument. 
Additionally, a change in one unobservable input may result in a 
change to another unobservable input (that is, changes in certain 
inputs are interrelated to one another), which may counteract or 
magnify the fair value impact. 

SECURITIES, LOANS, MORTGAGE LOANS HELD FOR SALE 
and NONMARKETABLE EQUITY INVESTMENTS  The fair 
values of predominantly all Level 3 trading securities, mortgage 
loans held for sale, loans, other nonmarketable equity 
investments, and available-for-sale securities have consistent 
inputs, valuation techniques and correlation to changes in 
underlying inputs. The internal models used to determine fair 
value for these Level 3 instruments use certain significant 
unobservable inputs within a discounted cash flow or market 
comparable pricing valuation technique. Such inputs include 
discount rate, prepayment rate, default rate, loss severity, 
comparability adjustment and weighted average life. 

These Level 3 assets would decrease (increase) in value 
based upon an increase (decrease) in discount rate, default rate, 
loss severity, or weighted average life inputs and would generally 
decrease (increase) in value based upon an increase (decrease) in 
prepayment rate. Generally, a change in the assumption used for 
default rate is accompanied by a directionally similar change in 
the risk premium component of the discount rate (specifically, 
the portion related to credit risk) and a directionally opposite 
change in the assumption used for prepayment rates. The 
comparability adjustment input may have a positive or negative 
impact on fair value depending on the change in fair value the 
comparability adjustment references. Unobservable inputs for 
comparability adjustment, loss severity, and weighted average 
life do not increase or decrease based on movements in the other 
significant unobservable inputs for these Level 3 assets. 

DERIVATIVE INSTRUMENTS  Level 3 derivative instruments 
are valued using market comparable pricing, option pricing and 
discounted cash flow valuation techniques. We utilize certain 
unobservable inputs within these techniques to determine the 
fair value of the Level 3 derivative instruments. The significant 
unobservable inputs consist of credit spread, a comparability 
adjustment, prepayment rate, default rate, loss severity, initial-
value servicing, fall-out factor, volatility factor, weighted average 
life, conversion factor, and correlation factor. 

Level 3 derivative assets (liabilities) where we are long the 
underlying would decrease (increase) in value upon an increase 
(decrease) in default rate, fall-out factor, credit spread, 
conversion factor, or loss severity inputs. Conversely, Level 3 
derivative assets (liabilities) would generally increase (decrease) 
in value upon an increase (decrease) in prepayment rate, initial-
value servicing, weighted average life, or volatility factor inputs. 
The inverse of the above relationships would occur for 
instruments in which we are short the underlying. The 
correlation factor and comparability adjustment inputs may 
have a positive or negative impact on the fair value of these 
derivative instruments depending on the change in value of the 
item the correlation factor and comparability adjustment is 
referencing. The correlation factor and comparability 
adjustment are considered independent from movements in 
other significant unobservable inputs for derivative instruments. 
Generally, for derivative instruments for which we are 
subject to changes in the value of the underlying referenced 
instrument, a change in the assumption used for default rate is 
accompanied by directionally similar change in the risk premium 
component of the discount rate (specifically, the portion related 
to credit risk) and a directionally opposite change in the 
assumption used for prepayment rates. Unobservable inputs for 
loss severity, fall-out factor, initial-value servicing, weighted 
average life, conversion factor, and volatility do not increase or 
decrease based on movements in other significant unobservable 
inputs for these Level 3 instruments. 

MORTGAGE SERVICING RIGHTS  We use a discounted cash 
flow valuation technique to determine the fair value of Level 3 
mortgage servicing rights. These models utilize certain 
significant unobservable inputs including prepayment rate, 
discount rate and costs to service. An increase in any of these 
unobservable inputs will reduce the fair value of the mortgage 
servicing rights and alternatively, a decrease in any one of these 
inputs would result in the mortgage servicing rights increasing in 
value. Generally, a change in the assumption used for the default 
rate is accompanied by a directionally similar change in the 
assumption used for cost to service and a directionally opposite 
change in the assumption used for prepayment. The sensitivity 
of our residential MSRs is discussed further in Note 9 
(Securitizations and Variable Interest Entities). 

244 

Wells Fargo & Company 

244

 
 
 
 
 
Assets and Liabilities Recorded at Fair Value on a 
Nonrecurring Basis 
We may be required, from time to time, to measure certain 
assets at fair value on a nonrecurring basis in accordance with 
GAAP. These adjustments to fair value usually result from 
application of LOCOM accounting, write-downs of individual 
assets or commencing in 2018 with our adoption of 

Table 18.12:  Fair Value on a Nonrecurring Basis 

ASU 2016-01, use of the measurement alternative for 
nonmarketable equity securities. Table 18.12 provides the fair 
value hierarchy and fair value at the date of the nonrecurring fair 
value adjustment for all assets that were still held as of 
December 31, 2018 and 2017, and for which a nonrecurring fair 
value adjustment was recorded during the years then ended. 

(in millions) 

Level 1 

Level 2 

Level 3 

Total 

Level 1 

Level 2 

Level 3 

Total 

December 31, 2018 

December 31, 2017 

Mortgage loans held for sale (LOCOM) (1) 

$ 

Loans held for sale 

Loans: 

Commercial 

Consumer 

Total loans (2) 

Nonmarketable equity securities (3) 

Other assets (4) 

Total assets at fair value on a nonrecurring

basis (5) 

$ 

— 

— 

— 

— 

— 

— 

— 

— 

1,213 

1,233 

2,446 

313 

339 

346 

685 

774 

149 

— 

— 

1 

1 

157 

6 

313 

339 

347 

686 

931 

155 

3,134 

1,397 

4,531 

— 

— 

— 

— 

— 

— 

— 

— 

1,646 

1,333 

2,979 

108 

— 

108 

374 

502 

876 

— 

177 

— 

10 

10 

136 

161 

374 

512 

886 

136 

338 

2,807 

1,640 

4,447 

(1)  Consists of commercial mortgages and residential real estate 1-4 family first mortgage loans. 
(2)  Represents the carrying value of loans for which nonrecurring adjustments are based on the appraised value of the collateral. 
(3)  Consists of certain nonmarketable equity securities that are measured at fair value on a nonrecurring basis, including observable price adjustments for nonmarketable 

equity securities carried under the measurement alternative. 
Includes the fair value of foreclosed real estate, other collateral owned and operating lease assets. 

(4) 
(5)  Prior period balances exclude $6 million of nonmarketable equity securities at NAV. 

Table 18.13 presents the increase (decrease) in value of 
certain assets held at the end of the respective reporting periods 
presented for which a nonrecurring fair value adjustment was 
recognized during the periods presented. 

Table 18.13:  Change in Value of Assets with Nonrecurring Fair 
Value Adjustment 

(in millions) 

Mortgage loans held for sale (LOCOM) 

$

Loans held for sale 

Loans: 

Commercial 

Consumer 

Total loans (1) 

Nonmarketable equity securities (2) 

Other assets (3) 

Total 

Year ended December 31, 

2018 

2017 

21

(39) 

(221) 

(284) 

(505) 

265 

(40) 

10 

(2) 

(335) 

(424) 

(759) 

(178) 

(121) 

$ 

(298) 

(1,050) 

(1)  Represents write-downs of loans based on the appraised value of the 

(2) 

(3) 

collateral. 
Includes impairment losses and observable price adjustments for certain 
nonmarketable equity securities. 
Includes the losses on foreclosed real estate and other collateral owned that 
were measured at fair value subsequent to their initial classification as 
foreclosed assets. 

245

Wells Fargo & Company 

245 

 
  
 
  
 
 
 
Note 18:  Fair Values of Assets and Liabilities (continued) 

Table 18.14 provides quantitative information about the 
valuation techniques and significant unobservable inputs used in 
the valuation of substantially all of our Level 3 assets that are 
measured at fair value on a nonrecurring basis using an internal 
model. The table is limited to financial instruments that had 
nonrecurring fair value adjustments during the periods 
presented. 

We have excluded from the table valuation techniques and 

significant unobservable inputs for certain classes of Level 3 

Table 18.14:  Valuation Techniques – Nonrecurring Basis 

assets measured using an internal model that we consider, both 
individually and in the aggregate, insignificant relative to our 
overall Level 3 nonrecurring measurements. We made this 
determination based upon an evaluation of each class that 
considered the magnitude of the positions, nature of the 
unobservable inputs and potential for significant changes in fair 
value due to changes in those inputs. 

4.0 

1.7 

46.5 

10.5 

1.7 % 

3.8 

2.2 

50.6 

10.2 

($ in millions) 

December 31, 2018 

Residential mortgage loans held

for sale (LOCOM) 

Nonmarketable equity securities 

Insignificant level 3 assets 

Total 

December 31, 2017 

Residential mortgage loans held for

sale (LOCOM) 

Fair Value 
Level 3 

Valuation Technique(s) (1) 

Significant
Unobservable 
Inputs (1) 

Range of inputs 

Weighted 
Average (2) 

$  1,233  (3) 

Discounted cash flow 

Default rate  (4) 

0.2  – 

2.3% 

1.4% 

Discount rate 

1.5  – 

8.5 

Loss severity 

0.5  – 

66.0 

Prepayment rate  (5) 

3.5  –  100.0 

Discounted cash flow 

Discount rate 

10.5  – 

10.5 

7 

157 

$  1,397 

$ 

1,333  (3) 

Discounted cash flow 

Default rate  (4) 

Discount rate 

0.1  – 

1.5  – 

4.1 % 

8.5 

Nonmarketable equity securities 

Insignificant level 3 assets 

Total 

122 

185 

$ 

1,640 

Loss severity 

0.7  – 

52.9 

Prepayment rate  (5) 

5.4  – 

100.0 

Discounted cash flow 

Discount rate 

5.0  – 

10.5 

(1)  Refer to the narrative following Table 18.10 for a definition of the valuation technique(s) and significant unobservable inputs. 
(2)  For residential MLHFS, weighted averages are calculated using the outstanding unpaid principal balance of the loans. 
(3)  Consists of approximately $1.2 billion and $1.3 billion of government insured/guaranteed loans purchased from GNMA-guaranteed mortgage securitizations at  

December 31, 2018 and 2017, respectively, and $27 million and $26 million of other mortgage loans that are not government insured/guaranteed at December 31, 2018 
and 2017, respectively. 

(4)  Applies only to non-government insured/guaranteed loans. 
(5) 

Includes the impact on prepayment rate of expected defaults for government insured/guaranteed loans, which impact the frequency and timing of early resolution of loans. 

Fair Value Option 
The fair value option is an irrevocable election, generally only 
permitted upon initial recognition of financial assets or 
liabilities, to measure eligible financial instruments at fair value 
with changes in fair value reflected in earnings. We may elect the 
fair value option to align the measurement model with how the 
financial assets or liabilities are managed or to reduce 
complexity or accounting asymmetry. Following is a discussion 
of the portfolios for which we elected the fair value option. 

MORTGAGE LOANS HELD FOR SALE (MLHFS)  We measure 
MLHFS at fair value for MLHFS originations for which an active 
secondary market and readily available market prices exist to 
reliably support fair value pricing models used for these loans. 
Loan origination fees on these loans are recorded when earned, 
and related direct loan origination costs are recognized when 
incurred. We also measure at fair value certain of our other 
interests held related to residential loan sales and 
securitizations. We believe fair value measurement for MLHFS 
and other interests held, which we hedge with economic hedge 
derivatives along with our MSRs measured at fair value, reduces 
certain timing differences and better matches changes in the 

value of these assets with changes in the value of derivatives 
used as economic hedges for these assets. 

LOANS HELD FOR SALE (LHFS)  We engage in holding loans 
for market-making purposes to support the buying and selling 
demands of our customers. These loans are generally held for a 
short period of time and managed within parameters of 
internally approved market risk limits. We have elected to 
measure and carry them at fair value, which best aligns with our 
risk management practices. Fair value for these loans is 
generally determined using readily available market data based 
on recent transaction prices for similar loans. 

LOANS  Loans that we measure at fair value consist 
predominantly of reverse mortgage loans previously transferred 
under a GNMA reverse mortgage securitization program 
accounted for as a secured borrowing. Before the transfer, they 
were classified as MLHFS measured at fair value and, as such, 
remain carried on our balance sheet under the fair value option. 

EQUITY SECURITIES  We elected to measure at fair value 
certain nonmarketable equity securities that are hedged with 
derivative instruments to better reflect the economics of the 
transactions. 

246 

Wells Fargo & Company 

246

  
 
Table 18.15 reflects differences between the fair value 
carrying amount of the assets for which we have elected the fair 
value option and the contractual aggregate unpaid principal 
amount at maturity. 

Table 18.15:  Fair Value Option 

(in millions) 

Mortgage loans held for sale: 

Total loans 

Nonaccrual loans 

Loans 90 days or more past due and still accruing 

Loans held for sale: 

Total loans 

Nonaccrual loans 

Loans: 

Total loans 

Nonaccrual loans 

Equity securities (1) 

December 31, 2018 

December 31, 2017 

Fair value 
carrying 
amount 

Aggregate
unpaid
principal 

$  11,771 

11,573 

127 

7 

158 

9 

1,469 

1,536 

21 

32 

244 

179 

5,455 

274 

208 

N/A 

Fair value 
carrying
amount less 
aggregate
unpaid
principal 

Fair value 
carrying 
amount 

Aggregate
unpaid
principal 

Fair value 
carrying
amount less 
aggregate
unpaid
principal 

198 

(31) 

(2) 

(67) 

(11) 

(30) 

(29) 

N/A 

16,116 

15,827 

127 

16 

165 

21 

1,023 

1,075 

34 

56 

376 

253 

4,867 

404 

281 

N/A 

289 

(38) 

(5) 

(52) 

(22) 

(28) 

(28) 

N/A 

(1)  Consists of nonmarketable equity securities carried at fair value. 

The assets accounted for under the fair value option are 
initially measured at fair value. Gains and losses from initial 
measurement and subsequent changes in fair value are 
recognized in earnings. The changes in fair value related to 

initial measurement and subsequent changes in fair value 
included in earnings for these assets measured at fair value are 
shown in Table 18.16 by income statement line item. Amounts 
recorded as interest income are excluded from Table 18.16. 

Table 18.16:  Fair Value Option – Changes in Fair Value Included in Earnings 

2018 

2017 

Year ended December 31, 

2016 

(in millions) 

Mortgage loans
held for sale 

Loans held for sale 

Loans 

Equity securities 

Other interests 
held (1) 

Mortgage
banking
noninterest 
income 

$ 

462 

— 

—

— 

— 

Net 
gains
(losses)
from 
trading
activities 

Net gains
(losses)
from 
equity
securities 

Other 
noninterest 
income 

Mortgage
banking
noninterest 
income 

Net 
gains
(losses)
from 
trading
activities 

Net gains
(losses)
from 
equity
securities 

Other 
noninterest 
income 

Mortgage
banking
noninterest 
income 

Net 
gains
(losses)
from 
trading
activities 

Net gains
(losses)
from 
equity
securities 

Other 
noninterest 
income 

— 

(1)

 —

— 

(3)

— 

 — 

 —

683 

 — 

— 

1 

  (1)

— 

— 

1,229 

—

  —

— 

—

— 

 45

 —

— 

 (9)

— 

  —

 —

1,592 

— 

2

  —

— 

1,456 

—

  —

— 

 —

  —

  —

— 

 55

 —

— 

 (5)

— 

  —

 —

(12) 

— 

3

  (60)

— 

 —

  —

(1) 

Includes retained interests in securitizations. 

For performing loans, instrument-specific credit risk gains 
or losses were derived principally by determining the change in 
fair value of the loans due to changes in the observable or 
implied credit spread. Credit spread is the market yield on the 
loans less the relevant risk-free benchmark interest rate. For 
nonperforming loans, we attribute all changes in fair value to 
instrument-specific credit risk. Table 18.17 shows the estimated 
gains and losses from earnings attributable to instrument-
specific credit risk related to assets accounted for under the fair 
value option. 

Table 18.17:  Fair Value Option – Gains/Losses Attributable to 
Instrument-Specific Credit Risk 

(in millions) 

2018 

2017 

2016 

Year ended December 31, 

Gains (losses) attributable to

instrument-specific credit risk: 

Mortgage loans held for sale  $ 

(16)

  (12) 

Loans held for sale 

Total 

— 

$ 

(16)

45 

33 

3 

55 

58 

247

Wells Fargo & Company 

247 

 
  
 
  
  
  
 
 
 
 
 
 
 
Note 18:  Fair Values of Assets and Liabilities (continued) 

Disclosures about Fair Value of Financial 
Instruments 
Table 18.18 is a summary of fair value estimates for financial 
instruments, excluding financial instruments recorded at fair 
value on a recurring basis, as they are included within Table 18.2 
in this Note. In connection with our adoption of ASU 2016-01 in 
first quarter 2018, the valuation methodologies for estimating 
the fair value of financial instruments in Table 18.18 have been 
changed, where necessary, to conform with an exit price notion. 
Under an exit price notion, fair value estimates are based upon 
the price that would be received to sell an asset or paid to 
transfer a liability in an orderly transaction between market 
participants at the balance sheet date. For certain loans and 
deposit liabilities, the estimated fair values prior to our adoption 

Table 18.18:  Fair Value Estimates for Financial Instruments 

(in millions) 

December 31, 2018 

Financial assets 

of ASU 2016-01 followed an entrance price notion that based fair 
values on recent prices offered to customers for loans and 
deposits with similar characteristics. The carrying amounts in 
the following table are recorded on the balance sheet under the 
indicated captions. 

We have not included assets and liabilities that are not 
financial instruments in our disclosure, such as the value of the 
long-term relationships with our deposit, credit card and trust 
customers, amortized MSRs, premises and equipment, goodwill 
and other intangibles, deferred taxes and other liabilities.

 The total of the fair value calculations presented does not 

represent, and should not be construed to represent, the 
underlying value of the Company. 

Carrying
amount 

Level 1 

Level 2 

Level 3 

Total 

Estimated fair value 

Cash and due from banks (1) 

Interest-earning deposits with banks (1) 

Federal funds sold and securities purchased under resale

agreements (1) 

Held-to-maturity debt securities 

Mortgage loans held for sale 

Loans held for sale 

Loans, net (2)(3) 

Nonmarketable equity securities (cost method) (4) 

$ 

23,551 

23,551 

149,736 

149,542 

80,207 

— 

144,788 

44,339 

3,355 

572 

923,703 

5,643 

— 

— 

— 

— 

— 

194 

80,207 

97,275 

2,129 

572 

— 

— 

— 

23,551 

149,736 

80,207 

501 

142,115 

1,233 

— 

3,362 

572 

45,190 

872,725 

917,915 

— 

5,675 

5,675 

Total financial assets 

$  1,331,555 

217,432 

225,567 

880,134 

1,323,133 

Financial liabilities 

Deposits (3)(5) 

Short-term borrowings 

Long-term debt (6) 

Total financial liabilities 

December 31, 2017 

Financial assets 

$  130,645 

105,787 

229,008 

$  465,440 

— 

— 

— 

— 

107,448 

22,641 

130,089 

105,789 

225,904 

— 

105,789 

2,230 

228,134 

439,141 

24,871 

464,012 

Cash and due from banks (1) 

Interest-earning deposits with banks (1) 

Federal funds sold and securities purchased under resale

agreements (1) 

Held-to-maturity debt securities 

Mortgage loans held for sale 

Loans held for sale 

Loans, net (2)(3) 

Nonmarketable equity securities (cost method) 

$ 

23,367 

23,367 

192,580 

192,455 

80,025 

139,335 

3,954 

108 

926,273 

7,136 

1,002 

44,806 

— 

— 

— 

—

— 

125 

78,954 

93,694 

2,625 

108 

— 

— 

69 

485 

1,333 

— 

23,367 

192,580 

80,025 

138,985 

3,958 

108 

51,713 

886,622 

938,335 

 23

 7,605 

7,628 

Total financial assets (7) 

$  1,372,778 

261,630 

227,242 

896,114 

1,384,986 

Financial liabilities 

Deposits (3)(5) 

Short-term borrowings 

Long-term debt (6) 

Total financial liabilities 

$ 

128,594 

103,256 

224,981 

$ 

456,831 

— 

— 

— 

— 

108,146 

103,256 

227,109 

438,511 

19,768 

127,914 

— 

103,256 

3,159 

22,927 

230,268 

461,438 

(1)  Amounts consist of financial instruments for which carrying value approximates fair value. 
(2)  Excludes lease financing with a carrying amount of $19.7 billion and $19.4 billion at December 31, 2018 and 2017, respectively. 
(3) 

In connection with our adoption of ASU 2016-01, the valuation methodologies used to estimate the fair value at December 31, 2018, for a portion of loans and deposit 
liabilities with a defined or contractual maturity has been changed to conform to an exit price notion. The fair value estimates at December 31, 2017 have not been revised 
to reflect application of the modified methodology. 

(4)  Excludes $1.7 billion of nonmarketable equity securities accounted for under the measurement alternative at December 31, 2018, that were accounted for under the cost 

method in prior periods. 

(5)  Excludes deposit liabilities with no defined or contractual maturity of $1.2 trillion at both December 31, 2018 and 2017. 
(6)  Excludes capital lease obligations under capital leases of $36 million and $39 million at December 31, 2018 and 2017, respectively. 
(7)  Excludes $27 million of carrying value and $30 million of fair value relating to nonmarketable equity securities at NAV at December 31, 2017. 

248 

Wells Fargo & Company 

248

  
 
 
Loan commitments, standby letters of credit and 

commercial and similar letters of credit are not included in Table 
18.18. A reasonable estimate of the fair value of these 
instruments is the carrying value of deferred fees plus the 
allowance for unfunded credit commitments, which totaled 
$1.0 billion at both December 31, 2018 and 2017. 

Note 19:  Preferred Stock 

We are authorized to issue 20 million shares of preferred stock 
and 4 million shares of preference stock, both without par value. 
Preferred shares outstanding rank senior to common shares 
both as to dividends and liquidation preference but have no 
general voting rights. We have not issued any preference shares 

under this authorization. If issued, preference shares would be 
limited to one vote per share. Our total authorized, issued and 
outstanding preferred stock is presented in the following two 
tables along with the Employee Stock Ownership Plan (ESOP) 
Cumulative Convertible Preferred Stock. 

Table 19.1:  Preferred Stock Shares 

December 31, 2018 

December 31, 2017 

Liquidation 
preference 
per share 

Shares 
authorized 
and 
designated 

Liquidation 
preference 
per share 

Shares 
 authorized 
and 
designated 

DEP Shares 

Dividend Equalization Preferred Shares (DEP) 

$ 

10 

97,000 

$ 

10 

97,000 

Series I 

Floating Class A Preferred Stock (1) 

Series J 

100,000 

25,010 

100,000 

25,010 

8.00% Non-Cumulative Perpetual Class A Preferred Stock (2) 

—

— 

1,000 

2,300,000 

Series K 

Floating Non-Cumulative Perpetual Class A Preferred Stock (3) 

1,000 

3,500,000 

1,000 

3,500,000 

Series L 

7.50% Non-Cumulative Perpetual Convertible Class A Preferred Stock 

1,000 

4,025,000 

1,000 

4,025,000 

Series N 

5.20% Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

30,000 

25,000 

30,000 

Series O 

5.125% Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

27,600 

25,000 

27,600 

Series P 

5.25% Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

26,400 

25,000 

26,400 

Series Q 

5.85% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

69,000 

25,000 

69,000 

Series R 

6.625% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

34,500 

25,000 

34,500 

Series S 

5.90% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

80,000 

25,000 

80,000 

Series T 

6.00% Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

32,200 

25,000 

32,200 

Series U 

5.875% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

80,000 

25,000 

80,000 

Series V 

6.00% Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

40,000 

25,000 

40,000 

Series W 

5.70% Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

40,000 

25,000 

40,000 

Series X 

5.50% Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

46,000 

25,000 

46,000 

Series Y 

5.625% Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

27,600 

25,000 

27,600 

ESOP 

Cumulative Convertible Preferred Stock (4) 

Total 

— 

1,406,460 

— 

1,556,104 

9,586,770 

12,036,414 

(1)  Floating rate for Preferred Stock, Series I, is the greater of three-month LIBOR plus 0.93% and 5.56975%. 
(2)  Preferred Stock, Series J, was redeemed in third quarter 2018. 
(3)  Effective June 15, 2018, Preferred Stock, Series K, converted from a fixed to a floating coupon rate of three-month LIBOR plus 3.77%. 
(4)  See the ESOP Cumulative Convertible Preferred Stock section in this Note for additional information about the liquidation preference for the ESOP Cumulative Convertible 

Preferred Stock. 

249

Wells Fargo & Company 

249 

  
 
Note 19:  Preferred Stock (continued) 

Table 19.2:  Preferred Stock – Shares Issued and Carrying Value 

(in millions, except shares) 

DEP Shares 

December 31, 2018 

December 31, 2017 

Shares 
issued and 
outstanding 

Liquidation
preference
value 

Carrying

value  Discount 

Shares 
issued and 
outstanding 

Liquidation
preference
value 

Carrying
value 

Discount 

Dividend Equalization Preferred Shares (DEP) 

96,546  $ 

— 

— 

Series I (1)(2) 

Floating Class A Preferred Stock 

25,010 

2,501 

2,501 

Series J (1)(3) 

8.00% Non-Cumulative Perpetual Class A Preferred Stock 

— 

— 

— 

Series K (1)(4) 

— 

— 

— 

96,546 

$ 

— 

— 

25,010 

2,501 

2,501 

— 

— 

2,150,375 

2,150 

1,995 

155 

Floating Non-Cumulative Perpetual Class A Preferred Stock 

3,352,000 

3,352 

2,876 

476 

3,352,000 

3,352 

2,876 

476 

Series L (1) 

7.50% Non-Cumulative Perpetual Convertible Class A

Preferred Stock 

Series N (1) 

3,968,000 

3,968 

3,200 

768 

3,968,000 

3,968 

3,200 

768 

5.20% Non-Cumulative Perpetual Class A Preferred Stock 

30,000 

750 

750 

Series O (1) 

5.125% Non-Cumulative Perpetual Class A Preferred Stock 

26,000 

650 

650 

Series P (1) 

5.25% Non-Cumulative Perpetual Class A Preferred Stock 

25,000 

625 

625 

Series Q (1) 

5.85% Fixed-to-Floating Non-Cumulative Perpetual Class A

Preferred Stock 

Series R (1) 

6.625% Fixed-to-Floating Non-Cumulative Perpetual Class A

Preferred Stock 

Series S (1) 

5.90% Fixed-to-Floating Non-Cumulative Perpetual Class A

Preferred Stock 

Series T (1) 

69,000 

1,725 

1,725 

33,600 

840 

840 

80,000 

2,000 

2,000 

6.00% Non-Cumulative Perpetual Class A Preferred Stock 

32,000 

800 

800 

Series U (1) 

5.875% Fixed-to-Floating Non-Cumulative Perpetual Class A

Preferred Stock 

Series V (1) 

80,000 

2,000 

2,000 

6.00% Non-Cumulative Perpetual Class A Preferred Stock 

40,000 

1,000 

1,000 

Series W (1) 

5.70% Non-Cumulative Perpetual Class A Preferred Stock 

40,000 

1,000 

1,000 

Series X (1) 

5.50% Non-Cumulative Perpetual Class A Preferred Stock 

46,000 

1,150 

1,150 

Series Y (1) 

5.625% Non-Cumulative Perpetual Class A Preferred Stock 

27,600 

690 

690 

ESOP 

Cumulative Convertible Preferred Stock 

1,406,460 

1,407 

1,407 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

30,000 

750 

750 

26,000 

650 

650 

25,000 

625 

625 

69,000 

1,725 

1,725 

33,600 

840 

840 

80,000 

2,000 

2,000 

32,000 

800 

800 

80,000 

2,000 

2,000 

40,000 

1,000 

1,000 

40,000 

1,000 

1,000 

46,000 

1,150 

1,150 

27,600 

690 

690 

1,556,104 

1,556 

1,556 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

Total 

9,377,216  $  24,458 

23,214 

1,244 

11,677,235 

$  26,757 

25,358 

1,399 

(1)  Preferred shares qualify as Tier 1 capital. 
(2)  Floating rate for Preferred Stock, Series I, is the greater of three-month LIBOR plus 0.93% and 5.56975%. 
(3)  Preferred Stock, Series J, was redeemed in third quarter 2018. 
(4)  Effective June 15, 2018, Preferred Stock, Series K, converted from a fixed to a floating coupon rate of three-month LIBOR plus 3.77%. 

See Note 9 (Securitizations and Variable Interest Entities) 

for additional information on our trust preferred securities. 

250 

Wells Fargo & Company 

250

  
 
ESOP CUMULATIVE CONVERTIBLE PREFERRED STOCK  All 
shares of our ESOP Cumulative Convertible Preferred Stock 
(ESOP Preferred Stock) were issued to a trustee acting on behalf 
of the Wells Fargo & Company 401(k) Plan (the 401(k) Plan). 
Dividends on the ESOP Preferred Stock are cumulative from the 
date of initial issuance and are payable quarterly at annual rates 
based upon the year of issuance. Each share of ESOP Preferred 
Stock released from the unallocated reserve of the 401(k) Plan is 
converted into shares of our common stock based on the stated 
value of the ESOP Preferred Stock and the then current market 

Table 19.3:  ESOP Preferred Stock 

price of our common stock. The ESOP Preferred Stock is also 
convertible at the option of the holder at any time, unless 
previously redeemed. We have the option to redeem the ESOP 
Preferred Stock at any time, in whole or in part, at a redemption 
price per share equal to the higher of (a) $1,000 per share plus 
accrued and unpaid dividends or (b) the fair market value, as 
defined in the Certificates of Designation for the ESOP Preferred 
Stock. 

(in millions, except shares) 

ESOP Preferred Stock 

$1,000 liquidation preference per share 

2018 

2017 

2016 

2015 

2014 

2013 

2012 

2011 

2010 

Shares issued and outstanding 

Carrying value 

Adjustable dividend rate 

Dec 31, 

2018 

336,945 

222,210 

233,835 

144,338 

174,151 

133,948 

77,634 

61,796 

21,603 

Dec 31, 

Dec 31, 

Dec 31, 

2017 

2018 

2017 

Minimum 

Maximum 

—  $ 

273,210 

322,826 

187,436 

237,151 

201,948 

128,634 

129,296 

75,603 

337 

222 

234 

144 

174 

134 

78 

62 

22 

— 

273 

323 

187 

237 

202 

129 

129 

76 

7.00% 

8.00% 

7.00 

9.30 

8.90 

8.70 

8.50 

10.00 

9.00 

9.50 

8.00 

10.30 

9.90 

9.70 

9.50 

11.00 

10.00 

10.50 

Total ESOP Preferred Stock (1) 

1,406,460 

1,556,104  $ 

1,407 

1,556 

Unearned ESOP shares (2) 

$ 

(1,502) 

(1,678) 

(1)  At December 31, 2018 and 2017, additional paid-in capital included $95 million and $122 million, respectively, related to ESOP preferred stock.  
(2)  We recorded a corresponding charge to unearned ESOP shares in connection with the issuance of the ESOP Preferred Stock. The unearned ESOP shares are reduced as 

shares of the ESOP Preferred Stock are committed to be released. 

251

Wells Fargo & Company 

251 

  
 
Note 20:  Common Stock and Stock Plans 

Common Stock 
Table 20.1 presents our reserved, issued and authorized shares 
of common stock at December 31, 2018. 

Table 20.1:  Common Stock Shares 

Dividend reinvestment and common stock 

purchase plans 

Director plans 

Stock plans (1) 

Convertible securities and warrants 

Total shares reserved 

Shares issued 

Shares not reserved or issued 

Total shares authorized 

Number of shares 

9,114,931 

447,526 

369,893,237 

65,835,468 

445,291,162 

5,481,811,474 

3,072,897,364 

9,000,000,000 

(1) 

Includes employee options, restricted shares and restricted share rights,     
401(k) profit sharing and compensation deferral plans. 

In connection with our participation in the Capital Purchase 

Program (CPP), a part of the Troubled Asset Relief Program 
(TARP), we issued to the U.S. Treasury Department warrants to 
purchase 110,261,688 shares of our common stock with an 
original exercise price of $34.01 per share. The warrants expired 
on October 29, 2018, and the holders of 110,646 unexercised 
warrants as of the expiration date are no longer entitled to 
receive any shares of our common stock. Holders exercised 
23,217,208 and 9,774,052 warrants to purchase shares of our 
common stock in 2018 and 2017, respectively. 

Dividend Reinvestment and Common Stock 
Purchase Plans 
Participants in our dividend reinvestment and common stock 
direct purchase plans may purchase shares of our common stock 
at fair market value by reinvesting dividends and/or making 
optional cash payments, under the plan’s terms. 

Employee Stock Plans 
We offer stock-based employee compensation plans as described 
below. For information on our accounting for stock-based 
compensation plans, see Note 1 (Summary of Significant 
Accounting Policies). 

LONG-TERM INCENTIVE COMPENSATION PLANS  Our Long-
Term Incentive Compensation Plan (LTICP) provides for awards 
of incentive and nonqualified stock options, stock appreciation 
rights, restricted shares, restricted share rights (RSRs), 
performance share awards (PSAs), performance units and stock 
awards with or without restrictions. 

Beginning in 2010, we granted RSRs and performance 

shares as our primary long-term incentive awards instead of 
stock options. Holders of RSRs are entitled to the related shares 
of common stock at no cost generally vesting over three to five 
years after the RSRs were granted. Subject to compliance with 
applicable laws, rules and regulations, RSRs generally continue 
to vest and are distributed after retirement according to the 
original vesting schedule. Except for retirement and other 
limited circumstances, RSRs are canceled when employment 
ends. 

Holders of each vested PSA are entitled to the related shares 

of common stock at no cost. Subject to compliance with 
applicable laws, rules, and regulations, PSAs continue to vest 
and are distributed after retirement according to the original 
vesting schedule subject to satisfying the performance criteria 
and other vesting conditions. 

Holders of RSRs and PSAs may be entitled to receive 
additional RSRs and PSAs (dividend equivalents) or cash 
payments equal to the cash dividends that would have been paid 
had the RSRs or PSAs been issued and outstanding shares of 
common stock. RSRs and PSAs granted as dividend equivalents 
are subject to the same vesting schedule and conditions as the 
underlying award. 

Stock options must have an exercise price at or above fair 
market value (as defined in the plan) of the stock at the date of 
grant (except for substitute or replacement options granted in 
connection with mergers or other acquisitions) and a term of no 
more than 10 years. Options generally become exercisable over 
three years beginning on the first anniversary of the date of 
grant. Except as otherwise permitted under the plan, if 
employment is ended for reasons other than retirement, 
permanent disability or death, the option exercise period is 
reduced or the options are canceled. 

Compensation expense for most of our RSRs, and PSAs 
granted prior to 2013 is based on the quoted market price of the 
related stock at the grant date; beginning in 2013 certain RSRs 
and all PSAs granted include discretionary conditions that can 
result in forfeiture and are subject to variable accounting. For 
these awards, the associated compensation expense fluctuates 
with changes in our stock price. Table 20.2 summarizes the 
major components of stock incentive compensation expense and 
the related recognized tax benefit. 

Table 20.2:  Stock Incentive Compensation Expense 

Year ended December 31, 

(in millions) 

RSRs (1) 

Performance shares 

Stock options 

2018 

2017 

$  1,013 

9 

— 

743 

112 

(6) 

849 

320 

2016 

692 

87 

— 

779 

294 

Total stock incentive 

compensation expense (2)  $  1,022 

Related recognized tax benefit 

$ 

252 

(1) 

In February 2018, a total of 11.9 million RSRs were granted to all eligible team 
members in the U.S., and eligible team members outside the U.S., referred to 
as broad-based RSRs. 

(2)  Amounts for the year-ended December 31, 2018, were net of $19 million 

related to reversal of previously accrued RSR costs. Year-ended December 31, 
2017, were net of $26 million related to clawback credits taken against a prior 
PSA awarded under our LTICP. 

For various acquisitions and mergers, we converted 
employee and director stock options of acquired or merged 
companies into stock options to purchase our common stock 
based on the terms of the original stock option plan and the 
agreed-upon exchange ratio. In addition, we converted restricted 
stock awards into awards that entitle holders to our stock after 
the vesting conditions are met. Holders receive cash dividends 
on outstanding awards if provided in the original award. 

The total number of shares of common stock available for 

grant under the plans at December 31, 2018, was 92 million. 

252 

Wells Fargo & Company 

252

  
 
 
 
  
 
 
Director Awards 
Beginning in 2011, we granted only common stock awards under 
the LTICP to non-employee directors elected or re-elected at the 
annual meeting of stockholders and prorated awards to directors 
who join the Board at any other time. Stock awards vest 
immediately. Options also were granted to directors prior to 
2011 and can be exercised after 12 months through the tenth 
anniversary of the grant date. 

Restricted Share Rights 
A summary of the status of our RSRs and restricted share awards 
at December 31, 2018, and changes during 2018 is presented in 
Table 20.3. 

Table 20.3:  Restricted Share Rights 

Weighted-
 average 
 grant-date 
 fair value 

Number 

Nonvested at January 1, 2018 

34,894,376  $ 

Granted 

Vested 

Canceled or forfeited 

28,023,158 

(14,571,562) 

(2,773,474) 

Nonvested at December 31, 2018 

45,572,498 

50.95 

58.47 

52.12 

56.76 

54.85 

The weighted-average grant date fair value of RSRs granted 

during 2017 and 2016 was $57.54 and $48.31, respectively. 
At December 31, 2018, there was $1.1 billion of total 

unrecognized compensation cost related to nonvested RSRs. The 
cost is expected to be recognized over a weighted-average period 
of 2.0 years . The total fair value of RSRs that vested during 
2018, 2017 and 2016 was $824 million, $865 million and 
$1.1 billion, respectively. 

Performance Share Awards 
Holders of PSAs are entitled to the related shares of common 
stock at no cost subject to the Company’s achievement of 
specified performance criteria over a three-year period. PSAs are 
granted at a target number; based on the Company’s 
performance, the number of awards that vest can be adjusted 
downward to zero and upward to a maximum of either 125% or 
150% of target. The awards vest in the quarter after the end of 
the performance period. For PSAs whose performance period 
ended December 31, 2018, the determination of the number of 
performance shares that will vest will occur in first quarter of 
2019 after review of the Company’s performance by the Human 
Resources Committee of the Board of Directors. Beginning in 
2013, PSAs granted include discretionary conditions that can 
result in forfeiture and are subject to variable accounting. For 
these awards, the associated compensation expense fluctuates 
with changes in our stock price and the estimated outcome of 
meeting the performance conditions. The total expense that will 
be recognized on these awards cannot be finalized until the 
determination of the awards that will vest. 

A summary of the status of our PSAs at December 31, 2018, 

and changes during 2018 is in Table 20.4, based on the 
performance adjustments recognized as of December 2018. 

Table 20.4:  Performance Share Awards 

Weighted-
 average 
 grant-date 
 fair value (1) 

Number 

Nonvested at January 1, 2018 

5,492,104  $ 

Granted 

Vested 

Canceled or forfeited 

2,570,300 

(1,879,523) 

(198,195) 

Nonvested at December 31, 2018 

5,984,686 

47.81 

58.62 

55.21 

54.48 

49.91 

(1)  Reflects approval date fair value for grants subject to variable accounting. 

The weighted-average grant date fair value of performance 

awards granted during 2017 and 2016 was $57.14 and $44.73, 
respectively. 

At December 31, 2018, there was $26 million of total 

unrecognized compensation cost related to nonvested 
performance awards. The cost is expected to be recognized over 
a weighted-average period of 1.5 years . The total fair value of 
PSAs that vested during 2018, 2017 and 2016 was $107 million, 
$117 million, and $220 million, respectively. 

253

Wells Fargo & Company 

253 

 
  
 
 
 
  
 
 
Note 20:  Common Stock and Stock Plans (continued) 

Stock Options 
Table 20.5 summarizes stock option activity and related 
information for the stock plans. Options assumed in mergers are 
included in the activity and related information for Incentive 

Compensation Plans if originally issued under an employee plan, 
and in the activity and related information for Director Awards if 
originally issued under a director plan. 

Table 20.5:  Stock Option Activity 

Incentive compensation plans 

Options outstanding as of December 31, 2017 

Canceled or forfeited 

Exercised 

Options exercisable and outstanding as of December 31, 2018 

Director awards 

Options outstanding as of December 31, 2017 

Exercised 

Options exercisable and outstanding as of December 31, 2018 

The total intrinsic value to option holders, which is the stock 

market value in excess of the option exercise price, of options 
exercised during 2018, 2017 and 2016 was $375 million, 
$623 million and $546 million, respectively. 

Cash received from the exercise of stock options for 2018, 
2017 and 2016 was $227 million, $602 million and $893 million, 
respectively. 

We do not have a specific policy on repurchasing shares to 
satisfy share option exercises. Rather, we have a general policy 
on repurchasing shares to meet common stock issuance 
requirements for our benefit plans (including share option 
exercises), conversion of our convertible securities, acquisitions 
and other corporate purposes. Various factors determine the 
amount and timing of our share repurchases, including our 
capital requirements, the number of shares we expect to issue for 
acquisitions and employee benefit plans, market conditions 
(including the trading price of our stock), and regulatory and 
legal considerations. These factors can change at any time, and 
there can be no assurance as to the number of shares we will 
repurchase or when we will repurchase them. 

Weighted-
 average 
 exercise price 

Number 

Weighted-
 average 
remaining
contractual 
term (in yrs.) 

Aggregate
intrinsic 
 value
 (in millions) 

20,179,179  $ 

(1,886,251) 

(9,949,771) 

8,343,157 

104,900 

(104,900) 

— 

32.80 

172.36 

22.50 

13.46 

29.87 

29.88 

— 

0.2  $ 

272 

0.0 

— 

Employee Stock Ownership Plan 
The Wells Fargo & Company 401(k) Plan (401(k) Plan) is a 
defined contribution plan with an Employee Stock Ownership 
Plan (ESOP) feature. The ESOP feature enables the 401(k) Plan 
to borrow money to purchase our preferred or common stock. 
From 1994 through 2018, with the exception of 2009, we loaned 
money to the 401(k) Plan to purchase shares of our ESOP 
preferred stock. As our employer contributions are made to the 
401(k) Plan and are used by the 401(k) Plan to make ESOP loan 
payments, the ESOP preferred stock in the 401(k) Plan is 
released and converted into our common stock shares. 
Dividends on the common stock shares allocated as a result of 
the release and conversion of the ESOP preferred stock reduce 
retained earnings, and the shares are considered outstanding for 
computing earnings per share. Dividends on the unallocated 
ESOP preferred stock do not reduce retained earnings, and the 
shares are not considered to be common stock equivalents for 
computing earnings per share. Loan principal and interest 
payments are made from our employer contributions to the 
401(k) Plan, along with dividends paid on the ESOP preferred 
stock. With each principal and interest payment, a portion of the 
ESOP preferred stock is released and converted to common 
stock shares, which are allocated to the 401(k) Plan participants 
and invested in the Wells Fargo ESOP Fund within the 401(k) 
Plan. 

254 

Wells Fargo & Company 

254

 
  
 
 
 
 
Table 20.6 presents the balance of common stock and 
unreleased preferred stock held in the Wells Fargo ESOP fund, 
the fair value of unreleased ESOP preferred stock and the 

dividends on allocated shares of common stock and unreleased 
ESOP Preferred Stock paid to the 401(k) Plan. 

Table 20.6:  Common Stock and Unreleased Preferred Stock in the Wells Fargo ESOP Fund 

(in millions, except shares) 

Allocated shares (common) 

Unreleased shares (preferred) 

Fair value of unreleased ESOP preferred shares 

Allocated shares (common) 

Unreleased shares (preferred) 

Deferred Compensation Plan for Independent 
Sales Agents 
WF Deferred Compensation Holdings, Inc. is a wholly-owned 
subsidiary of the Parent formed solely to sponsor a deferred 
compensation plan for independent sales agents who provide 
investment, financial and other qualifying services for or with 
respect to participating affiliates. 

Shares outstanding 

December 31, 

2018 

2017 

2016 

138,182,911 

124,670,717 

128,189,305 

1,406,460 

1,556,104 

1,439,181 

$ 

1,407 

1,556 

1,439 

$ 

2018 

213 

159 

Dividends paid 

Year ended December 31, 

2017 

195 

166 

2016 

208 

169 

The Nonqualified Deferred Compensation Plan for 

Independent Contractors, which became effective 
January 1, 2002, allowed participants to defer all or part of their 
eligible compensation payable to them by a participating 
affiliate. The plan was frozen for new compensation deferrals 
effective January 1, 2012. The Parent has fully and 
unconditionally guaranteed the deferred compensation 
obligations of WF Deferred Compensation Holdings, Inc. under 
the plan. 

255

Wells Fargo & Company 

255 

  
 
Note 21:  Revenue from Contracts with Customers 

Our revenue includes net interest income on financial 
instruments and noninterest income. Table 21.1 presents our 
revenue by operating segment. The “Other” segment for each of 
the tables below includes the elimination of certain items that 
are included in more than one business segment, most of which 
represents products and services for WIM customers served 
through Community Banking distribution channels. For 
additional description of our operating segments, including 
additional financial information and the underlying 
management accounting process, see Note 26 (Operating 
Segments) to Financial Statements in this Report. 

Table 21.1:  Revenue by Operating Segment 

We adopted ASU 2014-09 – Revenue from Contracts with 

Customers (“the new revenue recognition guidance”) on a 
modified retrospective basis as of January 1, 2018. Under this 
method of adoption, prior period financial information for 2017 
and 2016 was not adjusted. Rather, this ASU resulted in a 
cumulative-effect adjustment that decreased the beginning 
balance of retained earnings by $32 million on January 1, 2018, 
and changed the presentation of certain revenues and expenses 
prospectively. For details on the impact of the adoption of this 
ASU, see Note 1 (Summary of Significant Accounting Policies). 

(in millions) 

Net interest income (1) 

Noninterest income: 

Service charges on deposit accounts 

Trust and investment fees: 

Brokerage advisory, commissions and other fees 

Trust and investment management 

Investment banking 

Total trust and investment fees 

Card fees 

Other fees: 

Lending related charges and fees (1)(2) 

Cash network fees 

Commercial real estate brokerage commissions 

Wire transfer and other remittance fees 

All other fees (1) 

Total other fees 

Mortgage banking (1) 

Insurance (1) 

Net gains from trading activities (1) 

Net gains (losses) on debt securities (1) 

Net gains from equity investments (1) 

Lease income (1) 

Other income of the segment (1) 
Total noninterest income 

Revenue 

Net interest income (1) 

Noninterest income: 

Service charges on deposit accounts 

Trust and investment fees: 

Brokerage advisory, commissions and other fees 

Trust and investment management 

Investment banking 

Total trust and investment fees 

Card fees 

Other fees: 

Lending related charges and fees (1)(2) 

Cash network fees 

Commercial real estate brokerage commissions 

Wire transfer and other remittance fees 

All other fees (1) 

Total other fees 

Mortgage banking (1) 

Insurance (1) 

Net gains from trading activities (1) 

Net gains (losses) on debt securities (1) 

Net gains from equity investments (1) 
Lease income (1) 

Other income of the segment (1) 
Total noninterest income 

Revenue 

(continued on following page) 

256 

Community
Banking 

$ 

29,219 

Wholesale 
Banking 

18,690 

Wealth and 
Investment 
Management 

Year ended December 31, 2018 

Other (3) 

Consolidated 
Company 

4,441 

(2,355) 

49,995 

2,641 

2,074 

16 

(15) 

4,716 

1,887 

910 

(35) 

2,762 

3,543 

278 

478 

— 

264 

339 

1,359 

2,659 

83 

28 

(3) 

1,505 

— 

3,117 
17,694 

46,913 

317 

445 

1,783 

2,545 

362 

1,247 

3 

468 

209 

92 

2,019 

362 

312 

516 

102 

293 

1,753 

(322) 

10,016 

28,706 

9,161 

2,893 

9 

12,063 

6 

7 

— 

— 

8 

2 

17 

(11) 

82 

57 

9 

(283) 

— 

(21) 

11,935 

16,376 

(1,929) 

(932) 

— 

(2,861) 

(4) 

(6) 

— 

— 

(4) 

(1) 

(11) 

7 

(48) 

1 

— 

— 

— 

(301) 
(3,232) 

(5,587) 

9,436 

3,316 

1,757 

14,509 

3,907 

1,526 

481 

468 

477 

432 

3,384 

3,017 

429 

602 

108 

1,515 

1,753 
2,473 

36,413 

86,408 

28,658 

18,810 

4,641 

(2,552) 

49,557 

Year ended December 31, 2017 

$ 

$ 

$ 

2,909 

1,830 

889 

(59) 

2,660 

3,613 

311 

498 
1 

239 

448 

1,497 

3,895 

139 

(251) 

709 

1,455 
— 

1,734 
18,360 

47,018 

2,201 

304 

523 

1,827 

2,654 

345 

1,257 

8 

461 

204 

124 

2,054 

458 

872 

701 

(232) 

116 
1,907 

114 
11,190 

30,000 

Wells Fargo & Company 

17 

(16) 

5,111 

9,072 

2,877 

(2) 

11,947 

6 

8 

— 

— 

9 

1 

18 

(10) 

88 

92 

2 
208 

— 
63 

12,431 

17,072 

(1,848) 

(917) 

(1) 

(2,766) 

(4) 

(8) 

— 

— 

(4) 

— 

(12) 

7 

(50) 

— 

— 
— 

— 
(308) 

(3,149) 

(5,701) 

9,358 

3,372 

1,765 

14,495 

3,960 

1,568 

506 

462 

448 

573 

3,557 

4,350 

1,049 

542 

479 
1,779 

1,907 
1,603 

38,832 

88,389 

256

(continued from previous page) 

Net interest income (1) 

Noninterest income: 

Service charges on deposit accounts 
Trust and investment fees: 

Brokerage advisory, commissions and other fees 
Trust and investment management 

Investment banking 

Total trust and investment fees 

Card fees 

Other fees: 

Lending related charges and fees (1)(2) 
Cash network fees 

Commercial real estate brokerage commissions 
Wire transfer and other remittance fees 

All other fees (1) 

Total other fees 

Mortgage banking (1) 

Insurance (1) 

Net gains from trading activities (1) 

Net gains (losses) on debt securities (1) 

Net gains from equity investments (1) 

Lease income (1) 

Other income of the segment (1) 

Total noninterest income 

Revenue 

Community
Banking 

$ 

27,333 

Wholesale 
Banking 

18,699 

3,111 

1,854 
849 

(141) 
2,562 

3,598 

364 
528 

— 
219 

525 
1,636 

5,624 

112 

(148) 

933 

804 

— 

948 

$ 

19,180 

46,513 

2,260 

368 
473 

1,833 
2,674 

336 

1,198 
9 

494 
178 

206 
2,085 

475 

1,156 

677 

8 

199 

1,927 

551 

12,348 

31,047 

Wealth and 
Investment 
Management 

Year ended December 31, 2016 

Other (3) 

Consolidated 
Company 

4,249 

(2,527) 

47,754 

19 

(18) 

5,372 

8,870 
2,891 

(1) 
11,760 

(1,876) 
(877) 

— 
(2,753) 

6 

8 
— 

— 
8 

2 
18 

(9) 

— 

81 

1 

100 

— 

53 

12,029 

16,278 

(4) 

(8) 
— 

— 
(4) 

— 
(12) 

6 

— 

— 

— 

— 

— 

(263) 

(3,044) 

(5,571) 

9,216 
3,336 

1,691 
14,243 

3,936 

1,562 
537 

494 
401 

733 
3,727 

6,096 

1,268 

610 

942 

1,103 

1,927 

1,289 

40,513 

88,267 

(1)  Most of our revenue is not within the scope of Accounting Standards Update (ASU) 2014-09 – Revenue from Contracts with Customers, and additional details are included 
in other footnotes to our financial statements. The scope explicitly excludes net interest income as well as many other revenues for financial assets and liabilities, including 
loans, leases, securities, and derivatives. 

(2)  Represents combined amount of previously reported “Charges and fees on loans” and “Letters of credit fees”. 
(3) 

Includes the elimination of certain items that are included in more than one business segment, most of which represents products and services for WIM customers served 
through Community Banking distribution channels. 

We provide services to customers which have related 
performance obligations that we complete to recognize revenue. 
Our revenues are generally recognized either immediately upon 
the completion of our service or over time as we perform 
services. Any services performed over time generally require that 
we render services each period and therefore we measure our 
progress in completing these services based upon the passage of 
time. 

charges include fees for periodic account maintenance activities 
and event-driven services such as stop payment fees. Our 
obligation for event-driven services is satisfied at the time of the 
event when the service is delivered, while our obligation for 
maintenance services is satisfied over the course of each month. 
Our obligation for overdraft services is satisfied at the time of the 
overdraft. 

Table 21.2 presents our service charges on deposit accounts 

by operating segment. 

SERVICE CHARGES ON DEPOSIT ACCOUNTS are earned on 
depository accounts for commercial and consumer customers 
and include fees for account and overdraft services. Account 

Table 21.2:  Service Charges on Deposit Accounts by Operating Segment 

Community Banking 

Wholesale Banking 

Wealth and Investment 
Management 

Other 

Consolidated 
Company 

(in millions) 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

Overdraft fees 

$ 1,776 

1,941 

2,024 

5 

6 

6 

Account charges 

Service charges on

deposit accounts 

865 

968 

1,087 

2,069 

2,195 

2,254 

$ 2,641 

2,909 

3,111 

2,074 

2,201 

2,260 

1 

15 

16 

1 

16 

17 

— 

19 

19 

— 

— 

— 

1,782 

1,948 

2,030 

(15) 

(16) 

(18) 

2,934 

3,163 

3,342 

(15) 

(16) 

(18) 

4,716 

5,111 

5,372 

Year ended December 31, 

BROKERAGE ADVISORY, COMMISSIONS AND OTHER FEES 
are earned for providing full-service and discount brokerage 
services predominantly to retail brokerage clients. These 
revenues include fees earned on asset-based and transactional 
accounts and other brokerage advisory services. 

Asset-based revenues are charged based on the market 
value of the client’s assets. The services and related obligations 
associated with certain of these revenues, which include 
investment advice, active management of client assets, or 
assistance with selecting and engaging a third-party advisory 

manager, are generally satisfied over a month or quarter. The 
remaining revenues include trailing commissions which are 
earned for selling shares to investors. Our obligation associated 
with earning trailing commissions is satisfied at the time shares 
are sold. However, these fees are received and recognized over 
time during the period the customer owns the shares and we 
remain the broker of record. The amount of trailing commissions 
is variable based on the length of time the customer holds the 
shares and on changes in the value of the underlying assets. 

257

Wells Fargo & Company 

257 

 
Note 21:  Revenue from Contracts with Customers (continued) 

Transactional revenues are earned for executing 

transactions at the client’s direction. Our obligation is generally 
satisfied upon the execution of the transaction and the fees are 
based on the size and number of transactions executed. 

mutual fund companies in return for providing record keeping 
and other administrative services, and annual account 
maintenance fees charged to customers. 

Table 21.3 presents our brokerage advisory, commissions 

Other revenues earned from other brokerage advisory 

and other fees by operating segment. 

services include omnibus and networking fees received from 

Table 21.3:  Brokerage Advisory, Commissions and Other Fees by Operating Segment 

Community Banking 

Wholesale Banking 

Wealth and Investment 
Management 

Year ended December 31, 

Other 

Consolidated 
Company 

(in millions) 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

Asset-based 

revenue (1) 

Transactional 
revenue 

Other revenue 

Brokerage advisory,
commissions and 
other fees 

$  1,482 

1,372 

1,243 

1 

1 

2 

6,899 

6,630 

6,164 

(1,484) 

(1,371)  (1,241)  6,898 

6,632 

6,168 

340 

65 

382 

76 

454 

157 

70 

246 

40 

263 

55 

1,618 

1,802 

2,032 

(380) 

(400) 

(477)  1,648 

1,824 

2,064 

311 

644 

640 

674 

(65) 

(77) 

(158) 

890 

902 

984 

$  1,887 

1,830 

1,854 

317 

304 

368 

9,161 

9,072 

8,870 

(1,929) 

(1,848)  (1,876)  9,436 

9,358 

9,216 

(1)  We earned trailing commissions of $1.3 billion for each of the years ended December 31, 2018, 2017, and 2016. 

TRUST AND INVESTMENT MANAGEMENT FEES are earned 
for providing trust, investment management and other related 
services. 

Investment management services include managing and 

administering assets, including mutual funds, and institutional 
separate accounts. Fees for these services are generally 
determined based on a tiered scale relative to the market value of 
assets under management (AUM). In addition to AUM we have 
client assets under administration (AUA) that earn various 
administrative fees which are generally based on the extent of 
the services provided to administer the account. Services with 
AUM and AUA-based fees are generally performed over time. 

Trust services include acting as a trustee or agent for 
corporate trust, personal trust, and agency assets. Obligations 
for trust services are generally satisfied over time, while 
obligations for activities that are transactional in nature are 
satisfied at the time of the transaction. 

Other related services include the custody and safekeeping 

of accounts. Our obligation for these services is generally 
satisfied over time. 

Table 21.4 presents our trust and investment management 

fees by operating segment. 

Table 21.4:  Trust and Investment Management Fees by Operating Segment 

Community Banking 

Wholesale Banking 

Wealth and Investment 
Management 

Year ended December 31, 

Other 

Consolidated 
Company 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

$  — 

1 

— 

908 

887 

847 

2 

1 

2 

— 

329 

116 

— 

421 

102 

— 

2,087 

2,053 

2,079 

— 

— 

— 

2,087 

2,054 

2,079 

399 

74 

728 

78 

757 

67 

738 

(932) 

(916) 

(875) 

1,033 

1,149 

1,109 

74 

— 

(1) 

(2) 

196 

169 

148 

$  910 

889 

849 

445 

523 

473 

2,893 

2,877 

2,891 

(932) 

(917) 

(877) 

3,316 

3,372 

3,336 

(in millions) 

Investment 

management fees 

Trust fees 

Other revenue 

Trust and investment 
management fees 

258 

Wells Fargo & Company 

258

  
INVESTMENT BANKING FEES are earned for underwriting 
debt and equity securities, arranging loan syndications and 
performing other advisory services. Our obligation for these 
services is generally satisfied at closing of the transaction. 
Substantially all of these fees are in the Wholesale Banking 
operating segment. 

card interchange and network revenues are earned on credit and 
debit card transactions conducted through payment networks 
such as Visa, MasterCard, and American Express. Our obligation 
is satisfied concurrently with the delivery of services on a daily 
basis. 

Table 21.5 presents our card fees by operating segment. 

CARD FEES include credit and debit card interchange and 
network revenues and various card-related fees. Credit and debit 

Table 21.5:  Card Fees by Operating Segment 

Community Banking 

Wholesale Banking 

Wealth and Investment 
Management 

Year ended December 31, 

Other 

Consolidated 
Company 

(in millions) 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

2018 

2017 

2016 

Credit card interchange and
network revenues (1) 

Debit card interchange and

network revenues 

Late fees, cash advance
fees, balance transfer
fees, and annual fees 

$  792 

944 

959 

361 

345 

329 

2,053 

1,964 

1,889 

— 

698 

705 

750 

1 

—

—

7 

— 

Card fees (1) 

$ 3,543 

3,613 

3,598 

362 

345 

336 

6 

— 

— 

6 

6

—

—

6

6 

— 

— 

6 

(4) 

(4) 

(4)  1,155 

1,291 

1,290 

— 

—

— 

2,053 

1,964 

1,896 

— 

(4) 

—

(4) 

— 

699 

705 

750 

(4)  3,907 

3,960 

3,936 

(1)  The cost of credit card rewards and rebates of $1.4 billion, $1.2 billion and $1.0 billion for the years ended December 31, 2018, 2017 and 2016, respectively, are presented 

net against the related revenues. 

CASH NETWORK FEES are earned for processing ATM 
transactions. Our obligation is completed daily upon settlement 
of ATM transactions. Substantially all of these fees are in the 
Community Banking operating segment. 

COMMERCIAL REAL ESTATE BROKERAGE COMMISSIONS 
are earned for assisting customers in the sale of real estate 
property. Our obligation is satisfied upon the successful 
brokering of a transaction. Fees are based on a fixed percentage 
of the sales price. All of these fees are in the Wholesale Banking 
operating segment. 

WIRE TRANSFER AND OTHER REMITTANCE FEES consist of 
fees earned for funds transfer services and issuing cashier’s 
checks and money orders. Our obligation is satisfied at the time 
of the funds transfer services or upon issuance of the cashier’s 
check or money order. Substantially all of these fees are in the 
Community Banking and Wholesale Banking operating 
segments. 

ALL OTHER FEES include various types of fees earned on 
services to customers which have related performance 
obligations that we complete to recognize revenue. A significant 
portion of the revenue is earned from providing business payroll 
services and merchant services, which are generally recognized 
over time as we perform the services. Most of these fees are in 
the Community Banking operating segment. 

259

Wells Fargo & Company 

259 

 
Note 22:  Employee Benefits and Other Expenses 

We sponsored the Pension and Life Assurance Plan of 
Wachovia Bank to employees in the United Kingdom (UK 
Pension Plan). In September 2017, an annuity contract was 
entered into that effected a full settlement of this UK Pension 
Plan, resulting in a plan settlement of $74 million and a 
settlement loss of $7 million. 

Our nonqualified defined benefit plans are unfunded and 
provide supplemental defined benefit pension benefits to certain 
eligible employees. The benefits under these plans were frozen in 
prior years. 

We provide health care and life insurance benefits for 
certain retired employees, and we reserve the right to amend, 
modify or terminate any of the benefits at any time. 

The benefit obligation for the qualified plans, nonqualified 

plans and other benefits plans was $10.1 billion, $557 million 
and $555 million, respectively, at December 31, 2018, a decrease 
from $11.1 billion, $621 million and $611 million, respectively, at 
December 31, 2017. The decreases were primarily due to benefits 
paid (net of participant contributions), and actuarial gains, 
reflecting an increase in the discount rates, see Table 22.5. The 
information set forth in the following tables is based on current 
actuarial reports using the measurement date of December 31 for 
our pension and postretirement benefit plans. 

Pension and Postretirement Plans 
We sponsor a frozen noncontributory qualified defined benefit 
retirement plan, the Wells Fargo & Company Cash Balance Plan 
(Cash Balance Plan), which covers eligible employees of Wells 
Fargo. The Cash Balance Plan was frozen on July 1, 2009, and no 
new benefits accrue after that date. 

Prior to July 1, 2009, eligible employees’ Cash Balance Plan 

accounts were allocated a compensation credit based on a 
percentage of their certified compensation; the freeze 
discontinued the allocation of compensation credits after 
June 30, 2009. Investment credits continue to be allocated to 
participants’ accounts based on their accumulated balances. 

We did not make a contribution to our Cash Balance Plan in 

2018. We do not expect that we will be required to make a 
contribution to the Cash Balance Plan in 2019; however, this is 
dependent on the finalization of the actuarial valuation in 2019. 
Our decision of whether to make a contribution in 2019 will be 
based on various factors including the actual investment 
performance of plan assets during 2019. Given these 
uncertainties, we cannot estimate at this time the amount, if any, 
that we will contribute in 2019 to the Cash Balance Plan. For the 
nonqualified pension plans and postretirement benefit plans, 
there is no minimum required contribution beyond the amount 
needed to fund benefit payments; we may contribute more to our 
postretirement benefit plans dependent on various factors. 

We recognize settlement losses for our Cash Balance Plan 

based on assessing whether lump sum payments will, in 
aggregate for the year, exceed the sum of its annual service and 
interest cost (threshold). In 2018, lump sum payments (included 
in the “Benefits paid” line in Table 22.1) exceeded this threshold. 
Settlement losses of $134 million were recognized in 2018, 
representing the pro rata portion of the net loss in cumulative 
other comprehensive income based on the percentage reduction 
in the Cash Balance Plan’s projected benefit obligation 
attributable to 2018 lump sum payments. 

260 

Wells Fargo & Company 

260

Table 22.1 presents the changes in the benefit obligation and 

the fair value of plan assets, the funded status, and the amounts 
recognized on the balance sheet. 

Table 22.1:  Changes in Benefit Obligation and Fair Value of Plan Assets 

(in millions) 

Change in benefit obligation: 

December 31, 2018 

December 31, 2017 

Pension benefits 

Pension benefits 

Qualified 

Non-
qualified 

Other 
benefits 

Qualified 

Non-
qualified 

Other 
benefits 

Benefit obligation at beginning of year 

$  11,110 

Service cost 

Interest cost 

Plan participants’ contributions 

Actuarial loss (gain) 

Benefits paid 

Medicare Part D subsidy 

Amendment 

Settlement 

Other 

Foreign exchange impact 

11 

392 

—

(674) 

(719) 

— 

1 

— 

13 

(5) 

Benefit obligation at end of year 

10,129 

Change in plan assets: 

Fair value of plan assets at beginning of year 

Actual return on plan assets 

Employer contribution 

Plan participants’ contributions 

Benefits paid 

Medicare Part D subsidy 

Settlement 

Other 

Foreign exchange impact 

10,667 

(478) 

10 

—

— 

— 

1 

(4) 

Fair value of plan assets at end of year 

9,477 

Funded status at end of year 

$ 

(652) 

(557) 

Amounts recognized on the balance sheet at end of year: 

Assets 

Liabilities 

$ 

1 

— 

(653) 

(557) 

Table 22.2 provides information for pension and post 

retirement plans with benefit obligations in excess of plan assets. 

Table 22.2:  Plans with Benefit Obligations in Excess of Plan Assets 

621 

— 

21 

 —

(27) 

(57) 

— 

— 

— 

— 

(1) 

557 

— 

— 

57 

 —

— 

— 

— 

— 

— 

611 

10,774 

630 

— 

21 

 48

(33) 

(92) 

2 

— 

— 

— 

(2) 

5 

412 

 —

634 

— 

24 

 —

46 

(651) 

(79) 

— 

— 

(74) 

— 

10 

— 

— 

— 

— 

— 

731 

— 

28 

 40 

(102) 

(88) 

1 

— 

— 

— 

1 

555 

11,110 

621 

611 

565 

(17) 

5 

 48

2 

— 

— 

— 

511 

(44) 

— 

(44) 

10,120 

1,253 

11 

 —

(651) 

— 

(74) 

— 

8 

10,667 

— 

— 

79 

 —

(79) 

— 

— 

— 

— 

— 

(443) 

(621) 

— 

(443) 

— 

(621) 

549 

56 

7 

 40 

(88) 

1 

— 

— 

— 

565 

(46) 

— 

(46) 

(719) 

(57) 

(92) 

(in millions) 

Projected benefit obligation 

Accumulated benefit obligation 

Fair value of plan assets 

December 31, 2018 

December 31, 2017 

Pension Benefits 

Other Benefits 

Pension Benefits 

Other Benefits 

$ 

10,640 

10,627 

9,429 

N/A 

555 

511 

11,721 

11,717 

10,656 

N/A 

611 

565 

261

Wells Fargo & Company 

261 

  
 
  
Note 22:  Employee Benefits and Other Expenses (continued) 

Table 22.3 presents the components of net periodic benefit 

cost and other comprehensive income (OCI). 

Table 22.3:  Net Periodic Benefit Cost and Other Comprehensive Income 

December 31, 2018 

December 31, 2017 

December 31, 2016 

Pension benefits 

Pension benefits 

Pension benefits 

Qualified  qualified  benefits  Qualified 

Non-

Other 

Non-
qualified 

Other 

benefits  Qualified 

Non-
qualified 

Other 
benefits 

(in millions) 

Service cost 

Interest cost (1) 

Expected return on plan assets (1) 

Amortization of net actuarial loss (gain) (1) 

Amortization of prior service credit (1) 

Settlement loss (1) 

Net periodic benefit cost 

Other changes in plan assets and benefit

obligations recognized in other
comprehensive income: 

Net actuarial loss (gain) 

Amortization of net actuarial gain (loss) 

Prior service cost (credit) (2) 

Amortization of prior service credit 

Settlement 

Total recognized in other comprehensive

income 

Total recognized in net periodic benefit cost

$

11

392 

(641) 

131 

— 

134 

27 

445 

(131) 

1 

—

(134) 

—

21 

— 

14 

— 

2 

37 

(27) 

(14) 

— 

 —

(2) 

181 

(43) 

—

21 

(31) 

(18) 

(10) 

— 

5 

412 

(652) 

148 

—

7 

(38) 

(80) 

15 

18 

— 

 10

— 

43 

33 

(148) 

1

 —

(8) 

(122) 

and other comprehensive income 

$ 

208 

(6) 

5 

(202) 

— 

24 

— 

11 

 —

6 

41 

46 

(11) 

 —

 —

(6) 

29 

70 

— 

28 

(30) 

(9) 

 (10)

— 

(21) 

(128) 

9 

 —

 10

— 

3 

422 

(608) 

146 

 —

5 

(32) 

302 

(146) 

 —

 —

(5) 

— 

26 

— 

12 

 —

2 

40 

— 

39 

(30) 

(5) 

 (2)

— 

2 

9 

(12) 

 —

 —

(2) 

(82) 

5 

(177)

 2 

— 

(109) 

151 

(5) 

(252) 

(130) 

119 

35 

(250) 

(1)  Effective January 1, 2018, we adopted ASU 2017-07 – Improving the Presentation of Net Periodic Pension Cost and Net Periodic Postretirement Benefit Cost. Accordingly, 

2018 balances are reported in other noninterest expense on the consolidated statement of income. For 2017 and 2016, these balances were reported in employee benefits. 
In 2016, a prior service credit of $177 million was recognized for an amendment that reduced the Wells Fargo & Company Retiree Plan obligation. 

(2) 

Table 22.4 provides the amounts recognized in cumulative 

OCI (pre tax). 

Table 22.4:  Benefits Recognized in Cumulative OCI 

(in millions) 

Net actuarial loss (gain) 

Net prior service cost (credit) 

Total 

December 31, 2018 

December 31, 2017 

Pension benefits 

Pension benefits 

Qualified 

$ 

3,336 

1 

$ 

3,337 

Non-
qualified 

Other 
benefits 

Qualified 

Non-
qualified 

Other 
benefits 

149 

— 

149 

(327) 

(156) 

(483) 

3,156 

— 

3,156 

192 

— 

192 

(360) 

(166) 

(526) 

262 

Wells Fargo & Company 

262

  
  
 
 
 
 
 
 
 
 
Plan Assumptions 
For additional information on our pension accounting 
assumptions, see Note 1 (Summary of Significant Accounting 
Policies). Table 22.5 presents the weighted-average assumptions 
used to estimate the projected benefit obligation for pension 
benefits. 

Table 22.5:  Weighted-Average Assumptions Used to Estimate Projected Benefit Obligation 

Discount rate 

Interest crediting rate 

December 31, 2018 

December 31, 2017 

Pension benefits 

Pension benefits 

Qualified 

4.30% 

3.22 

Non-
qualified 

Other 
benefits 

4.20 

2.18 

4.24 

N/A 

Qualified 

3.65 

2.74 

Non-
qualified 

Other 
benefits 

3.55 

1.54 

3.54 

N/A 

Table 22.6 presents the weighted-average assumptions used 

to determine the net periodic benefit cost. 

Table 22.6:  Weighted-Average Assumptions Used to Determine Net Periodic Benefit Cost 

December 31, 2018 

December 31, 2017 

December 31, 2016 

Pension benefits 

Pension benefits 

Pension benefits 

Qualified 

Non-
qualified 

Other 

benefits  Qualified 

Non-
qualified 

Other 

benefits  Qualified 

Non-
qualified 

Other 
benefits 

Discount rate (1) 

Interest crediting rate (1) 

Expected return on plan assets 

3.65% 

2.74 

6.24 

3.65 

1.68 

N/A 

3.54 

N/A 

5.75 

3.98 

2.92 

6.70 

3.93 

1.85 

N/A 

4.00 

N/A 

5.75 

3.99 

3.03 

6.75 

4.11 

2.02 

N/A 

4.16 

N/A 

5.75 

(1) 

Includes the impact of interim re-measurements as applicable. 

To account for postretirement health care plans, we used 
health care cost trend rates to recognize the effect of expected 
changes in future health care costs due to medical inflation, 
utilization changes, new technology, regulatory requirements 
and Medicare cost shifting. In determining the end of year 
benefit obligation, we assumed an average annual increase of 
approximately 8.40% for health care costs in 2019. This rate is 
assumed to trend down 0.50%-0.60% per year until the trend 
rate reaches an ultimate rate of 4.50% in 2026. The 2018 
periodic benefit cost was determined using an initial annual 
trend rate of 9.00%. This rate was assumed to decrease 
0.40%-0.70% per year until the trend rate reached an ultimate 
rate of 4.50% in 2026. 

Investment Strategy and Asset Allocation 
We seek to achieve the expected long-term rate of return with a 
prudent level of risk, given the benefit obligations of the pension 
plans and their funded status. Our overall investment strategy is 
designed to provide our Cash Balance Plan with long-term 
growth opportunities while ensuring that risk is mitigated 
through diversification across numerous asset classes and 
various investment strategies. We target the asset allocation for 
our Cash Balance Plan at a target mix range of 25%-45% 
equities, 45%-65% fixed income, and approximately 10% in real 
estate, venture capital, private equity and other investments. The 
Employee Benefit Review Committee (EBRC), which includes 
several members of senior management, formally reviews the 
investment risk and performance of our Cash Balance Plan on a 
quarterly basis. Annual Plan liability analysis and periodic asset/ 
liability evaluations are also conducted. 

Other benefit plan assets include (1) assets held in a 401(h) 
trust, which are invested with a target mix of 40%-60% for both 
equities and fixed income, and (2) assets held in the Retiree 
Medical Plan Voluntary Employees’ Beneficiary Association 
(VEBA) trust, which are invested with a general target asset mix 
of 20%-40% equities and 60%-80% fixed income. Members of 
the EBRC formally review the investment risk and performance 
of these assets on a quarterly basis. 

Projected Benefit Payments 
Future benefits that we expect to pay under the pension and 
other benefit plans are presented in Table 22.7. 

Table 22.7:  Projected Benefit Payments 

(in millions) 

Year ended December 31, 

2019 

2020 

2021 

2022 

2023 

Pension benefits 

Qualified 

Non-
qualified 

Other 
Benefits 

$ 

784 

771 

767 

759 

711 

52 

50 

49 

46 

44 

46 

48 

48 

47 

46 

2024-2028 

3,381 

199 

198 

263

Wells Fargo & Company 

263 

  
 
  
 
 
  
 
Note 22:  Employee Benefits and Other Expenses (continued) 

Fair Value of Plan Assets 
Table 22.8 presents the balances of pension plan assets and 
other benefit plan assets measured at fair value. See Note 18 
(Fair Values of Assets and Liabilities) for fair value hierarchy 
level definitions. 

Table 22.8:  Pension and Other Benefit Plan Assets 

Pension plan assets 

Other benefits plan assets 

Carrying value at year end 

Level 1 

Level 2 

Level 3 

Total 

Level 1 

Level 2 

Level 3 

Total 

(in millions) 

December 31, 2018 

Cash and cash equivalents 

Long duration fixed income (1)

Intermediate (core) fixed income (2) 

High-yield fixed income

International fixed income

Domestic large-cap stocks (3) 

Domestic mid-cap stocks 

Domestic small-cap stocks 

Global stocks (4)

International stocks (5) 

Emerging market stocks 

Real estate

Hedge funds/absolute return 

Other 

$ 

2 

284 

902

4,414

— 

—

55

582 

167 

141 

72

449 

— 

148

63 

34

118 

 114

 186

238 

89 

7 

 357

110 

205 

 33

32 

44 

— 

 —

— 

 —

 —

— 

— 

— 

 —

— 

— 

 14

— 

8

286 

5,316

118 

 114

 241

820 

256 

148 

 429

559 

205 

 195

95 

86 

69 

 —

— 

 —

 —

— 

— 

— 

 —

9 

—

 —

— 

4 

22 

 —

183 

 —

 —

115 

28 

17 

 —

40 

 —

 —

— 

—

Plan investments - excluding investments

at NAV 

$  2,615 

6,231 

22 

8,868 

82 

405 

Investments at NAV (6) 

Net receivables 

Total plan assets 

December 31, 2017 

Cash and cash equivalents 

Long duration fixed income (1) 

Intermediate (core) fixed income (2) 

$ 

High-yield fixed income

International fixed income

Domestic large-cap stocks (3) 

Domestic mid-cap stocks 

Domestic small-cap stocks 

Global stocks (4)

International stocks (5) 

Emerging market stocks

Real estate

Hedge funds/absolute return

Other 

566 

43 

$  9,477 

235 

5,299 

255 

 267

 283

1,125 

360 

236 

 480

799 

 305

 208

 90

80 

— 

— 

— 

 —

 —

— 

— 

— 

 —

— 

 —

 20

 —

8

85 

— 

— 

 —

 —

— 

— 

— 

 —

23 

 —

 —

 —

3 

23 

— 

185 

 —

 —

130 

34 

20 

 —

38 

 —

 —

 —

—

1 

875 

— 

—

60

825 

227 

224 

89

542 

—

157

62

—

234 

4,424 

255 

 267

 223

300 

133 

12 

 391

257 

 305

 31

 28

72 

Plan investments - excluding investments at NAV  $  3,062 

6,932 

28 

10,022 

111 

430 

Investments at NAV (6) 

Net receivables 

Total plan assets 

594 

51 

$  10,667 

— 

 —

— 

 —

 —

— 

— 

— 

 —

— 

 —

 —

— 

24 

24 

— 

— 

— 

 —

 —

— 

— 

— 

 —

— 

 —

 —

 —

23

23 

91 

 —

183 

 —

 —

115 

28 

17 

 —

49 

 —

 —

— 

28 

511 

— 

— 

511 

108 

— 

185 

 —

 —

130 

34 

20 

 —

61 

 —

 —

 —

26 

564 

— 

1 

565 

(1)  This category includes a diversified mix of assets, which are being managed in accordance with a duration target of approximately 10 years and an emphasis on corporate 

credit bonds combined with investments in U.S. Treasury securities and other U.S. agency and non-agency bonds. 

(2)  This category includes assets that are intermediate duration, investment grade bonds held in investment strategies benchmarked to the Bloomberg Barclays Capital U.S. 

Aggregate Bond Index, including U.S. Treasury securities, agency and non-agency asset-backed bonds and corporate bonds. 

(3)  This category covers a broad range of investment styles, including active, enhanced index and passive approaches, as well as style characteristics of value, core and growth 

emphasized strategies. Assets in this category are currently diversified across eight unique investment strategies with no single investment manager strategy representing 
more than 2.0% of total plan assets. 

(4)  This category consists of five unique investment strategies providing exposure to broadly diversified, global equity investments, which generally have an allocation of 
40-60% in U.S. domiciled equities and an equivalent allocation range in non-U.S. equities, with no single strategy representing more than 1.5% of total Plan assets. 
(5)  This category includes assets diversified across four unique investment strategies providing exposure to companies in developed market, non-U.S. countries with no single 

strategy representing more than 2.5% of total plan assets. 

(6)  Consists of certain investments that are measured at fair value using NAV per share (or its equivalent) as a practical expedient and are excluded from the fair value 

hierarchy. 

264 

Wells Fargo & Company 

264

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 22.9 presents the changes in Level 3 pension plan and 

other benefit plan assets measured at fair value. 

Table 22.9:  Fair Value Level 3 Pension and Other Benefit Plan Assets 

(in millions)

Quarter ended December 31, 2018 

Pension plan assets: 

Real estate 

Other

Total pension plan assets 

Other benefits plan assets: 

Other 

Total other benefit plan assets 

Quarter ended December 31, 2017 

Pension plan assets: 

Long duration fixed income 

Real estate 

Other

Total pension plan assets 

Other benefits plan assets: 

Other

Total other benefit plan assets 

Gains (losses) 

Balance 
beginning 
 of year 

Realized 

Unrealized (1) 

Purchases, 
sales 
and 
settlements 
(net)

Transfers 
Into/ 
(Out of) 
 Level 3

Balance 
end of 
 year 

$ 

$ 

$ 

$ 

$ 

$ 

$

$ 

20 

8

28 

23 

23 

19 

25 

8

52 

23

23 

(2) 

—

(2) 

1 

1 

— 

(3) 

 —

(3) 

 —

— 

(1) 

  ———

(1) 

— 

— 

— 

5 

  —

5 

  —

— 

(3)

(3)

— 

— 

— 

(4) 

 —

(4) 

 —

— 

 —

 —

— 

— 

(19)

(3) 

 —

(22) 

 —

— 

 14

8

 22 

24 

24 

 — 

20 

 8

28 

 23 

23 

(1)  All unrealized gains (losses) relate to instruments held at period end. 

VALUATION METHODOLOGIES  Following is a description of 
the valuation methodologies used for assets measured at fair 
value. 

Cash and Cash Equivalents – includes investments in 
collective investment funds valued at fair value based upon the 
fund’s NAV per share held at year-end. The NAV per share is 
quoted on a private market that is not active; however, the NAV 
per share is based on underlying investments traded on an active 
market. This group of assets also includes investments in 
registered investment companies valued at the NAV per share 
held at year-end and in interest-bearing bank accounts. 

Long Duration, Intermediate (Core), High-Yield, and 
International Fixed Income – includes investments traded on 
the secondary markets; prices are measured by using quoted 
market prices for similar securities, pricing models, and 
discounted cash flow analyses using significant inputs 
observable in the market where available, or a combination of 
multiple valuation techniques. This group of assets also includes 
highly liquid government securities such as U.S. Treasuries, 
limited partnerships valued at the NAV, registered investment 
companies and collective investment funds described above. 
Domestic, Global, International and Emerging Market 

Stocks – investments in exchange-traded equity securities are 
valued at quoted market values. This group of assets also 
includes investments in registered investment companies and 
collective investment funds described above. 

Real Estate – includes investments in real estate, which are 
valued at fair value based on an income capitalization valuation 
approach. Market values are estimates, and the actual market 
price of the real estate can only be determined by negotiation 
between independent third parties in sales transactions. This 
group of assets also includes investments in exchange-traded 
equity securities and collective investment funds described 
above. 

Hedge Funds / Absolute Return – includes investments in 
registered investment companies, and limited partnerships, as 
described above. 

Other – insurance contracts that are stated at cash 

surrender value. This group of assets also includes investments 
in registered investment companies and collective investment 
funds described above. 

The methods described above may produce a fair value 
calculation that may not be indicative of net realizable value or 
reflective of future fair values. While we believe our valuation 
methods are appropriate and consistent with other market 
participants, the use of different methodologies or assumptions 
to determine the fair value of certain financial instruments could 
result in a different fair value measurement at the reporting 
date. 

265

Wells Fargo & Company 

265 

  
 
  
 
 
 
 
 
 
 
 
Note 22:  Employee Benefits and Other Expenses (continued) 

Defined Contribution Retirement Plans 
We sponsor a qualified defined contribution retirement plan, the 
Wells Fargo & Company 401(k) Plan (401(k) Plan). Under the 
401(k) Plan, after one month of service, eligible employees may 
contribute up to 50% of their certified compensation, subject to 
statutory limits. Eligible employees who complete one year of 
service are eligible for quarterly company matching 
contributions, which are generally dollar for dollar up to 6% of 
an employee’s eligible certified compensation. Matching 
contributions are 100% vested. The 401(k) Plan includes an 
employer discretionary profit sharing contribution feature to 
allow us to make a contribution to eligible employees’ 401(k) 
Plan accounts for a plan year. Eligible employees who complete 
one year of service are eligible for profit sharing contributions. 
Profit sharing contributions are vested after three years of 
service. Total defined contribution retirement plan expenses 
were $1.2 billion in each of the following years, 2018, 2017 and 
2016. 

Other Expenses 
Table 22.10 presents expenses exceeding 1% of total interest 
income and noninterest income in any of the years presented 
that are not otherwise shown separately in the financial 
statements or Notes to Financial Statements. 

Table 22.10:  Other Expenses 

(in millions) 

Year ended December 31, 

2018 

2017 

2016 

Outside professional services 

$  3,306 

3,813 

3,138 

Operating losses 

Contract services (1) 

3,124 

2,192 

Credit card rewards and rebates (2) 

1,401 

Operating leases 

Outside data processing 

1,334 

660 

5,492 

1,638 

1,201 

1,351 

891 

1,608 

1,497 

1,047 

1,329 

888 

(1)  The periods prior to 2018 have been revised to conform with the current 

period presentation whereby temporary help is included in contract services 
rather than in all other noninterest expense. 

(2)  Noninterest income from card fees is net of cardholder rewards and rebates 

expense. 

266 

Wells Fargo & Company 

266

 
  
 
Note 23:  Income Taxes 

On December 22, 2017, the Tax Cuts & Jobs Act (Tax Act) was 
enacted resulting in significant changes to both domestic tax law 
and the U.S taxation of foreign subsidiaries. In 2018, we re-
measured our provisional estimates of the tax impacts that were 
recorded in 2017. As a result, during 2018 the Company 
recognized a $164 million discrete tax expense for adjustments 
to the provisional tax impacts of the Tax Act included in its 
consolidated financial statement for the year ended 
December 31, 2017. The accounting was completed in fourth 
quarter 2018. 

Table 23.1 presents the components of income tax expense. 

Table 23.1:  Income Tax Expense 

(in millions) 

Current: 

Federal 

State and local 

Foreign 

Total current 

Deferred: 

Federal 

State and local 

Foreign 

Total deferred 

Year ended December 31, 

2018 

2017 

2016 

$  2,382 

3,507 

1,140 

170 

3,692 

1,706 

236 

28 

1,970 

561 

183 

4,251 

156 

564 

(54) 

666 

6,712 

1,395 

175 

8,282 

1,498 

296 

(1) 

1,793 

Total 

$  5,662 

4,917 

10,075 

The tax effects of our temporary differences that gave rise to 

significant portions of our deferred tax assets and liabilities are 
presented in Table 23.2. 

Table 23.2:  Net Deferred Tax Liability 

(in millions) 

Deferred tax assets 

Dec 31, 

Dec 31, 

2018 

2017 

Allowance for loan losses 

$ 

2,644 

2,816 

Deferred compensation and employee

benefits 

Accrued expenses 

PCI loans 

Net unrealized losses on debt 

securities 

Net operating loss and tax credit carry

forwards 

Other 

Total deferred tax assets 

Deferred tax assets valuation 
allowance 

Deferred tax liabilities 

Mortgage servicing rights 

Leasing 

Basis difference in investments 

Mark to market, net 

Intangible assets 

Net unrealized gains on debt

securities 

Insurance reserves 

Other 

2,893 

815 

467 

1,022 

366 

1,272 

9,479 

2,377 

722 

1,057 

— 

341 

986 

8,299 

(315) 

(397) 

(3,475) 

(4,271) 

(1,203) 

(7,252) 

(427) 

— 

(696) 

(831) 

(3,421) 

(4,084) 

(577) 

(5,816) 

(539) 

(55) 

(750) 

(821) 

Total deferred tax liabilities 

(18,155) 

(16,063) 

Net deferred tax liability (1)  $ 

(8,991) 

(8,161) 

(1)  The net deferred tax liability is included in accrued expenses and other 

liabilities. 

267

Wells Fargo & Company 

267 

  
 
  
 
Note 23:  Income Taxes (continued) 

Deferred taxes related to net unrealized gains (losses) on 

debt securities, net unrealized gains (losses) on derivatives, 
foreign currency translation, and employee benefit plan 
adjustments are recorded in cumulative OCI (see Note 25 (Other 
Comprehensive Income)). These associated adjustments 
increased OCI by $1.1 billion in 2018. In 2018, we adopted ASU 
2018-02 – Income Statement-Reporting Comprehensive Income 
(Topic 220): Reclassification of Certain Tax Effects from 
Accumulated Other Comprehensive Income, and reclassified 
$400 million from OCI to retained earnings. See Note 1 
(Summary of Significant Accounting Policies) and Note 25 
(Other Comprehensive Income) for more information. 

We have determined that a valuation allowance is required 

for 2018 in the amount of $315 million, predominantly 
attributable to deferred tax assets in various state and foreign 
jurisdictions where we believe it is more likely than not that 
these deferred tax assets will not be realized. In these 
jurisdictions, carry back limitations, lack of sources of taxable 
income, and tax planning strategy limitations contributed to our 
conclusion that the deferred tax assets would not be realizable. 
We have concluded that it is more likely than not that the 
remaining deferred tax assets will be realized based on our 
history of earnings, sources of taxable income in carry back 
periods, and our ability to implement tax planning strategies. 

Table 23.3:  Effective Income Tax Expense and Rate 

At December 31, 2018, we had net operating loss carry 
forwards with related deferred tax assets of $366 million. If 
these carry forwards are not utilized, they will mostly expire in 
varying amounts through December 31, 2038. 

In 2018, we finalized the recognition of the U.S. tax expense 

associated with the deemed repatriation of undistributed 
earnings of certain non-U.S. subsidiaries as required under the 
2017 Tax Act. We do not intend to distribute these earnings in a 
taxable manner, and therefore intend to limit distributions to 
foreign earnings previously taxed in the U.S., that would qualify 
for the 100% dividends received deduction, and that would not 
result in any significant state or foreign taxes. All other 
undistributed foreign earnings will continue to be permanently 
reinvested outside the U.S. and the related tax liability on these 
earnings is insignificant. 

Table 23.3 reconciles the statutory federal income tax 
expense and rate to the effective income tax expense and rate. 
Our effective tax rate is calculated by dividing income tax 
expense by income before income tax expense less the net 
income from noncontrolling interests. 

(in millions) 

Amount 

Rate 

Amount 

Rate 

Amount 

2018 

2017 

2016 

Rate 

Statutory federal income tax expense and rate 

$  5,892 

21.0% 

$ 

9,485 

35.0% 

$ 

11,204 

35.0% 

December 31, 

Change in tax rate resulting from: 

State and local taxes on income, net of federal income tax 

benefit 

Tax-exempt interest 

Tax credits 

Non-deductible accruals 

 Tax reform 

Other 

1,076 

(494) 

(1,537) 

236 

164 

325 

3.9 

(1.8) 

(5.5) 

0.8 

0.6 

1.2 

926 

(812) 

(1,419) 

1,320 

3.4 

(3.0) 

(5.2) 

4.9 

(3,713) 

(13.7) 

1,004 

(725) 

(1,251) 

81 

— 

3.1 

(2.2) 

(3.9)

0.3

— 

(870) 

(3.3) 

(238) 

(0.8) 

Effective income tax expense and rate 

$  5,662 

20.2% 

$ 

4,917 

18.1% 

$ 

10,075 

31.5% 

The 2018 effective income tax rate was 20.2%, compared 

The 2017 effective income tax rate included an estimated 

with 18.1% in 2017 and 31.5% in 2016. The 2018 effective income 
tax rate reflected the reduction to the U.S. federal income tax 
rate from 35% to 21% resulting from the 2017 Tax Act. It also 
included income tax expense related to non-deductible litigation 
accruals and the reconsideration of reserves for state income 
taxes following the U.S. Supreme Court opinion in South Dakota 
v. Wayfair, Inc. In addition, we recognized $164 million of 
income tax expense associated with the final re-measurement of 
our initial estimates for the impacts of the Tax Act, in accordance 
with ASC Topic 740, Income Taxes and SEC Accounting 
Bulletin 118. 

impact of the Tax Act, including a benefit of $3.9 billion 
resulting from the re-measurement of the Company’s estimated 
net deferred tax liability as of December 31, 2017, partially offset 
by $173 million of income tax expense for the estimated deemed 
repatriation of the Company’s previously undistributed foreign 
earnings. The 2017 effective income tax rate also included 
income tax expense of $1.3 billion related to the effect of discrete 
non tax-deductible items, predominantly consisting of litigation 
accruals. The effective income tax rate for 2016 included net 
reductions in reserves for uncertain tax positions resulting from 
settlements with tax authorities, partially offset by a net increase 
in tax benefits related to tax credit investments. 

268 

Wells Fargo & Company 

268

  
 
Table 23.4 presents the change in unrecognized tax benefits. 

We are subject to U.S. federal income tax as well as income 

tax in numerous state and foreign jurisdictions. We are routinely 
examined by tax authorities in these various jurisdictions. The 
IRS is currently examining the 2013 through 2016 consolidated 
U.S. federal income tax returns of Wells Fargo & Company and 
its subsidiaries. In addition, we are currently subject to 
examination by various state, local and foreign taxing 
authorities. With few exceptions, Wells Fargo and its 
subsidiaries are not subject to federal, state, local and foreign 
income tax examinations for taxable years prior to 2007. 

We are litigating or appealing various issues related to prior 

IRS examinations for the periods 2003 through 2012. For the 
2003 through 2006 periods, we have paid the IRS the contested 
income tax and interest associated with these issues and refund 
claims have been filed for the respective years. It is possible that 
one or more of these examinations, appeals or litigation may be 
resolved within the next twelve months resulting in a decrease of 
up to $700 million to our gross unrecognized tax benefits. 

Table 23.4:  Change in Unrecognized Tax Benefits 

Year ended 
December 31, 

(in millions) 

2018 

Balance at beginning of year 

$ 

5,167 

2017 

5,029 

Additions: 

For tax positions related to the current 

year 

For tax positions related to prior years 

393 

503 

367 

158 

Reductions: 

For tax positions related to prior years 

(262) 

(319) 

Lapse of statute of limitations 

Settlements with tax authorities 

(7) 

(44) 

(48) 

(20) 

Balance at end of year 

$ 

5,750 

5,167 

Of the $5.8 billion of unrecognized tax benefits at 
December 31, 2018, approximately $3.9 billion would, if 
recognized, affect the effective tax rate. The remaining 
$1.9 billion of unrecognized tax benefits relates to income tax 
positions on temporary differences. 

We recognize interest and penalties related to unrecognized 

tax benefits as a component of income tax expense. As of 
December 31, 2018 and 2017, we have accrued approximately 
$968 million and $726 million, respectively, for the payment of 
interest and penalties. In 2018, we recognized in income tax 
expense a net tax expense related to interest and penalties of 
$200 million. In 2017, we recognized in income tax expense a 
net tax expense related to interest and penalties of $96 million. 

269

Wells Fargo & Company 

269 

  
 
Note 24:  Earnings and Dividends Per Common Share 

Table 24.1 shows earnings per common share and diluted 
earnings per common share and reconciles the numerator and 
denominator of both earnings per common share calculations. 
See Note 1 (Summary of Significant Accounting Policies) for 

discussion of private share repurchases, and the Consolidated 
Statement of Changes in Equity and Note 20 (Common Stock 
and Stock Plans) for information about stock and options 
activity and terms and conditions of warrants. 

Table 24.1:  Earnings Per Common Share Calculations 

(in millions, except per share amounts) 

Wells Fargo net income 

Less: Preferred stock dividends and other (1) 

Wells Fargo net income applicable to common stock (numerator) 

Earnings per common share 

Average common shares outstanding (denominator) 

Per share 

Diluted earnings per common share 

Average common shares outstanding 

Add:  Stock options 

Restricted share rights 

Warrants 

Diluted average common shares outstanding (denominator) 

Per share 

2018 

$ 

22,393 

1,704 

$ 

20,689 

Year ended December 31, 

2017 

22,183 

1,629 

20,554 

2016 

21,938 

1,565 

20,373 

4,799.7 

$

 4.31

4,964.6 

  4.14 

5,052.8 

4.03 

4,799.7 

4,964.6 

5,052.8 

8.0 

26.3 

4.4 

17.1 

24.7 

10.9 

18.9 

25.9 

10.7 

4,838.4 

5,017.3 

5,108.3 

$

 4.28

  4.10 

3.99 

(1)  The year ended December 31, 2018, includes $155 million as a result of eliminating the discount on our Series J Preferred Stock, which was redeemed on 

September 17, 2018. 

Table 24.2 presents the outstanding options to purchase 
shares of common stock that were anti-dilutive (the exercise 
price was higher than the weighted-average market price), and 
therefore not included in the calculation of diluted earnings per 
common share. 

Table 24.2:  Outstanding Anti-Dilutive Options 

(in millions) 

Options 

Weighted-average shares 

Year ended December 31, 

2018 

0.3 

2017 

1.9 

2016 

3.2 

Table 24.3 presents dividends declared per common share. 

Table 24.3:  Dividends Declared Per Common Share 

Per common share 

$  1.640 

2018 

Year ended December 31, 

2017 

1.540 

2016 

1.515 

270 

Wells Fargo & Company 

270

  
 
  
 
  
 
Note 25:  Other Comprehensive Income 

Table 25.1 provides the components of other comprehensive 
income (OCI), reclassifications to net income by income 
statement line item, and the related tax effects. 

Table 25.1:  Summary of Other Comprehensive Income 

(in millions)

Debt securities (1): 

Before 
 tax 

Tax 
effect 

2018 

Net of 
tax 

Before 
tax 

Tax 
effect 

Year ended December 31, 

2017 

Net of 
tax 

Before 
tax 

Tax 
effect 

2016 

Net of 
tax 

Net unrealized gains (losses) arising during the

period 

$(4,493) 

1,100 

(3,393) 

2,719 

(1,056) 

1,663 

(3,458) 

1,302 

(2,156) 

Reclassification of net (gains) losses to net

income: 

Interest income on debt securities (2) 

Net gains on debt securities 

Net gains from equity securities (3) 

Other noninterest income 

357 

(108) 

—

(1) 

(88) 

27 

—

— 

269 

(81) 

— 

(1) 

198 

(479) 

(456) 

— 

Subtotal reclassifications to net income 

248 

(61) 

187 

(737) 

(75) 

123 

7 

(3) 

4 

181 

172 

— 

278 

(298) 

(284) 

—

(942) 

(300) 

(5)

(459) 

(1,240) 

355 

113 

2

467 

(587) 

(187) 

(3) 

(773) 

Net change 

(4,245) 

1,039 

(3,206) 

1,982 

(778) 

1,204 

(4,698) 

1,769 

(2,929) 

Derivatives and hedging activities: 

Fair Value Hedges: 

Change in fair value of excluded

components on fair value hedges (4) 

Cash Flow Hedges: 

Net unrealized gains (losses) arising during

the period on cash flow hedges 

Reclassification of net (gains) losses to net

income: 

Interest income on loans 

Interest expense on long-term debt 

Subtotal reclassifications

 to net income 

Net change 

Defined benefit plans adjustments: 

Net actuarial and prior service gains (losses)

arising during the period 

Reclassification of amounts to noninterest 
expense and employee benefits (5): 

Amortization of net actuarial loss 

Settlements and other 

Subtotal reclassifications to noninterest 

expense and employee benefits 

Net change 

Foreign currency translation adjustments: 

Net unrealized gains (losses) arising during the

period 

Net change 

(254) 

63 

(191) 

(253) 

95 

(158) 

— 

— 

— 

(278) 

67 

(211) 

(287) 

108 

(179) 

177 

(67) 

110 

292 

2

294 

(238) 

(72) 

— 

220 

2 

(551) 

8 

(72) 

222 

(543) 

58 

(180) 

(1,083) 

208 

(3) 

205 

408 

(343) 

(1,043) 

5

14 

(338) 

(1,029) 

(675) 

(852) 

393 

(5) 

388 

321 

(650) 

9 

(641) 

(531) 

(434) 

106 

(328) 

49 

(12) 

37 

(52) 

(40) 

(92) 

127 

126 

253 

(181) 

(31) 

(29) 

96 

97 

(60) 

193 

46 

(135) 

(156) 

(156) 

1 

1 

(155) 

(155) 

150 

3

153 

202 

96 

96 

(57) 

 2

(55) 

(67) 

3

3

93 

 5

98 

135 

99 

99 

153 

 5

158 

106 

(57) 

(1)

(58) 

(98) 

(3) 

(3) 

4 

4 

96 

 4

100 

8 

1 

1 

Other comprehensive income (loss) 

$(4,820) 

1,144 

(3,676) 

1,197 

(434) 

763 

(5,447) 

1,996 

(3,451) 

Less: Other comprehensive loss from
noncontrolling interests, net of tax 

Wells Fargo other comprehensive income

(loss), net of tax 

(2) 

$(3,674) 

(62) 

825 

(17) 

(3,434) 

(1)  The years ended December 31, 2017 and 2016, include net unrealized gains (losses) arising during the period from equity securities of $81 million and $259 million and 

reclassification of net (gains) losses to net income related to equity securities of $(456) million and $(300) million, respectively. In connection with our adoption in first 
quarter 2018 of ASU 2016-01 – Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities, the year 
ended December 31, 2018, reflects net unrealized gains (losses) arising during the period and reclassification of net (gains) losses to net income from only debt securities. 

(2)  Represents net unrealized gains and losses amortized over the remaining lives of securities that were transferred from the available-for-sale portfolio to the held-to-

maturity portfolio. 

(3)  Net gains from equity securities is presented for table presentation purposes. After our adoption of ASU 2016-01 – Financial Instruments – Overall (Subtopic 825-10): 

Recognition and Measurement of Financial Assets and Financial Liabilities on January 1, 2018, this line will not contain balances as realized and unrealized gains and losses 
on marketable equity investments will be recorded in earnings. 

(4)  Represents changes in fair value of cross-currency swaps attributable to changes in cross-currency basis spreads, which are excluded from the assessment of hedge 

effectiveness and recorded in other comprehensive income. 

(5)  Effective January 1, 2018, we adopted ASU 2017-07 – Improving the Presentation of Net Periodic Pension Cost and Net Periodic Postretirement Benefit Cost. Accordingly, 

2018 balances are reclassified to other noninterest expense on the consolidated statement of income. For 2017 and 2016, these balances were reclassified to employee 
benefits. 

271

Wells Fargo & Company 

271 

  
 
 
 
 
Note 25:  Other Comprehensive Income (continued) 

Table 25.2 provides the cumulative OCI balance activity on 

an after-tax basis. 

Table 25.2:  Cumulative OCI Balances 

(in millions) 

Balance, December 31, 2015 

Net unrealized gains (losses) arising during the period 

Amounts reclassified from accumulated other comprehensive

income 

Net change 

Less: Other comprehensive loss from noncontrolling interests 

Balance, December 31, 2016 

Transition adjustment (2) 

Balance, January 1, 2017 

Net unrealized gains (losses) arising during the period 

Amounts reclassified from accumulated other comprehensive

income 

Net change 

Less: Other comprehensive income (loss) from noncontrolling

interests 

Balance, December 31, 2017 

Transition adjustment (3) 

Balance, January 1, 2018 

Reclassification of certain tax effects to retained 

earnings (4) 

Net unrealized losses arising during the period 

Amounts reclassified from accumulated other 

comprehensive income 

Net change 

Debt
securities (1)

$ 

1,813 

(2,156) 

(773) 

(2,929) 

(17)

(1,099)

— 

(1,099) 

1,663 

(459) 

1,204 

(66)

171 

(118) 

53 

31 

(3,393) 

187 

(3,175) 

Derivatives 
and 
 hedging 
 activities 

Defined 
benefit 
plans 
adjustments 

Foreign 
currency 
 translation 
adjustments 

Cumulative 
other 
comprehensive 
income (loss) 

620 

110 

(641) 

(531) 

 —

 89

168 

257 

(337) 

(338) 

(675) 

 —

(418) 

— 

(1,951) 

(92) 

100 

8 

 —

(1,943) 

— 

(1,943) 

37 

98 

135 

 —

(1,808) 

— 

(418) 

(1,808) 

(87) 

(402) 

222 

(267) 

(353) 

(328) 

193 

(488) 

(185) 

1 

— 

1 

 —

(184) 

— 

(184) 

99 

— 

99 

  4

(89) 

— 

(89) 

9 

(155) 

297 

(2,137) 

(1,314) 

(3,451) 

 (17)

(3,137) 

168 

(2,969) 

1,462 

(699) 

763 

 (62)

(2,144) 

(118) 

(2,262) 

(400) 

(4,278) 

— 

602 

(146) 

(4,076) 

(2) 

(233) 

(2)

(6,336) 

Less: Other comprehensive loss from noncontrolling

interests 

— 

— 

— 

Balance, December 31, 2018 

$ 

(3,122) 

(685) 

(2,296) 

(1)  The years ended December 31, 2017 and 2016, include net unrealized gains (losses) arising during the period from equity securities of $81 million and $259 million and 

reclassification of net (gains) losses to net income related to equity securities of $(456) million and $(300) million, respectively. In connection with our adoption in first 
quarter 2018 of ASU 2016-01 – Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities, the year 
ended December 31, 2018, reflects net unrealized gains (losses) arising during the period and reclassification of net (gains) losses to net income from only debt securities. 

(2)  Transition adjustment relates to our adoption of ASU 2017-12 – Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting for Hedging Activities. See 

Note 1 (Summary of Significant Accounting Policies) for more information. 

(3)  The transition adjustment relates to our adoption of ASU 2016-01 – Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets 

and Financial Liabilities. See Note 1 (Summary of Significant Accounting Policies) for more information. 

(4)  Represents the reclassification from other comprehensive income to retained earnings as a result of our adoption of ASU 2018-02 – Income Statement-Reporting 

Comprehensive Income (Topic 220): Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income in third quarter 2018. See Note 1 (Summary of 
Significant Accounting Policies) for more information. 

272 

Wells Fargo & Company 

272

  
 
 
 
 
 
Note 26:  Operating Segments 

We have three reportable operating segments: Community 
Banking; Wholesale Banking; and Wealth and Investment 
Management (WIM). We define our operating segments by 
product type and customer segment and their results are based 
on our management accounting process, for which there is no 
comprehensive, authoritative guidance equivalent to GAAP for 
financial accounting. The management accounting process 
measures the performance of the operating segments based on 
our management structure and is not necessarily comparable 
with similar information for other financial services companies. 
If the management structure and/or the allocation process 
changes, allocations, transfers and assignments may change. 
Effective first quarter 2018, we adopted a new funds transfer 
pricing methodology to allow for better comparability of 
performance across the Company. Under the new methodology, 
assets and liabilities receive a funding charge or credit that 
considers interest rate risk, liquidity risk, and other product 
characteristics on a more granular level. This methodology 
change affects results across all three of our reportable operating 
segments and prior period operating segment results have been 
revised to reflect this methodology change. Our previously 
reported consolidated financial results were not impacted by the 
methodology change; however, in connection with our adoption 
of ASU 2016-01 in first quarter 2018, certain reclassifications 
have occurred within noninterest income. 

Community Banking offers a complete line of diversified 
financial products and services for consumers and small 
businesses with annual sales generally up to $5 million in which 
the owner generally is the financial decision maker. These 
financial products and services include checking and savings 
accounts, credit and debit cards, and automobile, student, 
mortgage, home equity and small business lending, as well as 
referrals to Wholesale Banking and WIM business partners. 

Community Banking serves customers through a complete 

range of channels, including traditional and in-supermarket and 
other small format branches, ATMs, digital (online, mobile, and 
social), and contact centers (phone, email and correspondence). 
The Community Banking segment also includes the results 
of our Corporate Treasury activities net of allocations (including 
funds transfer pricing, capital, liquidity and certain corporate 
expenses) in support of other segments and results of 
investments in our affiliated venture capital and private equity 
partnerships. 

Wholesale Banking provides financial solutions to businesses 
across the United States with annual sales generally in excess of 
$5 million and to financial institutions globally. Wholesale 
Banking provides a complete line of commercial, corporate, 
capital markets, cash management and real estate banking 
products and services. These include traditional commercial 
loans and lines of credit, letters of credit, asset-based lending, 
equipment leasing, international trade facilities, trade financing, 
collection services, foreign exchange services, treasury 
management, merchant payment processing, institutional fixed-
income sales, interest rate, commodity and equity risk 
management, online/electronic products such as the 
Commercial Electronic Office® (CEO®) portal, corporate trust 
fiduciary and agency services, and investment banking services. 
Wholesale Banking also supports the CRE market with products 
and services such as construction loans for commercial and 
residential development, land acquisition and development 
loans, secured and unsecured lines of credit, interim financing 
arrangements for completed structures, rehabilitation loans, 
affordable housing loans and letters of credit, permanent loans 
for securitization, CRE loan servicing and real estate and 
mortgage brokerage services. 

Wealth and Investment Management provides a full range 
of personalized wealth management, investment and retirement 
products and services to clients across U.S. based businesses 
including Wells Fargo Advisors, The Private Bank, Abbot 
Downing, Wells Fargo Institutional Retirement and Trust, and 
Wells Fargo Asset Management. We deliver financial planning, 
private banking, credit, investment management and fiduciary 
services to high-net worth and ultra-high-net worth individuals 
and families. We also serve clients’ brokerage needs, supply 
retirement and trust services to institutional clients and provide 
investment management capabilities delivered to global 
institutional clients through separate accounts and the 
Wells Fargo Funds. 

Other includes the elimination of certain items that are 
included in more than one business segment, most of which 
represents products and services for Wealth and Investment 
Management customers served through Community Banking 
distribution channels. 

273

Wells Fargo & Company 

273 

 
 
 
 
Note 26:  Operating Segments (continued) 

Table 26.1 presents our results by operating segment. 

Table 26.1:  Operating Segments 

(income/expense in millions, average balances in billions)

2018 

Community 
 Banking 

Wholesale 
Banking 

Wealth and 
Investment 
Management 

Other (1) 

Consolidated 
 Company 

Net interest income (2) 

$ 

29,219 

18,690 

Provision (reversal of provision) for credit losses 

Noninterest income 

Noninterest expense 

Income (loss) before income tax expense (benefit) 

Income tax expense (benefit) 

Net income (loss) before noncontrolling interests 

Less: Net income from noncontrolling interests 

Net income (loss) (3) 

2017 (4) 

Net interest income (2) 

Provision (reversal of provision) for credit losses 

Noninterest income 

Noninterest expense 

Income (loss) before income tax expense (benefit) 

Income tax expense (benefit) 

Net income (loss) before noncontrolling interests 

Less: Net income (loss) from noncontrolling interests 

Net income (loss) (3) 

2016 (4) 

Net interest income (2) 

Provision (reversal of provision) for credit losses 

Noninterest income 

Noninterest expense 

Income (loss) before income tax expense (benefit) 

Income tax expense (benefit) 

Net income (loss) before noncontrolling interests 

Less: Net income (loss) from noncontrolling interests 

Net income (loss) (3) 

2018 

Average loans 

Average assets 

Average deposits 

2017 (4) 

Average loans 

Average assets 

Average deposits 

1,783 

17,694 

30,491 

14,639 

3,784 

10,855 

461 

(58) 

10,016 

16,157 

12,607 

1,555 

11,052 

20 

$ 

10,394 

11,032 

$ 

28,658 

18,810 

2,555 

18,360 

32,615 

11,848 

634 

11,214 

276 

10,938 

27,333 

2,691 

19,180 

27,655 

16,167 

5,213 

10,954 

136 

10,818 

463.7 

1,034.1 

757.2 

475.7 

1,085.5 

729.6 

$ 

$ 

$ 

$ 

(19) 

11,190 

16,624 

13,395 

3,496 

9,899 

(15) 

9,914 

18,699 

1,073 

12,348 

15,901 

14,073 

4,159 

9,914 

(28) 

9,942 

465.7 

830.5 

423.7 

465.6 

822.8 

464.2 

4,441 

(5)

11,935 

12,938 

3,443 

861 

2,582 

2 

2,580 

4,641 

(5) 

12,431 

12,623 

4,454 

1,668 

2,786 

16 

2,770 

4,249 

(5) 

12,029 

12,051 

4,232 

1,596 

2,636 

(1) 

2,637 

74.6 

83.9 

165.0 

71.9 

82.8 

189.0 

(2,355) 

 24

(3,232) 

(3,460) 

(2,151) 

(538) 

(1,613) 

— 

49,995 

 1,744 

36,413 

56,126 

28,538 

5,662 

22,876 

483 

(1,613) 

22,393 

(2,552) 

(3) 

(3,149) 

(3,378) 

(2,320) 

(881) 

(1,439) 

— 

(1,439) 

(2,527) 

11 

(3,044) 

(3,230) 

(2,352) 

(893) 

(1,459) 

— 

(1,459) 

(58.8) 

(59.6) 

(70.0) 

(57.1) 

(58.1) 

(78.2) 

49,557 

2,528 

38,832 

58,484 

27,377 

4,917 

22,460 

277 

22,183 

47,754 

3,770 

40,513 

52,377 

32,120 

10,075 

22,045 

107 

21,938 

945.2 

1,888.9 

1,275.9 

956.1 

1,933.0 

1,304.6 

(1) 

Includes the elimination of certain items that are included in more than one business segment, most of which represents products and services for Wealth and Investment 
Management customers served through Community Banking distribution channels. 

(2)  Net interest income is the difference between interest earned on assets and the cost of liabilities to fund those assets. Interest earned includes actual interest earned on 

segment assets as well as as interest credits for any funding of a segment available to be provided to other segments. The cost of liabilities includes actual interest expense 
on segment liabilities as well as funding charges for any funding provided from other segments. 

(3)  Represents segment net income (loss) for Community Banking; Wholesale Banking; and Wealth and Investment Management segments and Wells Fargo net income for the 

consolidated company. 

(4)  Prior period operating segment results have been revised to reflect a methodology change of allocating funding charges and credits. 

274 

Wells Fargo & Company 

274

  
 
Note 27:  Parent-Only Financial Statements 

The following tables present Parent-only condensed financial 
statements. 

Table 27.1:  Parent-Only Statement of Income 

(in millions) 

Income 

Dividends from subsidiaries (1) 

Interest income from subsidiaries 

Other interest income 

Other income 

Total income 

Expense 

Interest expense: 

Indebtedness to nonbank subsidiaries 

Short-term borrowings 

Long-term debt 

Other 

Noninterest expense 

Total expense 

Income before income tax benefit and 

equity in undistributed income of subsidiaries 

Income tax benefit 

Equity in undistributed income of subsidiaries 

Year ended December 31, 

2018 

2017 

2016 

$ 

22,427 

3,298 

49 

(424) 

25,350 

644 

2 

4,541 

3 

286 

5,476 

19,874 

(544) 

1,975 

20,746 

1,984 

146 

1,238 

24,114 

189 

—

3,595 

5 

1,888 

5,677 

18,437 

(319) 

3,427 

22,183 

12,776 

1,615 

155 

177 

14,723 

387 

— 

2,619 

19 

1,300 

4,325 

10,398 

(1,152) 

10,388 

21,938 

Net income 

$ 

22,393 

(1) 

Includes dividends paid from indirect bank subsidiaries of $20.8 billion, $17.9 billion and $12.5 billion in 2018, 2017 and 2016, respectively. 

Table 27.2:  Parent-Only Statement of Comprehensive Income 

Year ended December 31, 

(in millions) 

Net income 

Other comprehensive income (loss), net of tax: 

Debt securities (1) 

Derivatives and hedging activities 

Defined benefit plans adjustment 

Equity in other comprehensive income (loss) of subsidiaries 

Other comprehensive income (loss), net of tax: 

2018 

$ 

22,393 

2017 

22,183 

(12) 

(198) 

(132) 

(3,332) 

(3,674) 

94 

(158) 

118 

771 

825 

Total comprehensive income 

$ 

18,719 

23,008 

2016 

21,938 

(76) 

— 

(20) 

(3,338) 

(3,434) 

18,504 

(1)  The years ended December 31, 2017 and 2016, includes net unrealized gains arising during the period from equity securities of $3 million and $7 million and 

reclassification of net (gains) to net income related to equity securities of $(21) million and $(30) million, respectively. In connection with our adoption in first quarter 2018 
of ASU 2016-01 – Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities, the year ended 
December 31, 2018, reflects net unrealized gains (losses) arising during the period and reclassification of net (gains) losses to net income from only debt securities. 

275

Wells Fargo & Company 

275 

  
 
  
 
Note 27:  Parent-Only Financial Statements (continued) 

Table 27.3:  Parent-Only Balance Sheet 

(in millions) 

Assets 

Cash, cash equivalents, and restricted cash due from (1): 

Subsidiary banks 

Nonaffiliates 

Debt securities: 

Trading, at fair value (2) 

Available-for-sale, at fair value (2) 

Loans to nonbank subsidiaries 

Investments in subsidiaries (3) 

Equity securities (2) 

Other assets (2) 

Total assets 

Liabilities and equity 

Accrued expenses and other liabilities 

Long-term debt 

Indebtedness to nonbank subsidiaries 

Total liabilities 

Stockholders’ equity 

Total liabilities and equity 

Dec 31, 

2018 

Dec 31, 

2017 

$ 

16,301 

23,180 

— 

— 

1 

139,163 

202,695 

2,164 

4,639 

1 

24 

5 

138,681 

206,367 

2,414 

4,731 

$ 

364,963 

375,403 

$ 

6,986  $ 

7,902 

135,079 

26,732 

168,797 

196,166 

$ 

364,963 

146,130 

14,435 

168,467 

206,936 

375,403 

(1)  Financial information has been revised to reflect the impact of our adoption in first quarter 2018 of ASU 2016-18 – Statement of Cash Flows (Topic 230): Restricted Cash in 

which we changed the presentation of our cash and cash equivalents to include both cash and due from banks as well as interest-earning deposits with banks, which are 
inclusive of restricted cash. See Note 1 (Summary of Significant Accounting Policies) for more information. 

(2)  Financial information for the prior period has been revised to reflect presentation changes made in connection with our adoption in first quarter 2018 of ASU 2016-01 – 
Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities. See Note 1 (Summary of Significant 
Accounting Policies) for more information. 

(3)  The years ended December 31, 2018, and December 31, 2017, include indirect ownership of bank subsidiaries with equity of $167.6 billion and $170.5 billion, respectively. 

276 

Wells Fargo & Company 

276

  
 
 
Table 27.4:  Parent-Only Statement of Cash Flows 

(in millions) 

Cash flows from operating activities: 

Year ended December 31, 

2018 

2017 

2016 

Net cash provided by operating activities (1) 

$ 

19,024 

22,233 

10,654 

Cash flows from investing activities: 

Available-for-sale debt securities: 

Proceeds from sales:

 Subsidiary banks 

 Nonaffiliates (1) 

Prepayments and maturities:

 Subsidiary banks 

Purchases: 

Subsidiary banks 

Nonaffiliates 

Equity securities, not held for trading: 

Proceeds from sales and capital returns (1) 

Purchases (1) 

Loans: 

Net repayments from (advances to) subsidiaries 

Capital notes and term loans made to subsidiaries 

Principal collected on notes/loans made to subsidiaries 

Net decrease (increase) in investment in subsidiaries 

Other, net 

Net cash provided (used) by investing activities 

Cash flows from financing activities: 

— 

— 

— 

— 

— 

355 

(220) 

(7) 

(2,441) 

756 

2,407 

109 

959 

8,658 

8,824 

—

5,201 

10,250 

15,000 

(3,900) 

— 

743 

(215) 

(35,876) 

(73,729) 

69,286 

(2,029) 

113 

(15,000) 

(6,544) 

583 

(314) 

3,174 

(32,641) 

15,164 

(606) 

18 

(17,875) 

(15,965) 

Net increase (decrease) in short-term borrowings and indebtedness to subsidiaries 

12,467 

(8,685) 

789 

Long-term debt: 

Proceeds from issuance 

Repayment 

Preferred stock: 

Proceeds from issuance 

Redeemed 

Cash dividends paid 

Common stock: 

Proceeds from issuance 

Stock tendered for payment of withholding taxes 

Repurchased 

Cash dividends paid 

Other, net 

Net cash provided (used) by financing activities 

Net change in cash, cash equivalents, and restricted cash (2) 

Cash, cash equivalents, and restricted cash at beginning of year (2) 

1,876 

(9,162) 

— 

(2,150) 

(1,622) 

632 

(331) 

(20,633) 

(7,692) 

(248) 

(26,863) 

(6,880) 

23,181 

Cash, cash equivalents, and restricted cash at end of year (2) 

$ 

16,301 

22,217 

(13,709) 

34,362 

(15,096) 

677 

—

(1,629) 

1,211 

(393) 

(9,908) 

(7,480) 

(138) 

(17,837) 

(13,479) 

36,660 

23,181 

2,101 

— 

(1,566) 

1,415 

(494) 

(8,116) 

(7,472) 

(118) 

5,805 

494 

36,166 

36,660 

(1)  Financial information for the prior period has been revised to reflect presentation changes made in connection with our adoption in first quarter 2018 of ASU 2016-01 – 
Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities. See Note 1 (Summary of Significant 
Accounting Policies) for more information. 

(2)  Financial information has been revised to reflect the impact of our adoption in first quarter 2018 of ASU 2016-18 – Statement of Cash Flows (Topic 230): Restricted Cash in 

which we changed the presentation of our cash and cash equivalents to include both cash and due from banks as well as interest-earning deposits with banks, which are 
inclusive of restricted cash. See Note 1 (Summary of Significant Accounting Policies) for more information. 

277

Wells Fargo & Company 

277 

  
 
Note 28:  Regulatory and Agency Capital Requirements 

The Company and each of its subsidiary banks are subject to 
regulatory capital adequacy requirements promulgated by 
federal bank regulatory agencies. The Federal Reserve 
establishes capital requirements for the consolidated financial 
holding company, and the OCC has similar requirements for the 
Company’s national banks, including Wells Fargo Bank, N.A. 
(the Bank). 

Table 28.1 presents regulatory capital information for 
Wells Fargo & Company and the Bank using Basel III, which 
increased minimum required capital ratios, and introduced a 
minimum Common Equity Tier 1 (CET1) ratio. We must report 
the lower of our CET1, tier 1 and total capital ratios calculated 
under the Standardized Approach and under the Advanced 
Approach in the assessment of our capital adequacy. The 
Standardized Approach applies assigned risk weights to broad 
risk categories, while the calculation of risk-weighted assets 
(RWAs) under the Advanced Approach differs by requiring 
applicable banks to utilize a risk-sensitive methodology, which 
relies upon the use of internal credit models, and includes an 
operational risk component. The Basel III capital rules are being 

Table 28.1:  Regulatory Capital Information 

phased-in effective January 1, 2014, through the end of 2021. 
Beginning January 1, 2018, the requirements for calculating 
CET1 and tier 1 capital, along with RWAs, became fully phased-
in. Accordingly, the information presented reflects fully phased-
in CET1 capital, tier 1 capital, and RWAs, but reflects total 
capital still in accordance with Transition Requirements. 

The Bank is an approved seller/servicer of mortgage loans 

and is required to maintain minimum levels of shareholders’ 
equity, as specified by various agencies, including the United 
States Department of Housing and Urban Development, GNMA, 
FHLMC and FNMA. At December 31, 2018, the Bank met these 
requirements. Other subsidiaries, including the Company’s 
insurance and broker-dealer subsidiaries, are also subject to 
various minimum capital levels, as defined by applicable 
industry regulations. The minimum capital levels for these 
subsidiaries, and related restrictions, are not significant to our 
consolidated operations. 

December 31, 2018 

December 31, 2017 

December 31, 2018 

December 31, 2017 

Wells Fargo & Company 

Wells Fargo Bank, N.A. 

Advanced 
Approach 

Standardized 
Approach 

Advanced 
Approach 

Standardized 
Approach 

Advanced 
Approach 

Standardized 
Approach 

Advanced 
Approach 

Standardized 
Approach 

(in millions, except ratios) 

Regulatory capital: 

Common equity tier 1 

$  146,363 

146,363 

Tier 1 

Total 

Assets: 

167,866 

167,866 

198,798 

207,041 

154,765 

178,209 

210,333 

154,765 

178,209 

220,097 

142,685 

142,685 

142,685 

142,685 

155,558 

163,380 

143,292 

143,292 

156,661 

143,292 

143,292 

165,734 

Risk-weighted assets 

$ 1,177,350 

1,247,210 

1,199,545 

1,260,663 

1,058,653 

1,154,182 

1,090,360 

1,169,863 

Adjusted average assets (1) 

1,850,299 

1,850,299 

1,905,568 

1,905,568 

1,652,009 

1,652,009 

1,708,828 

1,708,828 

Regulatory capital ratios: 

Common equity tier 1

capital 

Tier 1 capital 

Total capital 

Tier 1 leverage (1) 

12.43% 

11.74  * 

14.26 

16.89 

9.07 

13.46  * 

16.60  * 

9.07 

12.90 

14.86 

17.53 

9.35 

12.28  * 

14.14  * 

17.46  * 

9.35 

13.48 

13.48 

14.69 

8.64 

12.36  * 

12.36  * 

14.16  * 

8.64 

13.14 

13.14 

14.37 

8.39 

12.25  * 

12.25  * 

14.17  * 

8.39 

*Denotes the lowest capital ratio as determined under the Advanced and Standardized Approaches. 
(1)  The leverage ratio consists of Tier 1 capital divided by quarterly average total assets, excluding goodwill and certain other items. 

Table 28.2 presents the minimum required regulatory 
capital ratios under Transition Requirements to which the 
Company and the Bank were subject as of December 31, 2018, 
and December 31, 2017. 

Table 28.2:  Minimum Required Regulatory Capital Ratios – Transition Requirements (1) 

Regulatory capital ratios: 

Common equity tier 1 capital 

Tier 1 capital 

Total capital 

Tier 1 leverage 

December 31, 2018 

December 31, 2017 

December 31, 2018 

December 31, 2017 

Wells Fargo & Company 

Wells Fargo Bank, N.A. 

7.875% 

9.375 

11.375 

4.000 

6.750 

8.250 

10.250 

4.000 

6.375 

7.875 

9.875 

4.000 

5.750 

7.250 

9.250 

4.000 

(1)  At December 31, 2018, under transition requirements, the CET1, tier 1 and total capital minimum ratio requirements for Wells Fargo & Company include a capital 

conservation buffer of 1.875% and a global systemically important bank (G-SIB) surcharge of 1.500%. Only the 1.875% capital conservation buffer applies to the Bank at 
December 31, 2018. 

278 

Wells Fargo & Company 

278

 
  
 
  
 
  
  
Report of Independent Registered Public Accounting Firm 

The Stockholders and Board of Directors 
Wells Fargo & Company: 

Opinion on the Consolidated Financial Statements 

We have audited the accompanying consolidated balance sheets of Wells Fargo & Company and Subsidiaries (the Company) as of 
December 31, 2018 and 2017, the related consolidated statements of income, comprehensive income, changes in equity, and cash flows 
for each of the years in the three-year period ended December 31, 2018, and the related notes (collectively, the consolidated financial 
statements). In our opinion, the consolidated financial statements present fairly, in all material respects, the financial position of the 
Company as of December 31, 2018 and 2017, and the results of its operations and its cash flows for each of the years in the three-year 
period ended December 31, 2018, in conformity with U.S. generally accepted accounting principles. 

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), 
the Company’s internal control over financial reporting as of December 31, 2018, based on criteria established in Internal Control – 
Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission, and our report 
dated February 27, 2019, expressed an unqualified opinion on the effectiveness of the Company’s internal control over financial 
reporting. 

Basis for Opinion 

These consolidated financial statements are the responsibility of the Company’s management. Our responsibility is to express an 
opinion on these consolidated financial statements based on our audits. We are a public accounting firm registered with the PCAOB and 
are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules 
and regulations of the Securities and Exchange Commission and the PCAOB. 

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit 
to obtain reasonable assurance about whether the consolidated financial statements are free of material misstatement, whether due to 
error or fraud. Our audits included performing procedures to assess the risks of material misstatement of the consolidated financial 
statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, 
on a test basis, evidence regarding the amounts and disclosures in the consolidated financial statements. Our audits also included 
evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation 
of the consolidated financial statements. We believe that our audits provide a reasonable basis for our opinion. 

We have served as the Company’s auditor since 1931. 

San Francisco, California 
February 27, 2019 

279

Wells Fargo & Company 

279 

 
 
Quarterly Financial Data 
Condensed Consolidated Statement of Income - Quarterly (Unaudited) 

2018 

Quarter ended 

2017 

Quarter ended 

(in millions, except per share amounts) 

Dec 31, 

Sep 30, 

Jun 30,  Mar 31, 

Dec 31, 

Sep 30, 

Jun 30, 

Mar 31, 

Interest income 

Interest expense 

Net interest income 

Provision for credit losses 

$16,921 

16,364 

16,015 

15,347 

14,958 

15,044 

14,694 

14,213 

4,277 

3,792 

3,474 

3,109 

2,645 

2,595 

2,223 

1,889 

12,644 

12,572 

12,541 

12,238 

12,313 

12,449 

12,471 

12,324 

521 

580 

452 

191 

651 

717 

555 

605 

Net interest income after provision for credit losses 

12,123 

11,992 

12,089 

12,047 

11,662 

11,732 

11,916 

11,719 

Noninterest income 

Service charges on deposit accounts 

Trust and investment fees 

Card fees 

Other fees 

Mortgage banking 

Insurance 

Net gains (losses) from trading activities (1) 

Net gains on debt securities 

Net gains from equity securities (1) 

Lease income 

Other 

Total noninterest income 

Noninterest expense 

Salaries 

Commission and incentive compensation 

Employee benefits 

Equipment 

Net occupancy 

Core deposit and other intangibles 

FDIC and other deposit assessments 

1,176 

3,520 

981 

888 

467 

109 

10 

957

21 

402 

753 

1,204 

3,631 

1,017 

1,163 

3,675 

1,001 

850 

846 

104 

158 

416 

453 

633 

846 

770 

102 

191 

41

295 

443 

485 

1,173 

3,683 

1,246 

3,687 

908 

800 

934 

114 

243 

  1

783 

455 

602 

996 

913 

928 

223 

(1) 

 157 

572 

458 

558 

1,276 

3,609 

1,000 

877 

1,276 

3,629 

1,019 

902 

1,313 

3,570 

945 

865 

1,046 

1,148 

1,228 

269 

120 

166 

363 

475 

199 

280 

151 

120 

274 

493 

472 

277 

272 

36 

570 

481 

374 

8,336 

9,369 

9,012 

9,696 

9,737 

9,400 

9,764 

9,931 

4,545 

2,427 

706 

643 

735 

264 

153 

4,461 

2,427 

1,377 

634 

718 

264 

336 

4,465 

2,642 

1,245 

550 

722 

265 

297 

4,363 

2,768 

1,598 

617 

713 

265 

324 

4,403 

2,665 

1,293 

608 

715 

288 

312 

4,356 

2,553 

1,279 

523 

716 

288 

314 

4,343 

2,499 

1,308 

529 

706 

287 

328 

4,261 

2,725 

1,686 

577 

712 

289 

333 

Other 

3,866 

3,546 

3,796 

4,394 

6,516 

4,322 

3,541 

3,209 

Total noninterest expense 

13,339 

13,763 

13,982 

15,042 

16,800 

14,351 

13,541 

13,792 

Income before income tax expense 

Income tax expense (benefit) 

7,120 

966 

7,598 

1,512 

7,119 

1,810 

6,701 

1,374 

4,599 

(1,642) 

Net income before noncontrolling interests 

6,154 

6,086 

5,309 

5,327 

6,241 

Less: Net income from noncontrolling interests 

90 

79 

123 

191 

90 

6,781 

2,181 

4,600 

58 

8,139 

2,245 

5,894 

38 

7,858 

2,133 

5,725 

91 

Wells Fargo net income 

$  6,064 

6,007 

5,186 

5,136 

6,151 

4,542 

5,856 

5,634 

Less: Preferred stock dividends and other 

353 

554 

394 

403 

411 

411 

406 

401 

Wells Fargo net income applicable to common

stock 

Per share information 

Earnings per common share 

Diluted earnings per common share 

$  5,711 

5,453 

4,792 

4,733 

5,740 

4,131 

5,450 

5,233 

$  1.22 

1.21 

1.14 

1.13 

0.98 

0.98 

0.97 

0.96 

1.17 

1.16 

0.83 

0.83 

1.09 

1.08 

1.05 

1.03 

Average common shares outstanding 

4,665.8 

4,784.0 

4,865.8 

4,885.7 

4,912.5 

4,948.6 

4,989.9 

5,008.6 

Diluted average common shares outstanding 

4,700.8 

4,823.2 

4,899.8 

4,930.7 

4,963.1 

4,996.8 

5,037.7 

5,070.4 

(1)  Financial information for the prior periods of 2017 has been revised to reflect presentation changes made in connection with our adoption in first quarter 2018 of 

Accounting Standards Update (ASU) 2016-01 – Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial 
Liabilities. See Note 1 (Summary of Significant Accounting Policies) for more information. 

280 

Wells Fargo & Company 

280

 
Average Balances, Yields and Rates Paid (Taxable-Equivalent basis) - Quarterly (1)(2) - (Unaudited) 

(in millions) 

Earning assets 
Interest-earning deposits with banks (3) 
Federal funds sold and securities purchased under resale agreements (3) 
Debt securities (4): 

Trading debt securities (5) 
Available-for-sale debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
Mortgage-backed securities: 

Federal agencies 
Residential and commercial 
Total mortgage-backed securities 

Other debt securities (5) 

Total available-for-sale debt securities (5) 

Held-to-maturity debt securities: 

Securities of U.S. Treasury and federal agencies 
Securities of U.S. states and political subdivisions 
Federal agency and other mortgage-backed securities 
Other debt securities 

Total held-to-maturity debt securities 

Total debt securities (5) 

Mortgages loans held for sale (6) 
Loans held for sale (5)(6) 

Commercial loans: 

Commercial and industrial - U.S. 
Commercial and industrial - Non-U.S. 
Real estate mortgage 
Real estate construction 
Lease financing 

Total commercial loans 

Consumer loans: 

Real estate 1-4 family first mortgage 
Real estate 1-4 family junior lien mortgage 
Credit card 
Automobile 
Other revolving credit and installment 

Total consumer loans 

Total loans (6) 

Equity securities (5) 
Other (5) 

Total earning assets (5) 

Funding sources 
Deposits: 

Interest-bearing checking 
Market rate and other savings 
Savings certificates 
Other time deposits 
Deposits in foreign offices 

Total interest-bearing deposits 

Short-term borrowings 
Long-term debt 
Other liabilities 

Total interest-bearing liabilities 

Portion of noninterest-bearing funding sources (5) 

Total funding sources (5) 

Net interest margin and net interest income on a taxable-equivalent basis (7) 
Noninterest-earning assets 
Cash and due from banks 
Goodwill 
Other (5) 

Total noninterest-earning assets (5) 

Noninterest-bearing funding sources 
Deposits 
Other liabilities 
Total equity 
Noninterest-bearing funding sources used to fund earning assets (5) 

Net noninterest-bearing funding sources (5) 

Total assets 

Average
balance 

Yields/ 
rates 

2018 

Interest 
income/ 
expense 

Quarter ended December 31, 
2017 

Average
balance 

Yields/ 
rates 

Interest 
income/ 
expense 

$  150,091 
76,108 

2.18%  $ 
2.22 

825 
426 

189,114 
75,826 

1.27%  $ 
1.20% 

90,110 

3.52 

794 

81,580 

3.17 

605 
230 

647 

27 
513 

1,000 
114 
1,114 
443 
2,097 

246 
83 
503 
8 
840 
3,584 
196 
12 

2,649 
442 
1,244 
270 
31 
4,636 

1.66 
3.91 

2.62 
4.85 
2.75 
3.62 
3.10 

2.19 
5.26 
2.25 
2.64 
2.36 
2.90 
3.82 
3.19 

3.89 
2.96 
3.88 
4.38 
0.62 
3.68 

2,826 
4.01 
505 
4.96 
1,136 
12.37 
702 
5.13 
607 
6.28 
5,776 
5.10 
10,412 
4.35 
246 
2.60 
0.88 
16 
3.43%  $  15,301 

86 
0.68%  $ 
319 
0.19 
17 
0.31 
255 
1.49 
254 
0.81 
931 
0.39 
256 
0.99 
1,344 
2.32 
115 
1.86 
2,646 
0.81 
— 
— 
0.59 
2,646 
2.84%  $  12,655 

7,195 
47,618 

155,322 
6,666 
161,988 
46,072 
262,873 

44,747 
6,247 
95,748 
68 
146,810 
499,793 
17,044 
1,992 

281,431 
62,035 
120,404 
23,090 
19,519 
506,479 

1.80 
4.05 

2.91 
4.87 
2.99 
4.46 
3.41 

2.19 
4.34 
2.46 
3.65 
2.46 
3.15 
4.46 
6.69 

4.40 
3.73 
4.51 
5.32 
4.48 
4.39 

32 
483 

1,128 
81 
1,209 
518 
2,242 

247 
67 
589 
1 
904 
3,940 
190 
33 

3,115 
584 
1,369 
310 
219 
5,597 

285,260 
34,844 
37,858 
45,536 
36,359 
439,857 
946,336 
37,412 
4,074 
$ 1,732,850 

2,868 
4.02 
491 
5.60 
1,211 
12.69 
592 
5.16 
637 
6.95 
5,799 
5.25 
11,396 
4.79 
261 
2.79 
1.78 
18 
3.93%  $ 17,089 

165 
1.21%  $ 
741 
0.43 
48 
0.87 
575 
2.46 
236 
1.66 
1,765 
0.77 
546 
2.04 
1,802 
3.17 
164 
2.41 
4,277 
1.34 
— 
— 
0.99 
4,277 
2.94%  $ 12,812 

$ 

53,983 
689,639 
21,955 
92,676 
56,098 
914,351 
105,962 
226,591 
27,365 
1,274,269 
458,581 
$ 1,732,850 

$ 

19,288 
26,423 
100,486 
$  146,197 

$  354,597 
51,739 
198,442 
(458,581) 

$  146,197 

$ 1,879,047 

6,423 
52,390 

152,910 
9,371 
162,281 
48,679 
269,773 

44,716 
6,263 
89,622 
1,194 
141,795 
493,148 
20,517 
1,490 

270,294 
59,233 
127,199 
24,408 
19,226 
500,360 

281,966 
40,379 
36,428 
54,323 
38,366 
451,462 
951,822 
38,001 
7,103 
1,777,021 

50,483 
679,893 
20,920 
68,187 
124,597 
944,080 
102,142 
231,598 
24,728 
1,302,548 
474,473 
1,777,021 

19,152 
26,579 
112,566 
158,297 

367,512 
57,845 
207,413 
(474,473) 
158,297 

1,935,318 

(1)  Our average prime rate was 5.28% and 4.30% for the quarters ended December 31, 2018 and 2017, respectively. The average three-month London Interbank Offered 

Rate (LIBOR) was 2.62% and 1.46% for the same quarters, respectively. 

(2)  Yield/rates and amounts include the effects of hedge and risk management activities associated with the respective asset and liability categories. 
(3)  Financial information for the prior period has been revised to reflect the impact of our adoption of Accounting Standards Update (ASU) 2016-18 – Statement of Cash Flows 

(Topic 230): Restricted Cash in which we changed the presentation of our cash and cash equivalents to include both cash and due from banks as well as interest-earning 
deposits with banks, which are inclusive of any restricted cash. 

(4)  Yields and rates are based on interest income/expense amounts for the period, annualized based on the accrual basis for the respective accounts. The average balance 

amounts represent amortized cost for the periods presented. 

(5)  Financial information for the prior period has been revised to reflect presentation changes made in connection with our adoption in first quarter 2018 of ASU 2016-01 – 

Financial Instruments – Overall (Subtopic 825-10): Recognition and Measurement of Financial Assets and Financial Liabilities. 

(6)  Nonaccrual loans and related income are included in their respective loan categories. 
(7) 

Includes taxable-equivalent adjustments of $168 million and $342 million for the quarters ended December 31, 2018 and 2017, respectively, predominantly related to tax-
exempt income on certain loans and securities. The federal statutory tax rate was 21% and 35% for the periods ended December 31, 2018 and 2017, respectively. 

281

Wells Fargo & Company 

281 

 
 
Glossary of Acronyms 

ABS 

ACL 

ALCO 

ARM 

ASC 

ASU 

AUA 

AUM 

AVM 

BCBS 

BHC 

CCAR 

CD 

CDO 

CDS 

CECL 

CET1 

CFPB 

CLO 

CLTV 

CMBS 

CPI 

CPP 

CRE 

DPD 

ESOP 

FAS 

FASB 

FDIC 

FICO 

FNMA 

FRB 

GAAP 

Asset-backed security 

Allowance for credit losses 

Asset/Liability Management Committee 

Adjustable-rate mortgage 

Accounting Standards Codification 

Accounting Standards Update 

HAMP 

Home Affordability Modification Program 

HUD 

LCR 

LHFS 

LIBOR 

LIHTC 

U.S. Department of Housing and Urban Development 

Liquidity coverage ratio 

Loans held for sale 

London Interbank Offered Rate 

Low income housing tax credit 

Assets under administration 

LOCOM 

Lower of cost or market value 

Assets under management 

Automated valuation model 

Basel Committee on Bank Supervision 

LTV 

MBS 

MHA 

Loan-to-value 

Mortgage-backed security 

Making Home Affordable programs 

Bank holding company 

MLHFS 

Mortgage loans held for sale 

Comprehensive Capital Analysis and Review 

Certificate of deposit 

Collateralized debt obligation 

Credit default swaps 

Current expected credit loss 

Common Equity Tier 1 

Consumer Financial Protection Bureau 

Collateralized loan obligation 

MSR 

MTN 

NAV 

NPA 

OCC 

OCI 

OTC 

OTTI 

Mortgage servicing right 

Medium-term note 

Net asset value 

Nonperforming asset 

Office of the Comptroller of the Currency 

Other comprehensive income 

Over-the-counter 

Other-than-temporary impairment 

Combined loan-to-value 

PCI Loans 

Purchased credit-impaired loans 

Commercial mortgage-backed securities 

Collateral protection insurance 

PTPP 

RBC 

Pre-tax pre-provision profit 

Risk-based capital 

Capital Purchase Program 

Commercial real estate 

Days past due 

Employee Stock Ownership Plan 

Statement of Financial Accounting Standards 

Financial Accounting Standards Board 

Federal Deposit Insurance Corporation 

FFELP 

Federal Family Education Loan Program 

FHA 

FHLB 

Federal Housing Administration 

Federal Home Loan Bank 

FHLMC 

Federal Home Loan Mortgage Corporation 

Fair Isaac Corporation (credit rating) 

Federal National Mortgage Association 

RMBS 

Residential mortgage-backed securities 

ROA 

ROE 

ROTCE 

RWAs 

SEC 

S&P 

SLR 

SOFR 

SPE 

TARP 

TDR 

Wells Fargo net income to average total assets 

Wells Fargo net income applicable to common stock 

to average Wells Fargo common stockholders’ equity 

Return on average tangible common equity 

Risk-weighted assets 

Securities and Exchange Commission 

Standard & Poor’s Ratings Services 

Supplementary leverage ratio 

Secured Overnight Financing Rate 

Special purpose entity 

Troubled Asset Relief Program 

Troubled debt restructuring 

Board of Governors of the Federal Reserve System 

TLAC 

Total Loss Absorbing Capacity 

Generally accepted accounting principles 

GNMA 

Government National Mortgage Association 

GSE 

G-SIB 

Government-sponsored entity 

Globally systemic important bank 

VA 

VaR 

VIE 

WIM 

Department of Veterans Affairs 

Value-at-Risk 

Variable interest entity 

Wealth and Investment Management 

282 

Wells Fargo & Company 

282

STOC K PERFO RM AN CE 

These graphs compare the cumulative total stockholder return and total compound annual growth rate 
(CAGR) for our common stock (NYSE: WFC) for the five- and ten-year periods ended December 31, 2018, 
with the cumulative total stockholder returns for the same periods for the Keefe, Bruyette and Woods (KBW) 
Total Return Bank Index (KBW Nasdaq Bank Index (BKX)) and the S&P 500 Index. 

The cumulative total stockholder returns (including reinvested dividends) in the graphs assume the 
investment of $100 in Wells Fargo’s common stock, the KBW Nasdaq Bank Index, and the S&P 500 Index. 

F I V E   Y E A R   P E R F O R M A N C E   G R A P H  

$260 

$240 

$220 

$200 

$180 

$160 

$140 

$120 

$100 

$  80 

$  60 

$  40 

$  20 

Wells Fargo 
(WFC) 

S&P 500 

KBW Nasdaq 
Bank Index 

2013 

$100 

100 

100 

2014 

$124 

114 

109 

2015 

$126 

115 

110 

2016 

$132 

129 

141 

2017 

$149 

157 

168 

2018 

$117 

150 

138 

5-year 
CAGR 

3%  Wells Fargo 

8%  S&P 500 

7%  KBW Nasdaq 

Bank Index 

T E N   Y E A R   P E R F O R M A N C E   G R A P H  

$360 

$340 

$320 

$300 

$280 

$260 

$240 

$220 

$200 

$180 

$160 

$140 

$120 

$100 

$  80 

2008 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

Wells Fargo 
(WFC) 

S&P 500 

KBW Nasdaq 
Bank Index 

10-year 
CAGR 

$100 

100 

100 

$95 

126 

98 

$110 

146 

121 

$99 

149 

93 

$127 

$173 

$215 

$219 

$228 

$259 

$202 

7%  Wells Fargo 

172 

124 

228 

170 

259 

186 

263 

187 

294 

241 

359 

286 

343 

235 

13%  S&P 500 

9%  KBW Nasdaq 

Bank Index 

283 

 
  
 
 
WEL LS  FARGO  & COMPANY 

Wells Fargo & Company (NYSE: WFC) is a diversified, community-based financial services company with $1.9 trillion in 
assets. Wells Fargo’s vision is to satisfy our customers’ financial needs and help them succeed financially. Founded in 1852 
and headquartered in San Francisco, Wells Fargo provides banking, investment and mortgage products and services, as well as 
consumer and commercial finance, through 7,800 locations, more than 13,000 ATMs, the internet (wellsfargo.com), and mobile 
banking, and has offices in 37 countries and territories to support customers who conduct business in the global economy. 
With approximately 259,000 team members, Wells Fargo serves one in three households in the United States. Wells Fargo 
& Company was ranked No. 26 on Fortune’s 2018 rankings of America’s largest corporations. 

C O M M O N   S T O C K  

S E C   F I L I N G S  

Wells Fargo & Company is listed and trades 
on the New York Stock Exchange: WFC 

4,581,253,608 common shares outstanding 
(12/31/18) 

S TO C K   P U R C H A S E   A N D   D I V I D E N D  
R E I N V E S T M E N T  

You can buy Wells Fargo stock directly from 
Wells Fargo, even if you’re not a Wells Fargo 
stockholder, through optional cash payments 
or automatic monthly deductions from a bank 
account. You can also have your dividends 
reinvested automatically. It’s a convenient, 
economical way to increase your Wells Fargo 
investment. 

Call 1-877-840-0492 for an enrollment kit, 
which includes a plan prospectus. 

F O R M   1 0 - K  

We will send Wells Fargo’s 2018 Annual 
Report on Form 10-K (including the financial 
statements filed with the Securities 
and Exchange Commission) free to any 
shareholder who asks for a copy in writing. 
Shareholders also can ask for copies of any 
exhibit to the Form 10-K. We will charge 
a fee to cover expenses to prepare and 
send any exhibits. Please send requests to: 
Corporate Secretary, Wells Fargo & Company, 
MAC D1130-117, 301 S. Tryon Street, 
11th Floor, Charlotte, North Carolina 28202. 

Our annual reports on Form 10-K, quarterly 
reports on Form 10-Q, current reports on 
Form 8-K, and amendments to those reports 
are available free of charge on our website 
(www.wellsfargo.com) as soon as practical 
after they are electronically filed with or 
furnished to the SEC. Those reports and 
amendments are also available free of charge  
on the SEC’s website at www.sec.gov. 

F O R WA R D - L O O K I N G   S TAT E M E N T S  

This Annual Report contains forward-
looking statements about our future financial 
performance and business. Because forward-
looking statements are based on our current 
expectations and assumptions regarding 
the future, they are subject to inherent risks 
and uncertainties. Do not unduly rely on 
forward-looking statements, as actual results 
could differ materially from expectations. 
Forward-looking statements speak only as 
of the date made, and we do not undertake 
to update them to reflect changes or events 
that occur after that date. For information 
about factors that could cause actual results 
to differ materially from our expectations, 
refer to the discussion under “Forward-
Looking Statements” and “Risk Factors” 
in the Financial Review portion of this 
Annual Report. 

I N D E P E N D E N T  
R E G I S T E R E D   P U B L I C  
A C C O U N T I N G   F I R M  

KPMG LLP 
San Francisco, California 
1-415-963-5100 

I N V E S TO R   R E L AT I O N S  

1-415-371-2921 
investorrelations@ 
wellsfargo.com 

SH AREOWNER SE RVI CE S 
A N D   T R A N S F E R   AG E N T  

EQ Shareowner Services 
P.O. Box 64854 
St. Paul, Minnesota 
55164-0854 
1-877-840-0492 
www.shareowneronline.com 

AN NUAL  SHA REHO LD ERS’ 
M E E T I N G  

10:00 a.m. Central time 
Tuesday, April 23, 2019 
Grand Hyatt DFW 
2337 South International 
Parkway 
Dallas, Texas 75261 

C O M PA N Y  

3rd 
Total Deposits (2018)  
FDIC data 

4th 
Total Assets (2018)  
S&P Global Market Intelligence 

7th 
Biggest Public Company  
in the World* (2018) Forbes 

20th 
Biggest Employer in 
the United States (2018) 
Fortune 

B R A N D  

Third-Most Valuable Financial  
Services Brand in World (2018)   
Brand Finance 

Best in Social Media Marketing and 
Services – North America (2018)  
Global Finance 

I N N OVAT I O N   L E A D E R S H I P  

#1 
Overall Mobile Performance, 
Functionality, and Quality &  
Availability (March 2018)  
Dynatrace 

Most Comprehensive 
Mobile App (2018) 
S&P Global Market Intelligence 

D I V E R S I T Y  

Top Company for LGBT  
(2018) DiversityInc 

Perfect Score – 100 Corporate Equality 
Index (2018, 15th year) Human Rights 
Campaign 

Perfect Score – 100 Disability Equality 
Index® Best Places to Work™ 
(2018, 3rd year) American Association  
of People with Disabilities 

Top Military Employer and Top Military 
Spouse Friendly Employer (2018)  
Victory Media 

Top 50 Best Companies for Diversity 
(2018) Black Enterprise 

Most Valuable Banking Brand in  
North America and Retail Banking  
(2018) Brand Finance 

Best Integrated Corporate Bank Site – 
North America (2018) Global Finance 

*Based on sales, profits, assets, and market value. 

284 

 
 
 
 
  
  
 
 
 
 
 
  
  
 
 
 
 
 
 
  
  
 
 
 
  
 
 
 
 
 
  
 
 
 
 
  
 
 
 
 
  
 
 
 
 
 
 
 
 
 
  
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
  
 
 
 
 
 
 
 
 
 
 
  
  
  
  
 
 
 
 
 
   
 
 
 
 
 
 
 
WEL LS FARGO’ S EX TENS IVE N ET WORK  
Data as of December 31 , 2018, unless otherwise noted. 

Number of domestic 
locations by state 

HI 
6 

AK 
59 

Around the world 

Argentina 

Australia 

Bahamas 

Bangladesh 

Brazil 

Canada 

L O C AT I O N S*  

7,800 

AT M s 

13,000 

WA 
203 

OR 
139 

MT 
52 

WY 
32 

ID 
88 

NV 
119 

CA 
1,282 

UT 
123 

CO 
204 

AZ 
286 

NM 
95 

ME 
4 

NY 
192 

9 

6 

5 

1 

8 

ND 
33 

SD 
63 

NE 
57 

MN 
195 

IA 
92 

WI 
84 

MI 
47 

IL 
106 

IN 
33 

OH 
70 

KS 
34 

MO 
36 

OK 
15 

TX 
768 

AR 
23 

LA 
20 

MS 
25 

KY 
10 

TN 
47 

AL 
146 

WV 
10 

PA 
333 

7 

4 

2 

3 

VA 
319

NC 
377 

SC 
159 

GA 
317 

FL 
718 

1 

2 

3 

CT:  91 

DC :  40 

DE:  23 

4  MD:  124  

5  MA:  39 

6 

7 

8 

9 

NH:  8 

NJ:  345  

RI:  6 

VT:  6 

Cayman Islands 

Chile 

China 

Colombia 

Dominican Republic 

France 

Germany 

Hong Kong 

India 

Indonesia 

Ireland 

Israel 

Italy 

Japan 

Korea, Republic of 

Luxembourg 

Mexico 

Netherlands 

New Zealand 

Philippines 

Singapore 

South Africa 

Spain 

Sweden 

Taiwan 

Thailand 

Turkey 

United Arab Emirates 

United Kingdom 

Vietnam 

C U S T O M E R S  

70+ million 

M O B I L E   B A N K I N G* *  

22.8 million 
mobile active users 

285 

W E L L S F A R G O . C O M * *  

29.2 million 
digital (online and mobile) active customers 

*Number of domestic and global locations. Includes Wells Fargo Advisors Private Client Group and Financial Network locations. 
**Data as of November 2018. 

C O R P O R AT E   R E S P O N S I B I L I T Y  

Top 50 
Most community-minded companies 
(2018) Points of Light 

#2 
Most Generous Cash Donor (U.S.)  
(2018) The Chronicle of Philanthropy 

I N   S U P P O R T I N G   H O M E OW N E R S  
A N D   C O N S U M E R S  

#1 
Home loan servicer (3Q18)  
Inside Mortgage Finance 

#1 
Provider of private student loans  
among banks (2018) 
Company and competitor reports 

#2 
Retail mortgage lender (3Q18)  
Inside Mortgage Finance 

#3 
Used auto lender (August 2018)  
AutoCount 

I N   W E A LT H   A N D   I N V E S T M E N T  
M A N A G E M E N T  

Best Investment Management Services – 
North America (2018) Global Finance 

#3 
U.S. full-service retail brokerage provider 
(2Q18) Company and competitor reports 

#4 
U.S. wealth management provider  
(2018) Barron’s 

I N   C O M M E R C I A L  
R E A L   E S TAT E  

#1 
Commercial real estate lender in the U.S. 
(2018) MBA Commercial/Multifamily 
Annual Origination Rankings 

#1 
Market share by commercial real estate 
outstandings (2018)  
Federal Reserve Form FRY-9C 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
  
WEL LS   FARGO & COMPAN Y 

420  MONTGOMERY  STREET | S AN  FRAN CI SCO, CA  | 94104 

1- 866-87 8-58 65  | WELLSFARG O.COM  

© 2019 Wells Fargo & Company.  All rights reserved. 
Deposit products offered through Wells Fargo Bank, N.A. Member FDIC. 
CCM9537  (Rev 00, 1/each)