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Wells Fargo & Company

wfc · NYSE Financial Services
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Industry Banks - Diversified
Employees 10,000+
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FY2019 Annual Report · Wells Fargo & Company
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WELLS FARG O &  COMPA N Y

420 MON TGOM ERY  STR EE T  |  SA N   FR AN C ISC O,  CA   |   9 4 10 4

1-866-878- 5865  |  WE LL SFA RG O.COM

© 2020 Wells Fargo & Company.  All rights reserved.

Deposit products offered through Wells Fargo Bank, N.A. Member FDIC.

CCM3520  (Rev 00, 1/each)

Wells Fargo & Company 
2019 Annual Report 

 
 
 
 
 
 
 
 
 
  
 
Wells Fargo’s Extensive Network

LOCATIONS*

7.4K

ATMs

13K

CUSTOMERS

70M+

WELLS FARGO.COM**

30.3M

digital (online and mobile) active customers

MOBILE BANKI NG**

24.4M

mobile active users

*Number of domestic and global locations. Includes Wells Fargo Advisors Private Client Group and Financial Network locations.

*

*Data as of November 2019.

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

WA 

189

OR 

128

NV 

119

CA 

1,232

MT 

43

WY 

30

ID 

85

UT 

115

CO 

198

AZ 

259

NM 

91

ME 

4

NY 

191

9

6

5

1

8

7

4

2

3

PA 

324

VA 

313

NC 

352

ND 

27

SD 

55

NE 

54

MN 

182

IA 

85

WI 

82

MI 

42

IL 

103

IN 

34

OH 

63

WV 

10

KS 

31

MO 

36

OK 

15

TX 

740

AR 

37

LA 

20

MS 

25

KY 

9

TN 

44

AL 

140

SC 

149

GA 

302

FL 

701

AK 

53

HI 

6

1

2

3

4

5

6

7

8

9

CT: 90

DC: 40

DE: 22

MD: 121

MA: 33

NH: 6

NJ: 336

RI: 6

VT: 7

Data as of December 31, 2019.

A R O U N D   T H E   W O R L D

Dominican Republic

Japan

Argentina

Australia

Bahamas

Bangladesh

Brazil

Canada

Cayman Islands

Chile

China

Colombia

France

Germany

Hong Kong

India

Ireland

Israel

Italy

Luxembourg

Netherlands

New Zealand

Philippines

Singapore

South Korea

Sweden

Taiwan

Thailand

United Arab Emirates

United Kingdom

Vietnam

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Contents 

2 

8 

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 E O  

2 3  

O u r   P e r f o r m a n c e  

2 4  

B o a r d   o f   D i r e c t o r s  

2 6  

C o r p o r a t e   R e s p o n s i b i l i t y :   2 0 1 9  
E n v i r o n m e n t a l ,   S o c i a l ,   a n d   G o v e r n a n c e   H i g h l i g h t s  

2 9  

2 0 1 9   F i n a n c i a l   R e p o r t  

2 5 9  

S t o c k   P e r f o r m a n c e  

 
 
 
 
 
 
 
 
 
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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  

  
 
 
 
 
 
3 

F e b r u a r y   2 0 ,   2 0 2 0  

2019 brought a great deal of 

change to Wells Fargo, including 

the selection of our new CEO, 

Charlie Scharf. Through it all, 

the company’s foundational 

commitment to helping 

customers succeed fnancially 

has remained a constant. 

Working together, the company and our board continue to make 

progress in our ongoing transformation. Although much work remains, 

I am optimistic about our future as we move forward. 

The board decided to conduct an external search for a new CEO after 

Tim Sloan announced his retirement. I am pleased that our search led 

to the appointment of Charlie as our CEO and president. Charlie is an 

experienced CEO who has excelled at strategic leadership and execution. 

  
  
 
 
 
 
 
 
 
 
 
 
 
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With more than 24 years in leadership roles in the banking 

and payments industries, Charlie has demonstrated a strong 

track record in initiating and leading change, driving results, 

strengthening operational risk and compliance, and innovating 

amid a rapidly evolving digital landscape. 

Charlie embodies the traits our board’s search committee was 

looking for in Wells Fargo’s next leader — namely, financial and 

business acumen, integrity, passion for diversity and inclusion, and 

commitment to strong talent management. His proven ability to 

build strong relationships with stakeholders, including customers, 

employees, regulators, and investors, will be especially important 

to rebuilding trust and resolving key regulatory issues. He has led 

organizations in all our major business lines, and his experience with 

businesses that operate at the scale and complexity of Wells Fargo 

has prepared him well for this role. 

What we have observed in the first few months of Charlie’s 

tenure only confirms our initial high expectations. He brings to 

Wells Fargo a willingness and ability to make important changes, 

an urgency to address our regulatory issues, and a recognition of 

the importance of actively engaging with our stakeholders. He is 

actively developing his strategic priorities for the company and 

evaluating them in light of our risk appetite and the capacity of 

our risk management framework. He is making key organizational 

changes and has already demonstrated a commitment to direct 

and transparent communications. 

I wish to thank the members of the board’s search committee — 

Chair Jim Quigley, Wayne Hewett, Maria Morris, and Ron Sargent — 

for conducting a thorough and successful search that was 

comprehensive in its diligence and reach. I also would like to thank 

Allen Parker for his exemplary service as interim CEO and president. 

His leadership during a time of transition enabled Wells Fargo and 

our team members to continue moving forward in a focused and 

transparent way. 

 
 
 
  
 
 
 
 
 
 
  
  
 
  
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
5 

N E W   B O A R D   M E M B E R S  

As the company makes important changes, so does the Board 

of Directors. We continued our efforts to further enhance board 

efectiveness by adding more directors with expertise in fnancial 

services, regulatory matters, and financial reporting. 

In June 2019, we welcomed Chuck Noski to the board. Chuck 

brings broad experience as a corporate director through service 

on numerous boards, including Booking Holdings Inc., and until 

recently Microsoft Corporation. He also has financial industry 

experience through his prior roles as a director of Morgan Stanley 

and as CFO of Bank of America. In addition to his extensive 

experience in public accounting and as CFO of Fortune 500 

companies, he is the immediate past chairman of the Board 

of Trustees of the Financial Accounting Foundation, overseer 

of the Financial Accounting Standards Board. Chuck serves on 

our board’s Audit Committee. 

Dick Payne joined the board in October. Dick is a seasoned 

banking professional with more than 40 years of experience 

in corporate and commercial banking as well as capital markets 

with large financial institutions, serving middle-market and large 

corporate customers in many of the same geographic markets and 

businesses served by Wells Fargo. He has a deep understanding 

of banking and the regulatory environment and brings experience 

and valuable perspective to the board. 

Both new directors are already contributing to our progress as 

we work to transform Wells Fargo, meet the expectations of our 

regulators, and rebuild trust with our stakeholders. 

I also wish to thank John Baker, a member of the Board of Directors, 

for his years of service and many contributions to the board. 

John will retire as a director at the company’s 2020 annual meeting 

of shareholders. 

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

While much of the work underway is necessary to meet our 

regulatory requirements, it will also make us a stronger, nimbler, and 

more efcient company. The board’s oversight is ultimately focused 

on ensuring the alignment of strategy with risk management, and 

our ability to satisfy the fnancial needs of customers while creating 

value for shareholders. Several examples of actions taken over the 

past few years include the following: 

We changed the organizational structure of Wells Fargo from 

a decentralized to a centralized model. 

We reviewed, and continue to review, all business processes for 

effectiveness and standardization. 

We continued to make strategic choices about the businesses we 

are in. Over the past few years, we have divested businesses that 

did not meet our strategic objectives, such as the institutional 

retirement business, commercial real estate brokerage, crop 

insurance, property and casualty insurance, stock transfer agent, 

and payroll services businesses. 

In the Consumer Bank, management has continually reviewed and 

evaluated the branch network, closing some branches and selling others 

as a result of our customers’ steady migration to digital channels. 

Throughout 2017 and 2018, the Auto business intentionally slowed 

its originations in order to make needed changes to its business 

structure, including centralizing back-off ice functions from over 

50 locations into four hubs across the country, re-engineering 

processes to improve eff iciency and the customer experience, and 

better managing risk. Following this restructuring, the Auto portfolio 

started to grow again in 2019. 

Charlie and Wells Fargo’s management team are taking the strategic 

business review even further. They are looking inside our businesses, 

including core franchise businesses, to understand the business 

fundamentals, competitive position, distribution channels, growth 

prospects, and required investment to bring each to best-in-class 

status. At the same time, they are examining the structure, 

capabilities, and organizational maturity of enterprise functions 

such as technology, human resources, risk, and finance. 

 
 
 
  
   
 
 
 
 
 
 
 
 
 
 
 
 
   
 
  
 
 
 
 
  
 
  
 
 
 
 
 
7 

Over the course of 2020, the board and 

Charlie will work together to design and 

communicate a strategy that will provide 

the blueprint for the future of Wells Fargo. 

In doing so, we remain committed to our 

diversified business model. And we are 

mindful of the important role Wells Fargo 

plays in the economic success of the U.S. 

and in each customer’s financial success. 

Moving forward, the company has a renewed 

focus and commitment around our risk 

management structure and resources to 

execute against our business strategy and 

safely and efectively serve our customers. 

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

On behalf of the Board of Directors, we’d 

like to thank you, our shareholders, for your 

continued investment in Wells Fargo. We 

recognize the commitment you have made 

to the company and the responsibility that 

entails. With the sense of urgency Charlie 

brings to the company, the leadership of 

our management team, and the hard work 

of Wells Fargo’s 260,000 team members, I’m 

confident that we can address our current 

challenges while doing the work necessary 

to build a strong foundation for the future. 

While navigating change is difficult, I have 

faith in the ultimate value of what we are 

creating together. 

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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F e b r u a r y   2 0 ,   2 0 2 0  

I write this note just four months after joining Wells Fargo. 

It has been a busy time as I’ve been working to get to know the 

company and working with the senior team to understand both 

our opportunities and our challenges. While I’ve learned a great 

deal, as I discuss my observations here, please recognize that it is 

still early days and I do not pretend to have all of the answers yet. 

I was honored to be 

chosen to lead Wells Fargo 

because I believe this is an 

extraordinary company 

that plays an important 

role in this country. 

We came out of the financial crisis as the most valuable and 

most respected bank in the United States. However, we also had 

substantial problems that needed fixing. Significant parts of 

our operating model were flawed, and we broke our customers’ 

trust in the past. We have not yet efectively addressed all of our 

problems and these circumstances hurt our employees, hurt our 

customers, and also have led to financial underperformance. 

 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
9 

C H A R L E S   W.   S C H A R F  

W e l l s   F a r g o   &   C o m p a n y  

C E O  

   
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But we have one of the most enviable 

remediation, as well as $739 million of 

fnancial services franchises in the world 

deferred compensation expense, which 

and employees who want to do what’s 

is P&L neutral, as this expense is ofset by 

necessary to again be one of the most 

deferred compensation investment gains. 

respected and successful banks in the 

U.S. The opportunity to do so is in our 

reach. I will discuss the actions we are 

taking, but frst let me cover our 2019 

fnancial and business performance. 

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

Our financial results in 2019 reflected 

the ongoing impact of our historical 

shortcomings. Even after adjusting for 

these items, our results were not as strong 

as we aspire them to be. These items 

primarily relate to litigation, customer 

remediation related to previously 

disclosed retail sales practices matters, 

as well as other regulatory matters. Our 

results also included business divestitures 

and loan sales. They are all detailed in our 

fnancial disclosures. 

Wells Fargo generated $19.5 billion in 

net income in 2019, or $4.05 per diluted 

common share. Our revenue declined 

$1.3 billion, or 2%, from a year ago as 

4% growth in noninterest income was 

more than offset by a 6% decline in 

net interest income, driven by lower 

interest rates. Our noninterest expense 

increased $2.1 billion, or 4%, from a 

year ago. Expenses included $4.3 billion 

of operating losses ($1.2 billion higher 

than 2018), primarily for litigation and 

We continued to serve our customers and 

grew both loans and deposits in 2019. 

Loans increased $9.2 billion, or 1%, from a 

year ago, with growth in both commercial 

and consumer loans. Deposits grew 

$36.5 billion, or 3%, from a year ago. 

At the same time, credit quality continued 

to be strong. Our net charge-of rate 

remained near historic lows at 0.29% of 

average loans in 2019, and nonaccrual 

loans as a percentage of total loans 

declined to 0.56%, the lowest level in 

over 10 years. 

In 2019, we returned a record $30.2 billion 

to shareholders through common stock 

dividends and net share repurchases, 

reducing our common shares outstanding 

by 10% while maintaining a level of 

Common Equity Tier 1 that is well in 

excess of our regulatory requirements. 

This was the seventh consecutive year 

we have reduced our common share 

count, which is down 21% since 2012. 

In July 2019, we increased our quarterly 

common stock dividend to 51 cents per 

share, a 13% increase. 

B U S I N E S S   H I G H L I G H T S  

The strength of our franchise remains 

evident. We serve one in three U.S. 

 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
11 

households, we have strong distribution across both physical 

and digital channels, and we remain one of the largest lenders 

in the U.S. across a large and diversified client base. Despite 

our recent challenges, these strengths endure and you can 

see that if you look at the growth of some of our underlying 

business drivers. To be clear, we can do better, but I’ll touch on 

some key highlights across our businesses over the past year. 

In Community Banking, primary consumer checking customers 

increased 2% year-over-year, our ninth consecutive quarter of 

year-over-year growth. Our customers spent $448 billion across 

our debit and credit cards, an increase of 6%. We continued to 

invest across our various channels and delivered diferentiated 

experiences to meet our customer needs. We ended the year 

with over 30 million digital active customers, a 4% increase, and 

mobile active customers of 24.4 million were 7% higher. Our 

card customers can now complete transactions more seamlessly, 

as we have begun rolling out new tap-to-pay contactless 

cards. This functionality is available at millions of merchants, in 

addition to our own more than 13,000 ATMs across the nation. 

We’re making steady progress and the hard work of our teams is 

refected in what we are hearing from customers, as our branch 

survey scores for both customer loyalty (64.2%, up from 60.2%) 

and overall satisfaction with most recent visit (79.9%, up from 

78.7%) increased year-over-year. 

On the Consumer Lending side, origination momentum 

accelerated across our Home Lending and Auto platforms. 

Our Auto portfolio returned to growth in 2019 after a 

multiyear transformation. In addition, we continued to invest 

to improve the customer experience and enhance our own 

operational capabilities in both these areas. As evidence, in 

2019, for the frst time, we had a month when more than half 

of all mortgage applications came to us through our online 

mortgage app. The online mortgage app is fully digital and 

shortens the time from origination to customer approval by 

approximately 30%. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
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And in Auto, our automated decisioning went from 40% at the end of 

2018 to 57% today, which allows us to be responsive to dealers for 

whom speed is a top priority and also drive consistency that supports 

our focus on risk management. 

Our wholesale businesses, including Commercial Banking and 

Corporate and Investment Banking, saw loan growth of 1% as we 

selectively expanded the portfolio. In Commercial Banking, we 

accelerated our efforts to deliver a more consistent customer 

experience by segmenting customers to the most appropriate 

coverage channel, virtual or market-based. Additionally, we 

developed a revamped customer onboarding platform and have 

begun rolling it out to customers. Over 12,000 accounts have 

been opened to date on the platform and the early results so far 

have been impressive, reducing the customer onboarding cycle 

time by two-thirds. These changes are critical to our ongoing 

efforts to not only serve our customers better, but also reduce 

risk and improve our operational capabilities. It is our intent 

to leverage these efforts and roll out the common onboarding 

platform to our other wholesale businesses. 

The Corporate and Investment Bank performed well in 2019. 

We grew our overall U.S. investment banking fee market share 

by 50 basis points to 3.7% driven by strong growth in high-grade 

debt capital markets and in loan syndications. Overall, we raised 

$115 billion of debt capital for our clients. And our Markets 

businesses performed well, with strong performance across 

the FICC franchise, up 15%, including particularly strong results 

in our Credit, Rates, and Commodities businesses. 

In Wealth and Investment Management, we continued to simplify 

our go-to-market and operating model. We brought together our 

private wealth management businesses and centralized previously 

siloed key supporting capabilities like Lending, Banking, and 

Operations across the platform. We also divested the Institutional 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
13 

Retirement and Trust business. These 

behind us, and our future depends on 

changes are designed to simplify and 

doing this successfully so we can regain 

focus our businesses to better serve 

trust with all stakeholders. This includes 

the needs of our changing client base. 

our clients, employees, regulators, 

In addition, we had solid investment 

lawmakers, shareholders, as well as the 

broader American population. Ultimately, 

performance — on average, Wells Fargo 

we know our actions will dictate when 

Investment Institute’s actively managed 

that trust is completely regained, not 

portfolios outperformed relevant 

Morningstar benchmarks by over 

150 basis points. Client assets of 

our words. Given their importance, I’ve 

been spending the majority of my time 

on addressing these issues since joining 

$1.9 trillion increased 10% and we saw 

the company. 

further momentum resulting from 

our Community Bank and Wealth and 

A S S E S S M E N T  –   In an organization 

Investment Management partnership as 

like Wells Fargo, providing an honest 

closed referred investment assets grew 

assessment and clear priorities to the 

18% year-over-year in the fourth quarter. 

entire organization is critical. I’ve given a 

Again, while we need to improve 

our overall financial results, positive 

momentum across many of our 

underlying business drivers speaks 

to the strength of the franchise and 

the substantial opportunities we have  

to improve financial performance 

in the future. 

clear message that we have not yet met 

our own expectations or the expectations 

of others. We must do what’s necessary 

to put these issues behind us. Our ability 

to maximize the value of this great 

franchise is dependent on us running the 

company with the highest standards of 

operational excellence and integrity — 

beyond what we’ve done to date. 

T H E   P AT H   T O   S U C C E S S  
D O I N G   T H E   W O R K   N E C E S S A R Y  
T O   B U I L D   A   S T R O N G   F O U N D A T I O N  
To fully capture the opportunity to once 

R E G U L A T O R S  –   I am often asked 

about our regulatory relationships so let 

me provide my perspective. My experience 

again be one of the most respected and 

is that our regulators are clear, direct, 

successful banks in the country, we must 

tough, but fair. We are appropriately a 

have a strong foundation and move with 

highly regulated institution, and while we 

an extreme sense of urgency to fx what 

need to fulfll regulatory expectations, we 

was wrong with the bank. We still have 

recognize that what we want and what 

much more work to do to put these issues 

regulators want are not diferent. We are 

 
 
 
 
  
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
   
   
 
   
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
  
 
 
 
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responsible for our actions and they are 

at the company. They understand our 

responsible for ensuring our actions are 

lack of progress makes their jobs far 

consistent with a clearly defined set of 

more difficult — and they are looking 

standards. It’s our job to run the company 

to management to do more to move 

such that we fulfll their expectations and 

the company forward. 

those of the American public and other 

countries where we operate. Our job is to 

To set us up for success, we will ensure 

do the work that’s necessary. Regulators 

we have the right people in place to 

and other stakeholders will determine 

when it’s done to their satisfaction. 

both resolve these issues and be the 

stewards of this great company as we 

move forward. To that end, we have made 

W H AT   W E   A R E   D O I N G  –   Like any 

some important changes to the senior 

other problem, recognition of the 

management team to complement the 

importance and severity is a necessary 

talent that’s here at Wells Fargo. 

first step — but this by itself is 

inadequate. We will take whatever actions 

Scott Powell joined us as COO. When 

are necessary. The management team 

will be judged and held accountable for 

resolving these issues. 

I arrived at the company, many on the 

senior management team made clear to 

me that we needed stronger execution 

skills. After several weeks at the 

We are making signifcant changes to 

company, I came to quickly agree. Scott 

our management, structure, processes, 

will lead a transformation across the 

and culture to accomplish our work — 

company where high-quality execution, 

changes that will make us more efective. 

clear accountability, and operational 

excellence become part of our culture. 

T H E   T E A M  –   First, I want to 

acknowledge that we have so many 

Mike Weinbach will join us as CEO 

wonderful people at Wells Fargo who 

of Consumer Lending and will have 

have done an amazing job serving 

responsibility for Home Lending, Auto, 

our clients and customers in the face 

Credit Cards & Merchant Services, 

of adversity for several years now. 

and Personal Lines & Loans, including 

They have been through so much and 

Student Lending. We are one of the 

have helped us sustain such a great 

largest providers of consumer credit 

franchise — so I do want to say thank 

in the country and want to continue 

you to them for all that they’ve done. 

serving that important role for our 

The warmth and support I’ve been 

customers and the U.S. economy. Mike 

greeted with as I’ve discussed our past 

has the right experience, skills, and 

issues and work in front of us tells a 

knowledge to lead these franchises 

great deal about the character of many 

going forward. 

 
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
15 

Bill Daley joined as head of Public Affairs. He has a strong 

and experienced voice and brings perspectives from the public 

sector that we in business do not generally have but are critical 

for us as we make decisions. 

Allen Parker, who served both as General Counsel and Interim 

CEO, has announced that he will be leaving the company in 

March. As I write this, we are engaged in a General Counsel 

search and have seen some terrific candidates. 

Avid Modjtabai has announced that she will be retiring in 

March after 26 years at Wells Fargo. I will discuss below how 

we are restructuring Avid’s responsibilities. 

Ray Fischer has also joined us to run our Credit Cards & 

Merchant Services businesses, which will be part of Consumer 

Lending (more details below). Our card business is important to 

our franchise and we have an opportunity to make it even more 

significant. Ray is an experienced card and merchant services 

executive who brings deep knowledge and a fresh perspective 

to our business. 

Saul Van Beurden joined us as our new head of Technology 

earlier in 2019. Saul has great experience as a technology leader 

in fnancial services and his impact will certainly be a key element 

of the company’s control, customer experience, business and risk 

management transformation, and growth agenda. 

Julie Scammahorn also joined us as our Chief Auditor earlier 

in 2019. Julie will play a critical role and hold us to the highest 

standards as we build effective execution into all we do. 

These changes are all critical to our future, and I will continue 

to look at the structure and roles of our team to ensure we 

are best positioned for success. We need and will have the 

best talent and strong leadership at the company. 

 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
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O R G A N I Z A T I O N   S T R U C T U R E  –   We have made several 

changes which I believe enable us to be more effective in 

pursuing our goals. First, we reorganized the company into five 

lines of business and announced several new business leaders to 

help further drive operating, control, and business performance. 

Consumer and Small Business Banking – Mary Mack, who most recently 

led Consumer Banking, is now CEO of Consumer and Small Business 

Banking, responsible for Branch Banking and Small Business, which 

includes the company’s 5,400 branches and delivers a full range of deposit, 

lending, investment, and payment products. Mary will now have additional  

responsibilities for Deposits and a newly established Digital team focused 

on acquiring and servicing new customers through digital channels. 

Consumer Lending – as mentioned earlier, Mike Weinbach will join us 

in a couple of months as CEO of Consumer Lending, elevating a core 

competency of the company that provides critical capabilities to fulf ill 

the f inancial needs of customers. Mike will be responsible for Home 

Lending, Auto, Credit Cards & Merchant Services, and Personal Lines 

& Loans, including Student Lending. 

Commercial Banking – Perry Pelos is CEO of Commercial Banking, with 

both relationship and product responsibilities in serving businesses with 

annual sales generally in excess of $5 million. Perry is now responsible 

for Middle Market Banking, Commercial Capital, and Treasury 

Management. We’re proud of our market position and believe we have 

great opportunities to expand our franchise by continuing to integrate 

these products and capabilities. 

Corporate and Investment Banking – Jon Weiss, who most recently ran 

our Wealth and Investment Management business, is now CEO of our 

Corporate and Investment Bank. The creation of a separate business 

line supporting the capital markets, banking, and investment needs of 

our corporate, government, and institutional clients is a recognition of 

the successful franchise we have today and our belief that we continue 

to have signifcant opportunities to serve the needs of our corporate and 

middle market clients more broadly. Commercial Real Estate and our 

International franchise will be a part of Corporate and Investment Banking. 

  
  
  
  
  
  
  
 
  
 
  
  
  
  
  
 
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
17 

Wealth and Investment Management – 

Our lack of progress and under-

Our Wealth and Investment Management 

performance point to shortcomings. 

business provides a full range of 

Going forward: 

personalized wealth management, 

investment, asset management, and 

We will operate as one company, not 

retirement products and services to 

a series of decentralized businesses. 

clients. We restructured the businesses 

and management over the past couple 

of years and are conducting a search to 

We will continue to foster a culture of 

partnership, but we will move past the 

need for consensus and have open and 

replace Jon as the leader of this business. 

direct fact-based discussions where we 

This new organizational structure is fatter 

and provides important businesses more 

direct representation on our Operating 

Committee. It provides the necessary 

clarity and accountability and sets us up 

to build our businesses over the long term 

and increases our ability to successfully 

execute on our top priority, which is the 

risk, regulatory, and control work. 

C H A N G E S   T O   H O W   W E   R U N   T H E  
C O M PA N Y   A N D   O U R   C U LT U R E  –  

We are also introducing a new set of 

disciplines in how we run the company 

which seek to preserve some important 

pieces of our culture while recognizing 

where we need to change. These 

changes are critical for our future and I’m 

confdent will improve our performance.  

emerge with decisions. 

We will have a different level of 

management discipline than we’ve 

had in the past and will value and 

expect high-quality execution. 

There will be clear responsibility 

and accountability. 

We will judge ourselves based upon 

our outcomes — not our words. 

And we will ultimately judge ourselves 

versus the best as we believe that we 

should be the best. 

As we’ve begun to implement this 

new culture, the response has been 

overwhelmingly supportive. But 

I understand it’s different and is 

a signifcant change for many. We will 

be respectful of our past and of those 

Parts of our culture are wonderful and 

who have built this great franchise — which 

would take decades to recreate. People 

includes so many still at the company 

who work here love it. Wells Fargo really 

today — but we must move forward. 

is like a second family to many. We focus 

I’m confdent these changes will be  

on teamwork — not on the individual. 

highly impactful. Respect was earned 

People want to be successful and do 

in the past, and we will earn it again. 

what’s right — though we recognize 

we have fallen short of this goal. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
  
  
  
 
  
 
 
 
 
 
  
  
 
  
  
 
 
  
 
  
 
 
 
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C O R P O R AT E   A N D   S O C I A L   R E S P O N S I B I L I T Y  

As we make the changes to build a stronger foundation for the 

company, we will continue to recognize and act upon the broader role 

we play in our communities. Notably, we became a proud signatory 

of the Statement on the Purpose of a Corporation that was issued 

by the Business Roundtable in August of this past year. It’s simple 

and straightforward, and it’s a clear statement that businesses are 

responsible to a broad set of constituents and have responsibilities 

beyond what some companies have believed historically. Given 

the businesses we’re in and the reach we have, I believe our 

responsibilities and potential for impact are particularly great. 

Like many companies, we are taking an active role in addressing 

important social and environmental challenges, and we are 

constantly asking ourselves: How can we improve these eforts to 

drive even more positive impact? We believe the answer is to invest 

in innovative solutions fueled by a range of resources and expertise 

from across our entire company. We see our philanthropy, which 

totaled $455 million in 2019, as only the beginning — a way to seed 

investments that our core business capabilities, people, and built-in 

scale can then power for even greater impact. 

For example, we believe we have a responsibility to do our part to 

support the transition to a low-carbon economy and to work with our 

customers and communities to address the risks of climate change. 

Our $200 billion sustainable finance commitment, announced in 

2018, is central to our efforts in supporting sustainable business 

opportunities, including providing needed capital to renewable 

energy companies and empowering clean technology entrepreneurs. 

We continued to make strong progress in 2019 and we have now 

provided approximately $49 billion in sustainable fnancing toward 

our commitment of $200 billion by 2030. 

We are also one of the largest sources of capital for affordable 

housing development in the country. In 2019, Wells Fargo 

provided more than $4 billion of capital to support the 

development of more than 15,000 affordable housing units in 

communities in over 30 states. Building on this expertise, the 

Wells Fargo Foundation announced a $1 billion philanthropy 

commitment over six years to catalyze new ways to address the 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
   
 
 
 
 
  
 
 
 
 
 
 
 
19 

growing housing affordability crisis in 

And this isn’t just cheap talk — while it’s 

the U.S., where more than 18 million 

the right thing to do, it is my frm belief 

households are spending 50% of their 

that bringing together people of diferent 

income on housing. We’re working 

backgrounds, experiences, and identities  

with a range of grantees to test and 

leads to signifcantly better outcomes. 

scale innovations that increase the 

number of affordable rental units, 

expand homeownership opportunities, 

and develop solutions to persistent 

homelessness in cities. 

We’re very focused on this across the 

company. I will be personally chairing 

our Enterprise Diversity & Inclusion 

Council. This group, composed of leaders  

from across the organization, meets 

Our employees also care deeply about 

monthly and is charged with driving the 

the communities we serve, and we have 

education and change necessary for 

introduced new ways to turn that caring 

making meaningful progress against our 

into opportunities to take action. In 2019, 

objectives. We are setting clear, specifc, 

more than 100,000 of our people provided 

and measurable goals and will be holding 

1.9 million hours of volunteer service 

people accountable to advancing our 

through eforts such as our new Dedicated 

diversity and inclusion eforts at all levels.  

Day of Service in which more than 900 

Wells Fargo volunteer events were held 

on a single day this past September. 

To further support our efforts, we have 

ten different Team Member Networks 

(TMNs) formed around historically under-

These are just a few examples of our 

represented segments. Our TMNs bring 

ongoing commitment to the people and 

together people of common interests, 

communities in which we do business. 

backgrounds, experiences, or identities, 

Our goal is to combine our giving, our 

and provide forums to support career 

expertise, and our ingenuity in order 

and professional development of their 

to move the needle on social and 

members, engage and volunteer in our 

environmental issues that impact us all. 

communities together, and serve as 

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

Diversity and inclusion are absolutely 

integral parts of our business. We serve a 

diverse group of clients and communities, 

additional mechanisms for embedding 

inclusive practices into our day-to-day 

operations. We have approximately 74,000 

active participants across these networks. 

and it’s essential that our people refect 

We’ve made progress on a number of 

that diversity. Our goal is nothing less than 

fronts but we also know we have much 

ensuring that people across our workforce, 

work to do. It won’t be a straight line, 

communities, and supply chain feel valued 

but we’re focused on it and will be holding  

and respected and have equal access to 

ourselves accountable for advancing 

resources and opportunities to succeed. 

these goals over a period of time. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
  
  
  
  
  
  
  
 
 
  
  
  
 
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M E D I U M   A N D   L O N G E R   T E R M   O P P O R T U N I T I E S  

Our franchises are world class and are in the sweet spot of providing 

necessary fnancial services for consumers, small businesses, and 

middle market and large corporate companies. And importantly, we 

play a signifcant role in helping our customers and clients prosper 

as well as being an important enabler for U.S. economic growth. 

While I have spoken at length of our problems and our commitment 

to fix them, the underlying franchise itself remains strong, and 

our opportunities are greater than ever. The success of our 

business model is proven, assuming we run the company with 

the appropriate controls and work as one company with the goal 

of delivering for all our stakeholders. 

All of our business segments have the breadth and scale that give 

us signifcant competitive advantage and allow us to deliver truly 

diferentiated products and experiences for our customers and 

clients. Our opportunity to use technology to drive both automation 

and new solutions will continue to grow. 

Our franchises, both individually and collectively, are the envy of 

many. So while our resources and attention today are appropriately 

focused on historical issues, as we move forward, we will be in a 

position to leverage our unique franchise and focus on generating 

stronger financial results. 

And just to be clear, we are well aware that our expense levels are 

significantly too high. Part of this is driven by significant expense 

related to resolving historical issues, part is due to the necessary 

investments in technology, and part is due to significant 

inefficiencies that exist across the organization. But there is no 

reason why we shouldn’t have best-in-class efficiency with these 

businesses at this scale — and that ultimately will be our goal. 

And, though we’ve had pockets of strong performance, we are also 

well aware that our rate of customer and revenue growth is too low. 

Given what we’ve been through, this isn’t surprising. We have been 

operating under an asset cap as part of the Federal Reserve consent 

order from February 2018 and there is certainly an opportunity 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
  
 
 
 
 
 
21 

cost to doing so. Management time and resources have not 

been as focused on growth as they otherwise would have been. 

But we have an opportunity to think diferently, with a diferent 

level of rigor about how to grow the franchise. All of this points 

to great opportunity. 

We have begun a process to rethink our plans for 2020 and beyond 

at a very detailed level. While the opportunities for improvement 

are clear at a macro level, we need business-by-business plans. 

Accordingly, we have begun conducting business reviews where we 

are looking at our businesses and plans in detail. We are reviewing 

all businesses as well as all of our enterprise functions. 

This isn’t merely a review of the numbers, but one where we use 

the facts to form a basis to discuss strategy and potential actions. 

We are asking each business leader to show us what best-in-class 

efficiency looks like — and what our path to achieve it is. We are 

reviewing revenue growth and return performance as well — and 

what a path to best-in-class looks like. We are discussing our 

competitors — large and small — and we are thinking through our 

unique options given our special franchise. These are analytical and 

strategic discussions that I don’t think have occurred consistently 

across the company in some time given what has occurred. 

The output of this work is designed to provide us roadmaps to not 

only improve our performance within each business but to also 

position us to understand our opportunities across the company 

and prioritize accordingly. 

It’s still very early in our process — but I will say that every session 

thus far has reinforced that our opportunities are meaningful. 

To do this properly, and given our priorities, it will take time — much 

of this year — to complete our work. But in the interim, we will 

devote all necessary resources to risk and control, and spend what’s 

necessary. We will be as diligent as ever to drive efficiencies and 

control expenses, and we will begin to work through the business 

opportunities we have in front of us. 

  
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
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C L O S I N G   T H O U G H T S  

In closing, I want to repeat my thanks to the wonderful people 

at Wells Fargo who have worked tirelessly to sustain this great 

company. We are lucky that you have persevered through the 

tough times, and I and the members of our Operating Committee 

will do all we can to help guide us through the necessary changes 

we need to make. 

I’m confident in our ability to realize our potential — one that 

again puts us at the top of the respected financial institutions 

list, with a far more efficient organization and higher revenue 

growth than you see today. While there is much to do, and I know 

the path to success will be bumpy, I’m optimistic about our 

future and excited to be at a place with so many great people, 

and such strong franchises, doing incredibly important work. 

C H A R L E S   W.   S C H A R F  

C E O  
W e l l s   F a r g o   &   C o m p a n y  

 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
Our Performance 

23 

$ in millions, except per share amounts 

20 19 

20 18 

%  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 securities 

Loans 

Allowance for loan losses 

Goodwill 

Equity securities 

Assets 

Deposits 

Common stockholders’ equity 

Wells Fargo stockholders’ equity 

Total equity 
Tangible common equity1 

Capital ratios5: 

Total equity to assets 
Risk-based capital6: 

Common Equity Tier 1 

Tier 1 capital 

Total capital 

Tier 1 leverage 

Common shares outstanding 

Book value per common share7 

Tangible book value per common share1, 7 

Team members (active, full-time equivalent) 

$ 

$ 

$ 

$ 

$ 

19,549 
17,938 
4.05 

22,393 
20,689 
4.28 

1.02 % 

1.19 

10.23 
12.20 
68.4 

85,063 
26,885 

1.92 
4,393.1 
4,425.4 

11.53 
13.73 
65.0 

86,408 
30,282 

1.64 
4,799.7 
4,838.4 

950,956 
1,913,444 
1,286,261 
749,967 

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

2.73 % 

2.91 

497,125 
962,265 
9,551 
26,390 
68,241 
1,927,555 
1,322,626 
166,669 
187,146 
187,984 
138,506 

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

9.75 % 

10.39 

11.14 
12.76 
15.31 
8.31 
4,134.4 
40.31 
33.50 
259,800 

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

(13) 
(13) 
(5) 

(14) 

(11) 
(11) 
5 

(2) 
(11) 

17 
(8) 
(9) 

1 
1 
1 
– 

(6) 

3 
1 
(2) 
– 
24 
2 
3 
(4) 
(5) 
(5) 
(5) 

(6) 

(5) 
(5) 
(8) 
(8) 
(10) 
6 
5 
– 

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

rights) and goodwill and other intangibles on nonmarketable equity securities, 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 efciency ratio is noninterest expense divided by total revenue (net interest income and noninterest income). 

3  Pre-tax pre-provision proft (PTPP) is total revenue less noninterest expense. Management believes that PTPP is a useful fnancial 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  See the “Financial Review – Capital Management” section and Note 29 (Regulatory and Agency Capital Requirements) to Financial Statements in this Report for additional information. 

6  The risk-based capital ratios were calculated under the lower of the 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 refects fully phased-in common equity tier 1 capital, tier 1 capital and risk-weighted 
assets for the years ended December 31, 2019 and 2018, but refects all other ratios still in accordance with Transition Requirements. See the “Financial Review – Capital Management” section and Note 29 
(Regulatory and Agency Capital Requirements) to Financial Statements in this Report for additional information. 

7  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. 

 
 
 
 
 
 
 
 
 
 
Board of Directors 

J O H N   D.   B A K E R   I I   1 ,  3 ,  4 

Executive Chairman and CEO 
FRP Holdings, Inc. 

C E L EST 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 

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

Retired Chairman, President and CEO 
Edison International 

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

Chair 
Wells Fargo & Company 
Former member of the Federal 
Reserve Board of Governors 

WAY N E   M .   H EW E T T   2 ,  6 ,  7 

Senior Advisor, Permira 
and Chairman, DiversiTech Corporation 

D O NA L D   M .   JA M ES   4 ,  5 ,  6 

Retired Chairman 
Vulcan Materials Company 

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25 

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

JA M ES   H .   QU I G L EY   1 ,  7 

Retired Executive Vice President 
and Head of Global Employee 
Benefits business 
MetLife, Inc. 

C H A R L ES   H .   NO S K I   1 

Retired Vice Chairman and 
Former Chief Financial Officer 
Bank of America Corporation 

CEO Emeritus and Retired Partner 
Deloitte 

RO NA L D   L .   SA RG E N T   1 ,  5 ,  6 

Retired Chairman and CEO 
Staples, Inc. 

R I C H A R D   B .   PAY N E ,   J R .   3 

C H A R L ES   W.   S C H A R F  

Retired Vice Chairman 
Wholesale Banking 
U.S. Bancorp 

CEO 
Wells Fargo & Company 

J UA N   A .   P U JA DAS   3,  4,  7 

Retired Principal 
PricewaterhouseCoopers LLP 
and Former Vice Chairman 
Global Advisory Services 
PwC International 

S U Z A N N E   M .   VAU T R I NOT   2 ,  3 ,  7 

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

S T A N D I N G   C O M M I T T E E S  

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

|  As of February 15, 2020 

      
 
 
 
 
  
  
  
 
 
 
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
Corporate Responsibility: 2019 
Environmental, Social, and Governance Highlights 

Wells Fargo believes in creating a thriving global economy that benef its all stakeholders. 

By combining our resources and expertise with scale of operations, the company can effect 

positive societal change and inclusive economic growth. Below are examples of progress 

made on that journey. 

Building a better tomorrow starts with acknowledging the work still to be done. Wells Fargo 

is committed to continuing to do its part to build a stronger and more resilient company, 

workforce, global community, and environment. 

C OMM IT TED  

$1B 

HELPE D 

435K 

PROVIDED 
A P P R O X I M AT E LY  

$49B 

in philanthropic capital through 2025 

to address the U.S. housing affordability 

crisis — from homelessness and transitional 

housing to rentals and homeownership 

minority households purchase a home 

since 2016 through our commitment 

to increase homeownership among all 

minority communities 

in financing to sustainable businesses and 

projects since 2018 — with 67% toward low-

carbon opportunities. Achieved 24% of our goal 

to invest $200 billion by 2030 to accelerate 

the transition to a low-carbon economy 

26 

  
  
  
  
  
  
  
  
 
  
  
  
 
 
  
  
ENABLED 

9.2M 

customers to better manage their 

credit by providing free access to their 

FICO® Score 

ASSIS TED 

23K 

aspiring homeowners through LIFT 

programs to become homeowners 

through education and down payment 

assistance grants since 2012 

INT END  TO  MEET 

100% 

of our global electricity needs with 

renewable energy* and entered our largest 

long-term renewable energy purchase to 

date, supporting a new utility scale solar 

asset that is scheduled to begin delivering 

solar energy to the grid in 2021 

*Renewable energy sources include on-site solar, long-term contracts 
that fund net new sources of off-site renewable energy, and the purchase 
of renewable energy and renewable energy certificates (RECs). 

27 

INVESTED 

$455M 

in grants in 2019 to unlock economic 

opportunity for people and communities 

across the U.S. and internationally 

HELPED 

2M+ 

customers avoid overdraft 

charges with Overdraft Rewind® 

PROVIDED 

$1.15M 

in project financing for new wind, 

solar, and fuel cell projects providing 

2.6K+ megawatts of renewable 

energy capacity 

ACHIEVED A 

100% 

perfect score for the 16th year 

on the Corporate Equality Index 

(Human Rights Campaign) 

All data is for January 1, 2019 – December 31, 2019, unless otherwise noted. 

 
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
  
 
 
  
 
  
 
 
 
 
 
  
 
 
  
 
 
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“I’m confident in our ability 

to realize our potential — one 

that again puts us at the top 

of the respected financial 

institutions list, with a far 

more efficient organization 

and higher revenue growth 

than you see today.” 

C H A R L E S   W.   S C H A R F  

  
 
 
 
 
 
 
 
 
 
 
 
W E L L S  FA R G O   &   C O M P A N Y  2 0 1 9   F I N A N C I A L  RE P OR T  

30 

34 

51 

54 

56 

87 

93 

96 

100 

102 

103 

119 

119 

119 

120 

121 

122 

123 

124 

128 

129 

141 

142 

143 

Financial Review 

Overview 

Earnings Performance 

Balance Sheet Analysis 

Off-Balance Sheet Arrangements 

Risk Management 

Capital Management 

Regulatory Matters 

144 

151 

165 

167 

169 

5 

6 

7 

8 

9 

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

Loans and Allowance for Credit Losses 

Leasing Activity 

Equity Securities 

Premises, Equipment and Other Assets 

170 

10 

Securitizations and Variable Interest Entities 

180 

11 

Mortgage Banking Activities 

Critical Accounting Policies 

182 

12 

Intangible Assets 

Current Accounting Developments 

183 

13 

Deposits 

Forward-Looking Statements 

184 

14 

Short-Term Borrowings 

Risk Factors 

185 

15 

Long-Term Debt 

187 

16 

Guarantees, Pledged Assets and Collateral, and Other 

Commitments 

Controls and Procedures 

192 

17 

Legal Actions 

Disclosure Controls and Procedures 

196 

18 

Derivatives 

Internal Control Over Financial Reporting 

207 

19 

Fair Values of Assets and Liabilities 

Management’s Report on Internal Control over 

Financial Reporting 

Report of Independent Registered Public 

Accounting Firm 

227 

20 

Preferred Stock 

230 

21 

Common Stock and Stock Plans 

233 

22 

Revenue from Contracts with Customers 

Financial Statements 

236 

23 

Employee Benefits and Other Expenses 

Consolidated Statement of Income 

243 

24 

Income Taxes 

Consolidated Statement of Comprehensive 

245 

25 

Earnings and Dividends Per Common Share 

Income 

Consolidated Balance Sheet 

246 

26 

Other Comprehensive Income 

Consolidated Statement of Changes in Equity 

248 

27 

Operating Segments 

Consolidated Statement of Cash Flows 

250 

28 

Parent-Only Financial Statements 

253 

29 

Regulatory and Agency Capital Requirements 

Notes to Financial Statements 

Summary of Significant Accounting Policies 

Business Combinations 

Cash, Loan and Dividend Restrictions 

Trading Activities 

1 

2 

3 

4 

254 

256 

258 

Report of Independent Registered Public

Accounting Firm 

Quarterly Financial Data 

Glossary of Acronyms 

Wells Fargo & Company 

29 

 
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, 2019 (2019 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 definitions of terms used 
throughout this Report. 

Financial Review 

Overview 

Wells Fargo & Company is a diversified, community-based 
financial services company with $1.9 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 7,400 locations, 
more than 13,000 ATMs, digital (online, mobile and social), and 
contact centers (phone, email and correspondence), and we have 
offices in 32 countries and territories to support customers who 
conduct business in the global economy. With approximately 
260,000 active, full-time equivalent team members, we serve 
one in three households in the United States and ranked No. 29 
on Fortune’s 2019 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, 2019. 

On February 11, 2020, we announced a new organizational 

structure with five principal lines of business: Consumer and 
Small Business Banking; Consumer Lending; Commercial 
Banking; Corporate and Investment Banking; and Wealth and 
Investment Management. 

Wells Fargo’s top priority remains meeting its regulatory 
requirements in order to build the right foundation for all that 
lies ahead. To do that, the Company is committing the resources 
necessary to ensure that we operate with the strongest business 
practices and controls, maintain the highest level of integrity, and 
have in place the appropriate culture. 

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 Company’s Board of 
Directors (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 Company continues to engage with 
the FRB as the Company works to address the consent order 
provisions. The consent order also 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 an initial third-party review of the enhancements and 
improvements provided for in the plans. Until this third-party 
review is 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. As of the end of fourth quarter 2019, 
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 
In September 2016, we announced settlements with the CFPB, 
the OCC, and the Office of the Los Angeles City Attorney, and 
entered into related 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 a 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 to customers resulting from 
these matters and providing remediation. 

For additional information regarding retail sales practices 
matters, including related legal matters, see the “Risk Factors” 

30 

Wells Fargo & Company 

 
 
 
section and Note 17 (Legal Actions) to Financial Statements in 
this Report. 

Other Customer Remediation Activities 
Our priority of rebuilding trust has also included an effort to 
identify other areas or instances where customers may have 
experienced financial harm, provide remediation as appropriate, 
and implement additional operational and control procedures. 
We are working with our regulatory agencies in this effort. We 
have previously disclosed key areas of focus as part of our 
rebuilding trust efforts and are in the process of providing 
remediation for those matters. We have accrued for the 
reasonably estimable remediation costs related to our rebuilding 
trust efforts, which amounts may change based on additional 
facts and information, as well as ongoing reviews and 
communications with our regulators. 

As our ongoing reviews continue, it is possible that in the 
future we may identify additional items or areas of potential 
concern. To the extent issues are identified, we will continue to 
assess any customer harm and provide remediation as 
appropriate. For more information, including related legal and 
regulatory risk, see the “Risk Factors” section and Note 17 (Legal 
Actions) to Financial Statements in this Report. 

Financial Performance 
In 2019, we generated $19.5 billion of net income and diluted 
earnings per common share (EPS) of $4.05, compared with 
$22.4 billion of net income and EPS of $4.28 for 2018. Financial 
performance items for 2019 (compared with 2018) included: 
• 

revenue of $85.1 billion, down from $86.4 billion, with net 
interest income of $47.2 billion, down $2.8 billion, or 6%, and 
noninterest income of $37.8 billion, up $1.4 billion, or 4%; 
the net interest margin was 2.73%, down 18 basis points; 
noninterest expense of $58.2 billion, up $2.1 billion, or 4%; 
an efficiency ratio of 68.4%, compared with 65.0%; 
average loans of $951.0 billion, up $5.8 billion; 
average deposits of $1.3 trillion, up $10.4 billion; 
our credit results remained strong with a net charge-off rate 
of 0.29%, flat compared with a year ago; 
nonaccrual loans of $5.3 billion, down $1.2 billion, or 18%; 
$30.2 billion in capital returned to our shareholders through 
common stock dividends and net share repurchases, up 17% 
from $25.8 billion a year ago; and 
return on assets (ROA) of 1.02% and return on equity (ROE) 
of 10.23%, down from 1.19% and 11.53%, respectively. 

• 
• 
• 
• 
• 
• 

• 
• 

• 

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 2019 with strong 
credit quality and solid levels of liquidity and capital. Our total 
assets were $1.9 trillion at December 31, 2019. Cash and other 
short-term investments decreased $10.1 billion from 
December 31, 2018, reflecting lower cash balances, partially 
offset by an increase in federal funds sold and securities 
purchased under resale agreements. Debt securities increased 
$12.4 billion from December 31, 2018, predominantly due to 
increases in trading and held-to-maturity debt securities. Loans 
increased $9.2 billion from December 31, 2018, driven by 
increases in commercial and industrial loans, commercial real 
estate mortgage loans, real estate 1-4 family first mortgage 
loans, automobile loans, credit card loans, and lease financing, 

partially offset by decreases in commercial real estate 
construction loans, real estate 1-4 family junior lien mortgage 
loans, and other revolving credit and installment loans. 

Average deposits in 2019 were $1.3 trillion, up $10.4 billion 

from 2018, reflecting higher other time deposits, mortgage 
escrow deposits and commercial deposits. Our average deposit 
cost in 2019 was 67 basis points, up 23 basis points from a year 
ago, driven by increased retail banking promotional pricing for 
new deposits and a continued deposit mix shift to higher cost 
products. 

Credit Quality 
Credit quality remained solid in 2019, as losses remained low and 
we continued to originate high-quality loans, reflecting our long-
term risk focus. Net charge-offs were $2.8 billion, or 0.29% of 
average loans, in 2019, flat compared with 2018. 

Our commercial portfolio net charge-offs were $652 million, 

or 13 basis points of average commercial loans, in 2019, 
compared with $429 million, or 9 basis points, in 2018, 
predominantly driven by increased losses in our commercial and 
industrial loan portfolio. Our consumer portfolio net charge-offs 
were $2.1 billion, or 48 basis points of average consumer loans, in 
2019, compared with $2.3 billion, or 52 basis points, in 2018, 
predominantly driven by decreased losses in our automobile 
portfolio, partially offset by increased losses in our credit card 
portfolio. 

The allowance for credit losses of $10.5 billion at 

December 31, 2019, decreased $251 million from the prior year. 
The allowance coverage for total loans was 1.09% at 
December 31, 2019, compared with 1.12% at December 31, 
2018. The allowance covered 3.8 times net charge-offs in 2019, 
compared with 3.9 in 2018. Future amounts of the allowance for 
credit losses will be based on a variety of factors, including loan 
growth, portfolio performance and general economic conditions. 
Our provision for credit losses in 2019 was $2.7 billion, compared 
with $1.7 billion in 2018. The provision for credit losses in both 
2019 and 2018 reflected continuing solid underlying credit 
performance. The provision for credit losses in 2018 also 
reflected a higher level of credit quality improvement compared 
with 2019, as well as an improvement in the outlook associated 
with 2017 hurricane-related losses. 

Nonperforming assets (NPAs) at December 31, 2019, were 

$5.6 billion, down $1.3 billion from December 31, 2018. 
Nonaccrual loans decreased $1.2 billion from December 31, 
2018, driven by improvement across all consumer loan 
categories, including a decrease in consumer nonaccruals from 
sales of residential real estate mortgage loans as well as the 
reclassification of real estate 1-4 family mortgage nonaccrual 
loans to mortgage loans held for sale (MLHFS) in 2019. 
Foreclosed assets were down $148 million from December 31, 
2018. 

Capital 
Our financial performance in 2019 allowed us to maintain a solid 
capital position with total equity of $188.0 billion at 
December 31, 2019, compared with $197.1 billion at 
December 31, 2018. We returned $30.2 billion to shareholders in 
2019 ($25.8 billion in 2018) 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 168%. During 
2019, we increased our quarterly common stock dividend from 
$0.43 to $0.51 per share. We continued to reduce our common 
share count through the repurchase of 502.4 million common 

Wells Fargo & Company 

31 

Overview (continued) 

shares during the year. We expect our share count to continue to 
decline in 2020 as a result of anticipated net share repurchases. 
We believe an important measure of our capital strength is 
our Common Equity Tier 1 (CET1) ratio, which was 11.14% as of 
December 31, 2019, down from 11.74% a year ago, but still well 
above our internal target of 10%. Likewise, our other regulatory 
capital ratios remained strong. As of December 31, 2019, our 

Table 1:  Six-Year Summary of Selected Financial Data 

eligible external total loss absorbing capacity (TLAC) as a 
percentage of total risk-weighted assets was 23.28%, compared 
with the required minimum of 22.0%. See the “Capital 
Management” section in this Report for more information 
regarding our capital, including the calculation of our regulatory 
capital amounts. 

(in millions, except per share amounts) 

2019 

2018 

2017 

2016 

2015 

2014 

% 
Change
2019/
2018 

Five-year
compound
growth 
rate 

Income statement 

Net interest income 

Noninterest income 

Revenue 

Provision for credit losses 

Noninterest expense 

Net income before noncontrolling 

interests 

Less: Net income from noncontrolling 

interests 

Wells Fargo net income 

Earnings per common share 

Diluted earnings per common share 

Dividends declared per common share 

Balance sheet (at year end) 

Federal funds sold and securities 

$ 

47,231 

37,832 

85,063 

2,687 

58,178 

20,041 

492 

19,549 

4.08 

4.05 

1.920 

purchased under resale agreements 

$ 

102,140 

Debt securities 

Loans 

Allowance for loan losses 

Goodwill 

Equity securities 

Assets 

Deposits 

Long-term debt 

Wells Fargo stockholders’ equity 

Noncontrolling interests 

Total equity 

497,125 

962,265 

9,551 

26,390 

68,241 

1,927,555 

1,322,626 

228,191 

187,146 

838 

187,984 

49,995 

36,413 

86,408 

1,744 

56,126 

49,557 

38,832 

88,389 

2,528 

58,484 

47,754 

40,513 

88,267 

3,770 

52,377 

45,301 

40,756 

86,057 

2,442 

49,974 

43,527 

40,820 

84,347 

1,395 

49,037 

22,876 

22,460 

22,045 

23,276 

23,608 

483 

277 

107 

382 

551 

22,393 

22,183 

21,938 

22,894 

23,057 

4.31 

4.28 

1.640 

80,207 

484,689 

953,110 

9,775 

26,418 

55,148 

4.14 

4.10 

1.540 

80,025 

473,366 

956,770 

11,004 

26,587 

62,497 

4.03 

3.99 

1.515 

65,725 

459,038 

967,604 

11,419 

26,693 

49,110 

4.18 

4.12 

1.475 

49,721 

394,744 

916,559 

11,545 

25,529 

40,266 

4.17 

4.10 

1.350 

39,210 

350,661 

862,551 

12,319 

25,705 

44,005 

1,895,883 

1,951,757 

1,930,115 

1,787,632 

1,687,155 

1,286,170 

1,335,991 

1,306,079 

1,223,312 

1,168,310 

229,044 

196,166 

900 

225,020 

206,936 

1,143 

255,077 

199,581 

916 

199,536 

192,998 

893 

183,943 

184,394 

868 

197,066 

208,079 

200,497 

193,891 

185,262 

(6)% 

4 

(2) 

54 

4 

(12) 

2 

(13) 

(5) 

(5) 

17 

27  % 

3 

1 

(2) 

— 

24 

2 

3 

— 

(5) 

(7) 

(5) 

2 

(2) 

— 

14 

3 

(3) 

(2) 

(3) 

— 

— 

7 

21 

7 

2 

(5) 

1 

9 

3 

3 

4 

— 

(1) 

— 

32 

Wells Fargo & Company 

  
 
Table 2:  Ratios and Per Common Share Data 

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 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) 

Year ended December 31, 

2019 

2018 

2017 

1.02% 

10.23 

12.20 

68.4 

8.65 

9.75 

11.14 

12.76 

15.31 

8.31 

9.16 

10.33 

47.4 

40.31 

$ 

1.19 

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 

1.15 

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 

(1) 

(2) 
(3) 
(4) 

(5) 
(6) 

Tangible common equity is a non-GAAP financial measure and represents total equity less preferred equity, noncontrolling interests, goodwill, certain identifiable intangible assets (other than 
mortgage servicing rights) and goodwill and other intangibles on nonmarketable equity securities, 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 generally accepted accounting principles (GAAP) financial measures, see the 
“Capital Management – Tangible Common Equity” section in this Report. 
The efficiency ratio is noninterest expense divided by total revenue (net interest income and noninterest income). 
See the “Capital Management” section and Note 29 (Regulatory and Agency Capital Requirements) to Financial Statements in this Report for additional information. 
The risk-based capital ratios were calculated under the lower of the 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 for the years ended December 31, 2019 and 2018, but reflects all other ratios still in accordance with Transition Requirements. See the “Capital Management” 
section and Note 29 (Regulatory and Agency Capital Requirements) to Financial Statements in this Report for additional information. 
Dividend payout ratio is dividends declared per common share as a percentage of diluted earnings per common share. 
Book value per common share is common stockholders’ equity divided by common shares outstanding. 

Wells Fargo & Company 

33 

  
 
Earnings Performance 

Wells Fargo net income for 2019 was $19.5 billion ($4.05 diluted 
EPS), compared with $22.4 billion ($4.28 diluted EPS) for 2018. 
Net income decreased in 2019, compared with 2018, due to a 
$2.8 billion decrease in net interest income, a $943 million 
increase in provision for credit losses, and a $2.1 billion increase 
in noninterest expense, partially offset by a $1.4 billion increase 
in noninterest income, and a $1.5 billion decrease in income tax 
expense. Net income in 2019 included a net discrete income tax 
expense of $435 million, compared with a net discrete income 
tax expense of $627 million in 2018. 

Revenue, the sum of net interest income and noninterest 
income, was $85.1 billion in 2019, compared with $86.4 billion in 
2018. Revenue decreased $1.3 billion in 2019, compared with 
2018, due to a decrease in net interest income, partially offset by 
an increase in noninterest income. Our diversified sources of 
revenue generated by our businesses continued to be balanced 
between net interest income and noninterest income. In 2019, 
net interest income of $47.2 billion represented 56% of revenue, 
compared with $50.0 billion (58%) in 2018. See later in this 
section for discussions of net interest income, noninterest 
income and noninterest expense. 

Table 3 presents the components of net interest income on 

a tax-equivalent basis, noninterest income and noninterest 
expense as a percentage of revenue for year-over-year results. 
Net interest income is presented on a taxable-equivalent basis to 
consistently reflect income from taxable and tax-exempt loans 
and debt and equity securities based on a 21% federal statutory 
tax rate for the periods ended December 31, 2019 and 2018, and 
35% for the period ended December 31, 2017. 

For a discussion of our 2018 financial results compared with 

2017, see the “Earnings Performance” section of our Annual 
Report on Form 10-K for the year ended December 31, 2018. 

34 

Wells Fargo & Company 

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

(in millions) 

Interest income (on a taxable-equivalent basis) 

Debt securities 

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 

Technology and 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) 

(1) 
(2) 

See Table 7 – Noninterest Income in this Report for additional detail. 
See Table 8 – Noninterest Expense in this Report for additional detail. 

2019 

% of 
revenue 

2018 

% of 
revenue 

2017 

% of 
revenue 

Year ended December 31, 

$ 

15,456 

18% 

$ 

14,947 

17% 

$ 

14,084 

16% 

813 

79 

44,253 

966 

5,129 

66,696 

8,635 

2,317 

7,350 

551 

18,853 

47,843 

(612) 

47,231 

4,798 

14,072 

4,016 

3,084 

2,715 

378 

993 

140 

2,843 

1,612 

3,181 

37,832 

18,382 

10,828 

5,874 

2,763 

2,945 

108 

526 

4,321 

3,198 

9,233 

58,178 

85,063 

$ 

1 

— 

52 

1 

7 

79 

10 

3 

9 

— 

22 

57 

(1) 

56 

6 

17 

5 

4 

3 

— 

1 

— 

3 

2 

3 

44 

22 

13 

7 

3 

3 

— 

1 

5 

4 

10 

68 

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 

6 

76 

7 

2 

8 

— 

17 

59 

(1) 

58 

5 

17 

5 

4 

3 

— 

1 

— 

2 

2 

3 

42 

21 

12 

6 

3 

3 

1 

1 

4 

4 

10 

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 

38,832 

17,363 

10,442 

5,566 

2,237 

2,849 

1,152 

1,287 

5,492 

3,813 

8,283 

58,484 

1 

— 

47 

1 

3 

68 

3 

1 

6 

1 

11 

57 

(1) 

56 

6 

16 

4 

4 

5 

1 

1 

1 

2 

2 

2 

44 

20 

12 

6 

3 

3 

1 

1 

6 

4 

10 

66 

$ 

86,408 

$ 

88,389 

Wells Fargo & Company 

35 

  
 
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. The 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 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, variable sources 
of interest income, such as loan fees, periodic dividends, and 
collection of interest on nonaccrual loans, can fluctuate from 
period to period. 

Net interest income on a taxable-equivalent basis was 
$47.8 billion in 2019, compared with $50.7 billion in 2018. Net 
interest margin on a taxable-equivalent basis was 2.73% in 2019, 
compared with 2.91% in 2018. The decrease in both net interest 
income and net interest margin in 2019, compared with 2018, 
was driven by unfavorable impacts of repricing due to a 
flattening yield curve and mix of earning assets and funding 
sources, including sales of high yielding Pick-a-Pay loans, as well 
as higher costs on promotional retail banking deposits. 

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. 

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 non-U.S. offices. Average 
deposits were $1.3 trillion in 2019, flat compared with 2018, and 
represented 135% of average loans in both 2019 and 2018. 
Average deposits were 73% of average earning assets in both 
2019 and 2018. Our average deposit cost in 2019 was 67 basis 
points, up 23 basis points from a year ago, driven by increased 
retail banking promotional pricing for new deposits and a 
continued deposit mix shift to higher cost products. 

Table 5 presents the individual components of net interest 

income and the net interest margin. 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% 
federal statutory tax rate for the periods ended December 31, 
2019 and 2018, and 35% for the period ended December 31, 
2017. 

36 

Wells Fargo & Company 

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

(in millions) 

Earning assets 
Interest-earning deposits with banks 
Federal funds sold and 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 and mortgage-backed securities 

Other debt securities 

Total held-to-maturity debt securities 

Total debt securities 

Mortgage loans held for sale (1) 

Loans held for sale (1) 

Loans: 

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 non-U.S. 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. 

2019 

% of 
earning 
assets 

Average
balance 

Year ended December 31, 
2018 

Average 
balance 

% of 
earning 
assets 

Change
from prior 
year 

% Change
from prior
year 

$ 

135,741 
99,286 

$ 

8% 
6 

156,366 
78,547 

9% 
5 

$ 

(20,625) 
20,739 

(13)% 
26 

93,655 

15,293 

44,203 

154,160 
5,363 

159,523 
43,675 

262,694 

44,850 
8,644 

95,559 

52 

149,105 

505,454 

19,808 

1,708 

284,888 

64,274 

121,813 

21,183 

19,302 

511,460 

288,059 

31,989 

38,865 

45,901 

34,682 

439,496 

950,956 

35,930 

5,579 

5 

1 

3 

9 
— 

9 
2 

15 

3 
1 

5 

— 

9 

29 

1 

— 

16 

4 

7 

1 

1 

29 

16 

2 

2 

3 

2 

25 

54 

2 

— 

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 

— 

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 

10,129 

12 

8,675 

(3,681) 

(1,892) 
(2,406) 

(4,298) 
(3,200) 

(2,504) 

115 
2,391 

1,343 

(309) 

3,540 

11,165 

1,414 

(818) 

9,232 

3,556 

(1,134) 

(2,426) 

(90) 

9,138 

3,881 

(4,698) 

2,085 

(2,214) 

(2,433) 

(3,379) 

5,759 

(2,162) 

508 

131 

(8) 

(1) 
(31) 

(3) 
(7) 

(1) 

— 
38 

1 

(86) 

2 

2 

8 

(32) 

3 

6 

(1) 

(10) 

— 

2 

1 

(13) 

6 

(5) 

(7) 

(1) 

1 

(6) 

10 

$ 

1,754,462 

100% 

$ 

1,738,482 

100% 

$ 

15,980 

1 %  

$ 

59,121 

4% 

$ 

$ 

(4,122) 

(7)% 

40 

2 

5 

3 

54 
7 

13 

1 

75 

25 

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 

21,075 

9,613 

8,546 

(10,507) 

24,605 

11,070 

8,223 

(1,877) 

42,021 

(26,041) 

100% 

$ 

1,738,482 

100% 

$ 

15,980 

18,777 

26,453 

105,180 

150,410 

358,312 

53,496 

203,356 

(464,754) 

150,410 

1,888,892 

$ 

$ 

781 

(44) 

7,835 

8,572 

$ 

(14,201) 

2,467 

(5,735) 

26,041 

8,572 

24,552 

$ 

$ 

705,957 

30,266 

93,368 

53,438 

942,150 

115,337 

232,491 

25,771 

1,315,749 

438,713 
1,754,462 

19,558 

26,409 

113,015 

$ 

$ 

$ 

158,982 

$ 

344,111 

55,963 

197,621 

(438,713) 

158,982 

1,913,444 

$ 

$ 

Wells Fargo & Company 

3 

47 

10 

(16) 

3 

11 

4 

(7) 

3 

(6) 

1 %  

4 %  

— 

7 

6 %  

(4)% 

5 

(3) 

(6) 

6 %  

1 %  

37 

  
 
Earnings Performance (continued) 

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

(in millions) 

Earning assets 
Interest-earning deposits with banks 
Federal funds sold and securities purchased under resale agreements 
Debt securities (2): 

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 

Total held-to-maturity debt securities 

Total debt securities 

Mortgage loans held for sale (3) 
Loans held for sale (3) 
Loans: 

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 (3) 

Equity securities 
Other 

Total earning assets 

Funding sources 
Deposits: 

Interest-bearing checking 
Market rate and other savings 
Savings certificates 
Other time deposits 
Deposits in non-U.S. 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 (4) 

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 

Average 
balance 

Yields/ 
rates 

2019 
Interest 
income/ 
expense 

Average 
balance 

Yields/ 
rates 

2018 
Interest 
income/ 
expense 

Average 
balance 

Yields/ 
rates 

2017 
Interest 
income/ 
expense 

$  135,741 
99,286 

2.12%  $  2,875 
2,164 
2.18 

156,366 
78,547 

1.82%  $  2,854 
1,431 
1.82 

201,864 
74,697 

1.07%  $  2,162 
735 
0.98 

93,655 

3.36 

3,149 

83,526 

3.42 

2,856 

74,475 

3.16 

2,356 

15,293 
44,203 

154,160 
5,363 
159,523 

43,675 
262,694 

44,850 
8,644 
95,559 
52 

149,105 
505,454 

19,808 
1,708 

284,888 

64,274 

121,813 
21,183 
19,302 

511,460 

288,059 
31,989 
38,865 
45,901 
34,682 

439,496 

950,956 

2.07 
3.87 

2.85 
4.19 
2.90 

4.23 
3.23 

2.19 
3.97 
2.60 
3.71 

2.56 
3.06 

4.10 
4.60 

4.25 

3.71 

4.40 
5.17 
4.52 

4.27 

3.81 
5.63 
12.58 
5.15 
6.95 

5.11 

4.65 

316 
1,709 

4,397 
225 
4,622 

1,846 
8,493 

982 
343 
2,487 
2 

3,814 
15,456 

813 
79 

12,107 

2,385 

5,356 
1,095 
873 

21,816 

10,974 
1,800 
4,889 
2,362 
2,412 

22,437 

44,253 

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 

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 

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 

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 

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 

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 

35,930 
5,579 
$  1,754,462 

966 
2.69 
1.62 
90 
3.80%  $  66,696 

38,092 
5,071 
1,738,482 

999 
2.62 
1.46 
74 
3.76%  $  65,308 

36,105 
5,069 
1,776,590 

821 
2.27 
0.85 
44 
3.40%  $  60,233 

$ 

59,121 
705,957 
30,266 
93,368 
53,438 
942,150 

115,337 
232,491 
25,771 

1,315,749 

438,713 

$  1,754,462 

$ 

19,558 
26,409 
113,015 

$  158,982 

$  344,111 
55,963 
197,621 
(438,713) 

$  158,982 

$  1,913,444 

1.33%  $ 
0.59 
1.59 
2.46 
1.75 
0.92 

2.01 
3.16 
2.13 

1.43 

— 

1.07 

789 
4,132 
481 
2,295 
938 
8,635 

2,317 
7,350 
551 

18,853 

— 

18,853 

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 

0.96%  $ 
0.31 
0.57 
2.25 
1.30 
0.61 

1.65 
2.99 
2.21 

1.15 

— 

0.85 

606 
2,157 
118 
1,906 
835 
5,622 

1,719 
6,703 
610 

14,654 

— 

14,654 

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 

0.49%  $ 
0.14 
0.30 
1.43 
0.68 
0.32 

0.77 
2.09 
1.94 

0.72 

— 

0.53 

242 
983 
67 
880 
841 
3,013 

761 
5,157 
424 

9,355 

— 

9,355 

2.73%  $  47,843 

2.91%  $  50,654 

2.87%  $  50,878 

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 

Average prime rate 
Average three-month London Interbank Offered Rate (LIBOR) 

5.28% 
2.33 

4.91% 
2.31 

4.10% 
1.26 

(1) 
(2) 
(3) 
(4) 

Yields/rates and amounts include the effects of hedge and risk management activities associated with the respective asset and liability categories. 
Yields/rates are based on interest income/expense amounts for the period. The average balance amounts represent amortized cost for the periods presented. 
Nonaccrual loans and related income are included in their respective loan categories. 
Includes taxable-equivalent adjustments of $612 million, $659 million and $1.3 billion for the years ended December 31, 2019, 2018 and 2017, respectively, predominantly related to tax-exempt 
income on certain loans and securities. 

38 

Wells Fargo & Company 

  
 
 
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 
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. 

Table 6:  Analysis of Changes in Net Interest Income 

(in millions) 

Increase (decrease) in interest income: 

Interest-earning deposits with banks 

Federal funds sold and 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 

  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 

Total increase in interest income 

Increase (decrease) in interest expense: 

Deposits: 

Interest-bearing checking 

Market rate and other savings 

Savings certificates 

Other time deposits 

Deposits in non-U.S. offices 

Total interest-bearing deposits 

Short-term borrowings 

Long-term debt 

Other liabilities 

2019 over 2018 

Year ended December 31, 

2018 over 2017 

Volume 

Rate 

Total 

Volume 

Rate 

Total 

$ 

(407) 

419 

428 

314 

343 

(50) 

21 

733 

293 

204 

(97) 

49 

(133) 

(84) 

(134) 

(111) 

2 

72 

266 

(13) 

327 

36 

(61) 

642 

242 

77 

(72) 

(46) 

843 

(507) 

(175) 

211 

(129) 

(76) 

(676) 

167 

(33) 

16 

1,388 

183 

1,975 

363 

389 

103 

29 

46 

99 

(30) 

69 

5 

149 

— 

(25) 

233 

(1) 

207 

(23) 

(21) 

252 

112 

128 

52 

(42) 

502 

(662) 

88 

(51) 

(14) 

91 

(548) 

(46) 

26 

9 

993 

225 

1,910 

288 

187 

255 

175 

(143) 

(50) 

(103) 

(153) 

(139) 

(260) 

2 

97 

33 

(12) 

120 

59 

(40) 

390 

130 

(51) 

(124) 

(4) 

341 

155 

(263) 

262 

(115) 

(167) 

(128) 

213 

(59) 

7 

395 

(42) 

65 

75 

202 

(152) 

148 

196 

254 

(38) 

560 

(165) 

(569) 

40 

298 

(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 

— 

(860) 

82 

4 

(5) 

407 

(534) 

(46) 

43 

(495) 

122 

(376) 

(484) 

1,261 

656 

202 

30 

(92) 

281 

(76) 

205 

256 

399 

— 

(62) 

16 

22 

(24) 

86 

43 

692 

696 

500 

(127) 

(276) 

566 

(273) 

293

186 

76 

1 

(63) 

389 

(40)

287 

(9) 

90 

1,131 

1,269 

399 

692 

201 

194 

504 

420 

150 

204 

2,617 

2,547 

27 

225 

177 

(91) 

196 

534 

3,151 

131 

30 

5,935 

282 

1,170 

56 

619 

528 

2,655 

915 

2,041 

64 

5,675 

260 

275 

(87) 

323 

(603) 

80 

(12) 

2,535 

178 

30 

5,075 

364 

1,174 

51 

1,026 

(6) 

2,609 

958 

1,546 

186

5,299 

(224) 

Wells Fargo & Company 

39 

         Total increase in interest expense 

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

$ 

2,865 

3,013 

402 

393 

(21) 

3,639 

(2,646) 

598 

647 

(59) 

4,199 

(2,811) 

  
 
Earnings Performance (continued) 

Noninterest Income 

Table 7:  Noninterest Income 

(in millions) 

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 

Cash network fees 
Commercial real estate 

brokerage commissions 

Wire transfer and other remittance fees 
All other fees 

Total other fees 

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 

Year ended December 31, 

2019 

$ 

4,798 

2018 

4,716 

2017 

5,111 

9,237 

3,038 

1,797 

14,072 

4,016 

1,379 

452 

358 

474 
421 

9,436 

3,316 

1,757 

14,509 

3,907 

1,526 

481 

468 

477 
432 

9,358 

3,372 

1,765 

14,495 

3,960 

1,568 

506 

462 

448 
573 

3,084 

3,384 

3,557 

522 

1,373 

1,427 

2,193 

2,715 

378 

993 

140 

2,843 

1,612 

658 

2,523 

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 

Total 

$  37,832 

36,413 

38,832 

Noninterest income of $37.8 billion represented 44% of revenue 
for 2019, compared with $36.4 billion, or 42%, for 2018 and 
$38.8 billion, or 44%, for 2017. The increase in noninterest 
income in 2019, compared with 2018, was predominantly due to 
higher net gains from equity securities (including higher deferred 
compensation plan investment results, which are offset in 
employee benefits expense), higher all other income, and higher 
net gains from trading activities. These increases in 2019, 
compared with 2018, were partially offset by lower trust and 
investment fees, mortgage banking income, and other fees. The 
decline in noninterest income in 2018, compared with 2017, was 
predominantly due to lower net gains on mortgage loan 
origination/sales activities driven by decreased origination 
volumes and margins, 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 in 
2018, compared with 2017, were partially offset by higher gains 
from equity securities and higher all other income. For more 
information on our performance obligations and the nature of 
services performed for certain of our revenues discussed below, 
see Note 22 (Revenue from Contracts with Customers) to 
Financial Statements in this Report. 

Service charges on deposit accounts increased to $4.8 billion 

in 2019, compared with $4.7 billion in 2018, predominantly due 
to higher overdraft fees resulting from increased consumer 
payment transactions, partially offset by the impact of a higher 
earnings credit rate applied to commercial accounts due to 
higher interest rates. 

Brokerage advisory, commissions and other fees decreased 

to $9.2 billion in 2019, compared with $9.4 billion in 2018, due to 
lower asset-based fees and lower transactional revenue. Retail 

brokerage client assets totaled $1.6 trillion at December 31, 
2019, compared with $1.5 trillion at December 31, 2018. Asset-
based fees are calculated on the market value of the assets as of 
the beginning of each quarter. 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 fees decreased to 
$3.0 billion in 2019, compared with $3.3 billion in 2018, largely 
driven by lower trust fees due to the sale of our Institutional 
Retirement and Trust (IRT) business in 2019. 

Our assets under management (AUM), including IRT client 

assets still on our platform, totaled $705.9 billion at 
December 31, 2019, compared with $638.3 billion at 
December 31, 2018. Substantially all of our AUM is managed by 
our Wealth and Investment Management (WIM) operating 
segment. Our assets under administration (AUA), including IRT 
client assets still on our platform, totaled $1.8 trillion at 
December 31, 2019, compared with $1.7 trillion at December 31, 
2018. We had AUM and AUA associated with the IRT business of 
$21 billion and $915 billion, respectively, at December 31, 2019. 
No IRT client assets were transitioned to the buyer’s platform as 
of December 31, 2019. 

We closed the sale of our IRT business on July 1, 2019. We 
will continue to administer client assets at the direction of the 
buyer for up to 24 months from the closing date pursuant to a 
transition services agreement. The buyer will receive post-closing 
revenue from the client assets and will pay us a fee for certain 
costs that we incur to administer the client assets during the 
transition period. The transition services fee will be recognized as 
other noninterest income, and the expenses we incur will be 
recognized in the same manner as they were prior to the close of 
the sale. Transition period revenue is expected to approximate 
transition period expenses and is subject to downward 
adjustment as client assets transition to the buyer’s platform. 
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. 

Other fees decreased to $3.1 billion in 2019 from 
$3.4 billion in 2018, predominantly driven by the sale of our 
commercial real estate brokerage business (Eastdil Secured 
(Eastdil)) on October 1, 2019 and lower lending related charges 
and fees. 

Mortgage banking income, consisting of net servicing 
income and net gains on loan origination/sales activities, totaled 
$2.7 billion in 2019, compared with $3.0 billion in 2018. For more 
information, see Note 11 (Mortgage Banking Activities) to 
Financial Statements in this Report. 

Net servicing income was $522 million in 2019, compared 
with $1.4 billion in 2018, due to a decrease in net servicing fees 
and changes in the fair value of mortgage servicing rights 
(MSRs). Net servicing fees decreased $369 million from 2018, 
primarily driven by a decrease in contractually specified fees as a 
result of prepayments and sales of MSRs. In addition to servicing 
fees, net servicing income includes amortization of commercial 
MSRs, changes in the fair value of residential MSRs, as well as 
changes in the fair value of derivatives (economic hedges) used 
to hedge the residential MSRs. The total fair value of our 
residential MSRs declined in 2019, compared with 2018, driven 
by lower mortgage interest rates and higher prepayments. The 
net MSR valuation loss on our residential MSRs increased in 

40 

Wells Fargo & Company 

  
2019, compared with 2018, due to a decrease in hedge carry 
income from a flatter yield curve environment in 2019. Table 7a 
presents the components of the market-related valuation 
changes to our residential MSRs, net of hedge results. 

Table 7a:  Market-Related Valuation Changes on Residential MSRs, Net 
of Hedge Results 

(in millions) 

Year ended December 31, 

2019 

2018 

2017 

MSR valuation gain (loss) 

$  (2,569) 

960 

(126) 

Net derivative gains (losses) from economic 

hedges of residential MSRs 

2,318 

(1,072) 

Net MSR valuation gain (loss) 

$ 

(251) 

(112) 

413 

287 

Our portfolio of loans serviced for others was $1.6 trillion at 

December 31, 2019, and $1.7 trillion at December 31, 2018. At 
December 31, 2019, the ratio of combined residential and 
commercial MSRs to related loans serviced for others was 0.79%, 
compared with 0.94% at December 31, 2018. 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 

$2.2 billion in 2019, compared with $1.6 billion in 2018. The 
increase in 2019, compared with 2018, was primarily due to 
increases in origination volumes and margins. 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 7b presents the information used in determining the 
production margin. 

Table 7b:  Selected Mortgage Production Data 

Year ended December 31, 

2019 

2018 

2017 

Net gains on mortgage loan

origination/sales activities
(in millions): 

Residential 

Commercial 

(A) 

$ 

1,518 

1,174 

2,140 

337 

265 

358 

Residential pipeline and 

unsold/repurchased loan 
management (1) 

Total 

Residential real estate 

originations (in billions): 

Held-for-sale 

(B) 

Held-for-investment 

Total 

Production margin on

residential held-for-sale 
mortgage originations 

338 

205 

425 

$ 

2,193 

1,644 

2,923 

$ 

$ 

135 

69 

204 

132 

45 

177 

160 

52 

212 

(A)/(B) 

1.12% 

0.89 

1.34 

(1) 

Primarily 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 1.12% for 2019, compared with 
0.89% for 2018. The increase in the production margin in 2019, 
compared with 2018, was due to higher margins in both retail 
and correspondent production channels and a shift to more retail 
origination volume, which has a higher production margin. 

Mortgage applications were $311 billion in 2019, compared 

with $230 billion in 2018. The real estate 1-4 family first 
mortgage unclosed pipeline was $33 billion at December 31, 
2019, compared with $18 billion at December 31, 2018. 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 11 (Mortgage Banking Activities) and 
Note 19 (Fair Values of Assets and Liabilities) to Financial 
Statements in this Report. 

Net gains from trading activities, which reflect unrealized 
changes in fair value of our trading positions and realized gains 
and losses, were $993 million in 2019, compared with 
$602 million in 2018. The increase in 2019, compared with 2018, 
reflected higher trading volumes for rates and commodities, 
credit, and residential mortgage-backed securities, partially 
offset by lower equity and foreign exchange trading income. Net 
gains from trading activities exclude interest and dividend 
income and expense on trading securities, which are reported 
within interest income from debt and equity securities and other 
interest income. 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 $3.0 billion 

for 2019 and $1.6 billion for 2018. The increase in 2019 was 
predominantly driven by higher deferred compensation gains 
(offset in employee benefits expense) and higher unrealized 
gains on equity securities, partially offset by lower net realized 
gains from nonmarketable equity securities. Table 8a presents 
results for our deferred compensation plan and related 
investments. Net gains on debt and equity securities also 
included other-than-temporary impairment (OTTI) write-downs 
of $308 million for 2019 and $380 million for 2018. The 
decrease in OTTI in 2019 reflected a $214 million impairment 
taken in 2018 related to the sale of our ownership stake in The 
Rock Creek Group, LP (RockCreek), partially offset by higher 
write-downs in our investment portfolio in 2019. 

Lease income was $1.6 billion in 2019, compared with 
$1.8 billion in 2018. The decrease in 2019, compared with 2018, 
was driven by reductions in the size of the equipment leasing 
portfolio. 

All other income was $2.5 billion in 2019, compared with 

$1.8 billion in 2018. All other income includes losses on low 
income housing tax credit investments (excluding related tax 
credits recorded in income tax expense), 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 all other income in 2019, compared with 2018, 
was predominantly driven by pre-tax gains on the sales of our IRT 
business, Eastdil, and Business Payroll Services, partially offset 
by lower gains from the sales of purchased credit-impaired (PCI) 
loans in 2019, as well as higher losses on low income housing tax 
credit investments in 2019. 

Wells Fargo & Company 

41 

  
  
 
Earnings Performance (continued) 

Noninterest Expense 

Table 8:  Noninterest Expense 

(in millions) 

Salaries 

Commission and incentive compensation 

10,828 

$ 

18,382 

Year ended December 31, 

2019 

2018 

2017 

Employee benefits 

Technology and equipment 

Net occupancy (1) 

Core deposit and other intangibles 

FDIC and other deposit assessments 

Operating losses 

Outside professional services 

Contract services (2) 

Leases (3) 

Advertising and promotion 

Outside data processing 

Travel and entertainment 

Postage, stationery and supplies 

Telecommunications 

Foreclosed assets 

Insurance 

All other (2) 

Total 

17,834 

10,264 

17,363 

10,442 

4,926 

2,444 

2,888 

1,058 

1,110 

3,124 

3,306 

2,192 

1,334 

857 

660 

618 

515 

361 

188 

101 

5,566 

2,237 

2,849 

1,152 

1,287 

5,492 

3,813 

1,638 

1,351 

614 

891 

687 

544 

364 

251 

100 

5,874 

2,763 

2,945 

108 

526 

4,321 

3,198 

2,489 

1,155 

1,076 

673 

580 

518 

367 

163 

100 

2,112 

2,346 

1,843 

$ 

58,178 

56,126 

58,484 

(1) 
(2) 

(3) 

Represents expenses for both leased and owned properties. 
The amount for 2017 has been revised to conform with the current period presentation 
whereby temporary help is included in contract services rather than in all other noninterest 
expense. 
Represents expenses for assets we lease to customers. 

Noninterest expense was $58.2 billion in 2019, up 4% from 
$56.1 billion in 2018, which was down 4% from $58.5 billion in 
2017. The increase in 2019, compared with 2018, was driven by 
higher personnel expenses, operating losses, technology and 
equipment, and advertising and promotion expense, partially 
offset by lower core deposit and other intangibles expense, 
Federal Deposit Insurance Corporation (FDIC), leases, and other 
expense. The decrease in 2018, compared with 2017, was driven 
by lower operating losses from a decline in litigation accruals, 
lower personnel expenses, lower outside data processing, and 
lower FDIC expense, partially offset by higher advertising and 
promotion, technology and equipment, and other expense. 

Personnel expenses, which include salaries, commissions, 

incentive compensation and employee benefits, were up 
$2.1 billion, or 6%, in 2019, compared with 2018, due to higher 
deferred compensation costs (offset in net gains from equity 
securities), higher salaries driven by the impact of staffing mix 
changes and annual salary increases, as well as higher incentive 
compensation and commissions. The increase in incentive 
compensation and commissions was due to increased revenue 
from mortgage banking originations, market sensitive 
businesses (trading, debt and equity securities activities) and 
investment banking, partially offset by lower brokerage fees. 
Table 8a presents results for our deferred compensation plan and 
related investments. 

Table 8a:  Deferred Compensation Plan and Related Investments 

Year ended December 31, 

(in millions) 

Net interest income 

$ 

Net gains (losses) from equity securities 

Total revenue (losses) from deferred 
compensation plan investments 

Employee benefits expense (1) 

2019 

70 

664 

734 

739 

Income (loss) before income tax 

expense 

$ 

(5) 

(1) 

Represents change in deferred compensation plan liability. 

2018 

60 

(303) 

(243) 

(242) 

(1) 

Technology and equipment expense was up 13% in 2019, 
compared with 2018, due to higher impairment expenses on 
capitalized software and computer software licensing and 
maintenance costs, reflecting the strategic reassessment of 
technology projects in WIM. 

Core deposit and other intangibles expense was down 90% 

in 2019, compared with 2018, due to lower amortization 
expense reflecting the end of the 10-year amortization period on 
Wachovia intangibles. 

 FDIC and other deposit assessments were down 53% in 
2019, compared with 2018, due to the completion of the FDIC 
surcharge which ended September 30, 2018. 

Operating losses were up $1.2 billion, or 38%, in 2019, 
compared with 2018, due to higher litigation accruals for a 
variety of matters, including previously disclosed retail sales 
practices matters, partially offset by lower remediation expense. 

Outside professional and contract services expense was up 

3% in 2019, compared with 2018, reflecting an increase in 
project spending, partially offset by lower legal expense. 

Leases expense was down 13% in 2019, compared with 
2018, driven by reductions in the size of the operating lease 
portfolio. 

Advertising and promotion expense was up 26% in 2019, 
compared with 2018, due to increases in marketing and brand 
campaign volumes. 

All other noninterest expense was down 10% in 2019, 
compared with 2018, due to a sales tax refund in 2019, higher 
gains on the sale of corporate properties in 2019, compared with 
2018, and pension plan settlement expense in 2018 that did not 
recur in 2019. 

Income Tax Expense 
Our effective income tax rate in 2019 was 17.5%, compared with 
20.2% in 2018. The 2019 and 2018 effective income tax rates 
reflected the non-tax-deductible treatment of certain litigation 
accruals. The 2018 effective income tax rate also reflected 
income tax expense related to the reconsideration of reserves 
for state income taxes following the U.S. Supreme Court decision 
in South Dakota v. Wayfair, Inc. and the recognition of 
$164 million of income tax expense associated with the final re-
measurement of our initial estimates for the impacts of the Tax 
Cuts & Jobs Act (Tax Act). See Note 24 (Income Taxes) to 
Financial Statements in this Report for additional information 
about our income taxes. 

42 

Wells Fargo & Company 

  
 
  
 
 
Operating Segment Results 
As of December 31, 2019, we were 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 reporting process. The management reporting 
process is based on U.S. GAAP with specific adjustments, such as 
for funds transfer pricing for asset/liability management, for 
shared revenues and expenses, and tax-equivalent adjustments 
to consistently reflect income from taxable and tax-exempt 
sources. On February 11, 2020, we announced a new 
organizational structure with five principal lines of business: 
Consumer and Small Business Banking; Consumer Lending; 
Commercial Banking; Corporate and Investment Banking; and 
Wealth and Investment Management. This new organizational 

Table 9:  Operating Segment Results – Highlights 

structure is intended to help drive operating, control, and 
business performance. The Company is currently in the process 
of transitioning to this new organizational structure, including 
identifying leadership for some of these principal business lines 
and aligning management reporting and allocation 
methodologies. These changes will not impact the consolidated 
financial results of the Company, but are expected to result in 
changes to our operating segments. We will update our 
operating segment disclosures, including comparative financial 
results, when the Company completes its transition and is 
managed in accordance with the new organizational structure. 
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 reporting process, see Note 27 
(Operating Segments) to Financial Statements in this Report. 

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

2019 

Revenue 

Provision (reversal of provision) for credit losses 

Net income (loss) 

Average loans 

Average deposits 

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 

Community 
Banking 

Wholesale 
Banking 

Wealth and 
Investment 
Management 

Year ended December 31, 

Other (1) 

Consolidated 
Company 

$ 

45,316 

2,319 

7,398 

459.4 

782.0 

$ 

27,677 

378 

10,696 

475.3 

422.5 

17,341 

5 

2,713 

75.6 

146.0 

$ 

46,913 

28,706 

16,376 

1,783 

10,394 

463.7 

757.2 

$ 

(58) 

11,032 

465.7 

423.7 

(5) 

2,580 

74.6 

165.0 

$ 

47,018 

30,000 

17,072 

2,555 

10,938 

475.7 

729.6 

$ 

(19) 

9,914 

465.6 

464.2 

(5) 

2,770 

71.9 

189.0 

(5,271) 

(15) 

(1,258) 

(59.3) 

(64.2) 

(5,587) 

24 

(1,613) 

(58.8) 

(70.0) 

(5,701) 

(3) 

(1,439) 

(57.1) 

(78.2) 

85,063 

2,687 

19,549 

951.0 

1,286.3 

86,408 

1,744 

22,393 

945.2 

1,275.9 

88,389 

2,528 

22,183 

956.1 

1,304.6 

(1) 

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

Wells Fargo & Company 

43 

 
  
Earnings Performance (continued) 

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, automobile, student, mortgage, 
home equity and small business lending, as well as referrals to 
Wholesale Banking and WIM business partners. The Community 

Table 9a:  Community Banking 

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. Table 
9a provides additional financial information for Community 
Banking. 

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

2019 

2018 

% Change 

2017 

% 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 (1) 

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 

Technology and 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 interests 

Income tax expense 

Less: Net income from noncontrolling interests (4) 

Net income 

Average loans 

Average deposits 

$ 

27,610 

29,219 

(6)%  $ 

28,658 

2% 

2,823 

2,641 

1,931 

805 

(93) 

2,643 

3,655 

1,278 

2,307 

44 

24 

51 

2,155 

2,726 

1,887 

910 

(35) 

2,762 

3,543 

1,359 

2,659 

83 

28 

(3) 

1,505 

3,117 

17,706 

17,694 

45,316 

46,913 

2,319 

1,783 

22,867 

2,423 

2,236 

3 

327 

1,942 

3,846 

(948) 

32,696 

10,301 

2,426 

477 

7,398 

459.4 

782.0 

$ 

$ 

21,252 

2,356 

2,166 

404 

624 

1,560 

2,656 

(527) 

30,491 

14,639 

3,784 

461 

10,394 

463.7 

757.2 

7 

2 

(12) 

NM 

(4) 

3 

(6) 

(13) 

(47) 

(14) 

NM 

43 

(13) 

— 

(3) 

30 

8 

3 

3 

(99) 

(48) 

24 

45 

(80) 

7 

(30) 

(36) 

3 

(29) 

(1) 

3 

2,909 

(9) 

1,830 

889 

(59) 

2,660 

3,613 

1,497 

3,895 

139 

(251) 

709 

1,455 

1,734 

18,360 

47,018 

3 

2 

41 

4 

(2) 

(9) 

(32) 

(40) 

111 

NM 

3 

80 

(4) 

— 

2,555 

(30) 

20,381 

2,157 

2,111 

446 

715 

1,875 

5,312 

(382) 

32,615 

11,848 

634 

276 

10,938 

475.7 

729.6 

$ 

$ 

4 

9 

3 

(9) 

(13) 

(17) 

(50) 

(38) 

(7) 

24 

497 

67 

(5) 

(3) 

4 

NM - Not meaningful 
(1) 
(2) 

Represents income on products and services for WIM customers served through Community Banking distribution channels which is eliminated in consolidation. 
Includes underwriting fees paid to Wells Fargo Securities for services related to the issuance of our corporate securities which are offset in our Wholesale Banking segment and eliminated in 
consolidation. 
Largely represents gains resulting from venture capital investments. 
Reflects results attributable to noncontrolling interests predominantly associated with the Company’s consolidated venture capital investments. 

(3) 
(4) 

44 

Wells Fargo & Company 

Community Banking reported net income of $7.4 billion in 

Income tax expense was $2.4 billion in 2019, down 

$1.4 billion from $3.8 billion in 2018. The decrease in income tax 
expense in 2019 was driven by lower pre-tax income, and 
reflected the non-tax-deductible treatment of certain litigation 
accruals. 

Average loans decreased $4.3 billion in 2019, or 1%, from 

2018 driven by decreases in real estate 1-4 family junior lien 
mortgage, automobile, other revolving credit and installment, 
and commercial loans, partially offset by higher real estate 1-4 
family first mortgage and credit card loans. Average deposits 
increased $24.8 billion in 2019, or 3%, from 2018. 

2019, down $3.0 billion, or 29%, from 2018. Revenue was 
$45.3 billion in 2019, down $1.6 billion, or 3%, from 2018. The 
decrease in revenue in 2019 was due to lower net interest 
income, gains from the sales of purchased credit-impaired (PCI) 
residential mortgage loans, mortgage banking revenue driven by 
a decrease in servicing income, and trust and investment fees, 
partially offset by higher gains on equity securities, service 
charges on deposit accounts, and card fees. 

The provision for credit losses in 2019 increased 

$536 million from 2018 due to a higher level of credit quality 
improvement in 2018 compared with 2019, partially offset by 
lower net charge-offs in the automobile portfolio in 2019. 

Noninterest expense of $32.7 billion in 2019 increased 

$2.2 billion, or 7%, from 2018. The increase in 2019 was 
predominantly driven by higher personnel expense, operating 
losses reflecting litigation accruals for a variety of matters, 
including previously disclosed retail sales practices matters, and 
outside professional services expense, partially offset by lower 
other expense, core deposit and other intangibles amortization 
expense, and FDIC and other deposit assessments expense. 

Wells Fargo & Company 

45 

Earnings Performance (continued) 

Wholesale Banking provides financial solutions to businesses 
with annual sales generally in excess of $5 million and to financial 
institutions globally. 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) 

2019 

2018 

% Change 

2017 

% 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 

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 

Total revenue 

$ 

17,699 

18,690 

(5)%  $ 

18,810 

(1)% 

2,201 

(6) 

1,974 

2,074 

292 

486 

1,889 

2,667 

359 

1,801 

412 

303 

915 

89 

416 

1,042 

9,978 

317 

445 

1,783 

2,545 

362 

2,019 

362 

312 

516 

102 

293 

1,431 

10,016 

27,677 

28,706 

(5) 

(8) 

9 

6 

5 

(1) 

(11) 

14 

(3) 

77 

(13) 

42 

(27) 

— 

(4) 

304 

523 

1,827 

2,654 

345 

2,054 

458 

872 

701 

(232) 

116 

2,021 

11,190 

30,000 

Provision (reversal of provision) for credit losses 

378 

(58) 

752 

(19) 

Noninterest expense: 

Personnel expense 

Technology and 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 (1) 

Less: Net income (loss) from noncontrolling interest 

Net income 

Average loans 

Average deposits 

5,560 

5,567 

38 

388 

92 

172 

600 

35 

8,467 

15,352 

11,947 

1,246 

5 

10,696 

475.3 

422.5 

$ 

$ 

48 

403 

378 

419 

958 

246 

8,138 

16,157 

12,607 

1,555 

20 

11,032 

465.7 

423.7 

— 

(21) 

(4) 

(76) 

(59) 

(37) 

(86) 

4 

(5) 

(5) 

(20) 

(75) 

(3) 

2 

— 

$ 

$ 

6,603 

55 

425 

414 

481 

1,134 

74 

7,438 

16,624 

13,395 

3,496 

(15) 

9,914 

465.6 

464.2 

NM - Not meaningful 
(1) 

Income tax expense for our Wholesale Banking operating segment included income tax credits related to low-income housing and renewable energy investments of $1.8 billion, $1.6 billion and 
$1.4 billion for the years ended December 31, 2019, 2018 and 2017, respectively. 

Wholesale Banking reported net income of $10.7 billion in 

The provision for credit losses in 2019 increased 

2019, down $336 million, or 3%, from 2018. The decrease in 
2019 was predominantly due to lower net interest income, 
partially offset by lower noninterest expense. Revenue of 
$27.7 billion in 2019 decreased $1.0 billion, or 4%, from 2018. 
Net interest income of $17.7 billion in 2019 decreased 
$1.0 billion, or 5%, from 2018. The decrease in net interest 
income in 2019 was due to lower credit spreads on loans, trading 
assets, and debt securities, as well as the impact of migration 
from noninterest-bearing to interest-bearing deposits. 

Noninterest income of $10.0 billion in 2019 was flat 

compared with 2018. 

$436 million from 2018, driven by lower recoveries reflecting a 
higher level of credit quality improvement in 2018 compared 
with 2019. 

Noninterest expense of $15.4 billion in 2019 decreased 
$805 million, or 5%, compared with 2018. The decrease in 2019 
was predominantly due to lower core deposit and other 
intangibles amortization expense, FDIC and other deposit 
assessments expense, operating losses, and lease expense 
(within other expense), as well as the impact of the sale of 
Eastdil, partially offset by increased project expense (within 
other expense). 

46 

Wells Fargo & Company 

4 

(15) 

(2) 

(4) 

5 

(2) 

(21) 

(64) 

(26) 

144 

153 

(29) 

(10) 

(4) 

NM 

(16) 

(13) 

(5) 

(9) 

(13) 

(16) 

232 

9 

(3) 

(6) 

(56) 

233 

11 

— 

(9) 

 
  
Average loans of $475.3 billion in 2019 increased 

$9.6 billion, or 2%, compared with 2018. Loan growth in 2019 
from commercial and industrial loans was partially offset by 
declines in commercial real estate loans. Average deposits of 
$422.5 billion in 2019 decreased $1.2 billion from 2018. The 
decline in 2019 was driven by commercial customers allocating 
more cash to alternative higher-rate liquid investments. 

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, 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 and provide investment management 
capabilities delivered to global institutional clients through 
separate accounts and the Wells Fargo Funds. The sale of our IRT 
business closed on July 1, 2019. For additional information on 
the sale of our IRT business, including its impact on our AUM, 
AUA and associated revenue and expenses, see the “Noninterest 
Income” section in this Report. Tables 9c through 9f provide 
additional financial information for WIM. 

Table 9c:  Wealth and Investment Management 

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

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 on debt securities 

Net gains (losses) from equity securities 

Other income of the segment 

Total noninterest income 

Total revenue 

Provision (reversal of provision) for credit losses 

Noninterest expense: 

Personnel expense 

Technology and 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 

Less: Net income from noncontrolling interest 

Net income 

Average loans 

Average deposits 

NM - Not meaningful 

2019 

$ 

4,037 

2018 

4,441 

% Change 

2017 

% Change 

(9)%  $ 

4,641 

(4)% 

Year ended December 31, 

16 

16 

— 

17 

8,946 

2,587 

6 

9,161 

2,893 

9 

11,539 

12,063 

6 

17 

(12) 

72 

53 

— 

6 

17 

(11) 

82 

57 

9 

272 

1,341 

13,304 

(283) 

(21) 

11,935 

17,341 

16,376 

5 

(5) 

8,477 

8,085 

304 

448 

13 

49 

684 

452 

3,282 

13,709 

3,627 

904 

10 

2,713 

75.6 

146.0 

$ 

$ 

42 

440 

276 

116 

815 

232 

2,932 

12,938 

3,443 

861 

2 

2,580 

74.6 

165.0 

(2) 

(11) 

(33) 

(4) 

— 

— 

(9) 

(12) 

(7) 

(100) 

196 

NM 

11 

6 

200 

5 

624 

2 

(95) 

(58) 

(16) 

95 

12 

6 

5 

5 

400 

5 

1 

(12) 

$ 

$ 

9,072 

2,877 

(2) 

11,947 

6 

18 

(10) 

88 

92 

2 

208 

63 

12,431 

17,072 

(5) 

8,126 

28 

431 

292 

154 

834 

115 

2,643 

12,623 

4,454 

1,668 

16 

2,770 

71.9 

189.0 

(6) 

1 

1 

550 

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) 

WIM reported net income of $2.7 billion in 2019, up 

$133 million, or 5%, from 2018. Revenue of $17.3 billion in 2019 
increased $965 million, or 6%, from 2018. 

Net interest income of $4.0 billion in 2019 decreased 

$404 million, or 9%, from 2018 predominantly due to the impact 
of lower deposit balances. 

Noninterest income of $13.3 billion in 2019 increased 
$1.4 billion, or 11%, from 2018, predominantly due to the 
$1.1 billion gain on the sale of our IRT business and higher net 
gains from equity securities on increased deferred compensation 
plan investment results (largely offset by higher employee 
benefits expense), partially offset by lower asset-based fees. 

Wells Fargo & Company 

47 

  
Earnings Performance (continued) 

Noninterest income in 2018 reflected an impairment on the sale 
of our ownership stake in RockCreek. 

The provision for credit losses was $5 million in 2019, 

compared with a reversal of provision of $5 million in 2018. 
Noninterest expense of $13.7 billion in 2019 increased 
$771 million, or 6%, from 2018 due to higher personnel expense 
on increased deferred compensation plan expense (offset in net 
gains from equity securities), technology and equipment expense 
including $265 million of capitalized software impairment and 
computer software licensing and maintenance costs, reflecting 
the strategic reassessment of technology projects, operating 
losses, and project expense (within other expense), partially 
offset by lower core deposits and other intangibles amortization 
expense. 

Average loans of $75.6 billion in 2019 increased $1.0 billion 
from 2018 driven by growth in nonconforming mortgage loans. 
Average deposits of $146.0 billion in 2019 decreased 
$19.0 billion, or 12%, from 2018 as customers allocated more 
cash into higher yielding liquid alternatives. 

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 
represent transactional commissions based on the number and 
size of transactions executed at the client’s direction. Fees from 
advisory accounts are based on 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 services provided, 
and are affected by investment performance as well as asset 
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, 2019, 2018 and 2017. 

48 

Wells Fargo & Company 

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 

Year ended December 31, 

2019 

$ 

1,646.0 

589.5 

36% 

2018 

1,487.6 

501.1 

34 

2017 

1,651.3 

542.8 

33 

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. For the years ended December 31, 
2019, 2018 and 2017, 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, 2019, 2018 and 2017. The 
activity in 2019 reflected higher market valuations and net 
outflows primarily from the correspondent clearing business. 

Table 9e:  Retail Brokerage Advisory Account Client Assets 

(in billions) 

December 31, 2019 

Client directed (4) 

Financial advisor directed (5) 

Separate accounts (6) 

Mutual fund advisory (7) 

Total advisory client assets 

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 

Balance, beginning 
of period 

Inflows (1) 

Outflows (2)  Market impact (3) 

Year ended 

Balance, end of 
period 

$ 

$ 

$ 

$ 

$ 

$ 

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 

33.5 

33.9 

24.2 

11.8 

103.4 

33.6 

30.0 

23.8 

12.8 

100.2 

37.1 

30.6 

26.1 

13.1 

106.9 

(41.8) 

(34.7) 

(29.7) 

(14.1) 

(120.3) 

(41.0) 

(32.9) 

(29.1) 

(13.8) 

(116.8) 

(39.2) 

(24.5) 

(23.5) 

(11.1) 

(98.3) 

26.2 

35.2 

29.2 

14.7 

105.3 

(12.0) 

(2.2) 

(7.4) 

(3.5) 

(25.1) 

13.9 

25.2 

20.8 

10.5 

70.4 

169.4 

176.3 

160.1 

83.7 

589.5 

151.5 

141.9 

136.4 

71.3 

501.1 

170.9 

147.0 

149.1 

75.8 

542.8 

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

(5) 
(6) 
(7) 

Wells Fargo & Company 

49 

  
  
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, separate accounts, 
and personal trust assets, through our asset management and 
wealth businesses. Prior to the sale of our IRT business, which 
closed on July 1, 2019, we also earned fees from managing 
employee benefit trusts through the retirement business. Our 
asset management business is conducted by Wells Fargo Asset 
Management (WFAM), which offers Wells Fargo proprietary 
mutual funds and manages institutional separate accounts, and 

our wealth business manages assets for high net worth 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. For additional 
information on the sale of our IRT business, including its impact 
on our AUM, AUA and associated revenue and expenses, see the 
“Noninterest Income” section in this Report. Table 9f presents 
AUM activity for the years ended December 31, 2019, 2018 and 
2017. 

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

(in billions) 

December 31, 2019 

Assets managed by WFAM (4): 

Money market funds (5) 

Other assets managed 

Assets managed by Wealth and IRT (6) 

Total assets under management 

December 31, 2018 

Assets managed by WFAM (4): 

Money market funds (5) 

Other assets managed 

Assets managed by Wealth and IRT (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 IRT (6) 

Total assets under management 

Balance, beginning 
of period 

Inflows (1) 

Outflows (2)  Market impact (3) 

Year ended 

Balance, end of 
period 

$ 

$ 

$ 

$ 

$ 

$ 

112.4 

353.5 

170.7 

636.6 

108.2 

395.7 

186.2 

690.1 

102.6 

379.6 

168.5 

650.7 

18.2 

75.1 

33.6 

126.9 

4.2 

85.5 

36.3 

126.0 

5.6 

116.0 

41.1 

162.7 

— 

(86.1) 

(40.5) 

(126.6) 

— 

(120.2) 

(39.5) 

(159.7) 

— 

(130.9) 

(39.4) 

(170.3) 

— 

35.7 

23.6 

59.3 

— 

(7.5) 

(12.3) 

(19.8) 

— 

31.0 

16.0 

47.0 

130.6 

378.2 

187.4 

696.2 

112.4 

353.5 

170.7 

636.6 

108.2 

395.7 

186.2 

690.1 

(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 $5.0 billion, $4.9 billion and $5.5 billion as of December 31, 2019, 2018 and 2017, respectively, of client assets invested in proprietary funds managed by WFAM. 

50 

Wells Fargo & Company 

 
  
Balance Sheet Analysis 

At December 31, 2019, our assets totaled $1.9 trillion, up 
$31.7 billion from December 31, 2018. Asset growth was 
predominantly due to increases in federal funds sold and 
securities purchased under resale agreements, debt securities, 
and equity securities, which increased $21.9 billion, $12.4 billion, 
and $13.1 billion, respectively, partially offset by a $30.2 billion 
decline in interest-earning deposits with banks. 

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

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

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 29 (Regulatory and Agency 
Capital Requirements) to Financial Statements in this Report. 

(in millions) 

Available-for-sale 

Held-to-maturity 

Total (1) 

December 31, 2019 

December 31, 2018 

Amortized 
cost 

$ 

260,060 

153,933 

413,993 

Net 
unrealized 
gain (loss) 

3,399 

2,927 

6,326 

Fair 
value 

263,459 

156,860 

420,319 

Amortized 
cost 

272,471 

144,788 

417,259 

Net 
unrealized 
gain (loss) 

(2,559) 

(2,673) 

(5,232) 

Fair 
value 

269,912 

142,115 

412,027 

(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 held-
to-maturity debt securities, which increased $2.7 billion in 
balance sheet carrying value from December 31, 2018, due to 
higher net unrealized gains, partially offset by paydowns, sales 
and maturities exceeding purchases. 

The total net unrealized gains on available-for-sale debt 
securities were $3.4 billion at December 31, 2019, up from net 
unrealized losses of $2.6 billion at December 31, 2018, driven by 
lower interest rates and tighter credit spreads. 

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

to-maturity debt securities is 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 primarily 
consists of liquid, high-quality U.S. Treasury and federal agency 
debt, and agency mortgage-backed securities (MBS), in addition 
to securities issued by U.S. states and political subdivisions, 
corporate debt securities, and highly rated collateralized loan 
obligations (CLOs). 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. 

The held-to-maturity debt securities portfolio 

predominantly consists of high-quality U.S. Treasury debt, 
agency MBS and securities issued by U.S. states and political 
subdivisions 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 OTTI quarterly or more 

often if a potential loss-triggering event occurs. In 2019, we 
recognized $63 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, 2019, debt securities included $53.8 billion 

of municipal bonds, of which 96.9% were rated “A-” or better 
based predominantly on external 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 4.7 years at December 31, 2019. The 
expected remaining maturity is shorter than the remaining 
contractual maturity for the 63.5% 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. 

Wells Fargo & Company 

51 

  
 
Balance Sheet Analysis (continued) 

Table 11:  Mortgage-Backed Securities Available for Sale 

(in billions) 

At December 31, 2019 

Actual 

Assuming a 200 basis point: 

Increase in interest rates 

Decrease in interest rates 

Fair 
value 

Net 
unrealized 
gain (loss) 

Expected 
remaining 
maturity 
(in years) 

167.2 

2.2 

151.3 

176.9 

(13.7) 

11.9 

4.6 

6.9 

3.2 

The weighted-average expected remaining maturity of debt 

securities held-to-maturity (HTM) was 4.9 years at 
December 31, 2019. HTM debt securities are measured at 
amortized cost and, therefore, changes in the fair value of our 
held-to-maturity MBS resulting from changes in interest rates 
are not recognized in earnings. 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. 

Loan Portfolios 
Table 12 provides a summary of total outstanding loans by 
portfolio segment. Total loans increased $9.2 billion from 
December 31, 2018, largely driven by an increase in consumer 
loans. 

Consumer loans were up $6.8 billion from December 31, 
2018, predominantly due to growth in the real estate 1-4 family 
first mortgage portfolio, as mortgage loan originations were 
partially offset by paydowns and $4.0 billion of sales of PCI loans, 
predominantly Pick-a-Pay, in 2019. We also purchased 
$3.3 billion of mortgage loans in 2019 as a result of exercising 
servicer cleanup calls. In addition, during 2019, we reclassified 
$1.9 billion of existing mortgage loans to MLHFS in anticipation 
of future whole loan sales. 

Commercial loans also increased from December 31, 2018, 

predominantly driven by growth in our commercial and industrial 
loan portfolio, reflecting growth in our Corporate and 
Investment Banking business and purchases of CLOs in loan form 
within our Credit Investment Portfolio, partially offset by 
declines in our Commercial Banking business. 

Table 12:  Loan Portfolios 

(in millions) 

Commercial 

Consumer 

Total loans 

Change from prior year 

December 31, 2019 

December 31, 2018 

$ 

$ 

515,719 

446,546 

962,265 

9,155 

513,405 

439,705 

953,110 

(3,660) 

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

Table 13 shows contractual maturities for selected classes 
of commercial loans and the distribution of loans to changes in 
interest rates. 

Table 13:  Maturities for Selected Commercial Loan Categories 

(in millions) 

Selected loan maturities: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Total selected loans 

Distribution of loans to changes in interest rates: 

Loans at fixed interest rates 

Loans at floating/variable interest rates 

Total selected loans 

Within 
one 
year 

After 
one year 
through 
five years 

$ 

130,342 

196,460 

27,951 

9,219 

64,506 

10,178 

December 31, 2019 

After 
five 
years 

27,323 

29,367 

542 

Total 

354,125 

121,824 

19,939 

$ 

167,512 

271,144 

57,232 

495,888 

$ 

22,660 

28,688 

144,852 

242,456 

18,479 

38,753 

69,827 

426,061 

$ 

167,512 

271,144 

57,232 

495,888 

52 

Wells Fargo & Company 

  
  
 
  
 
Deposits 
Deposits were $1.3 trillion at December 31, 2019, up 
$36.5 billion from December 31, 2018, due to an increase in 
commercial deposits, consumer and small business banking 
deposits, and mortgage escrow deposits reflecting an inflow of 
higher mortgage payoffs to be remitted to investors in 
accordance with servicing contracts, partially offset by a 
decrease in other time deposits. The increase in commercial 
deposits was due to higher balances in corporate and investment 
banking deposits, and commercial real estate deposits. The 

increase in consumer and small business banking deposits was 
due to higher balances in high-yield savings, certificates of 
deposit (CDs), and noninterest-bearing deposits, partially offset 
by declines in brokerage sweeps. 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 the “Earnings 
Performance – Net Interest Income” section 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 non-U.S. offices (1) 

Total deposits 

Dec 31, 
2019 

% of 
total 
deposits 

Dec 31, 
2018 

% of 
total 
deposits 

% Change 

$ 

344,496 

26% 

$ 

349,534 

62,814 

751,080 

31,715 

78,609 

53,912 

5 

57 

2 

6 

4 

56,797 

703,338 

22,648 

95,602 

58,251 

27% 

4 

55 

2 

7 

5 

$ 

1,322,626 

100%  $ 

1,286,170 

100% 

(1) 

11 

7 

40 

(18) 

(7) 

3 

(1) 

Includes Eurodollar sweep balances of $34.2 billion and $31.8 billion at December 31, 2019 and 2018, respectively. 

Equity 
Total equity was $188.0 billion at December 31, 2019, compared 
with $197.1 billion at December 31, 2018. The decrease was 
driven by a $21.6 billion increase in treasury stock and a 
$1.7 billion decline in preferred stock, partially offset by an 
$8.5 billion increase in retained earnings net of dividends paid, 
and a $5.0 billion increase in cumulative other comprehensive 
income predominantly due to fair value adjustments to available-
for-sale debt securities. The increase in treasury stock was the 
result of the repurchase of 502.4 million shares of common stock 
in 2019, an increase of 34% from 2018. 

Wells Fargo & Company 

53 

  
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. 

Guarantees and Other 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, direct pay 
letters of credit, written options, recourse obligations, exchange 
and clearing house guarantees, indemnifications, and other types 
of similar arrangements. For more information, see Note 16 
(Guarantees, Pledged Assets and Collateral, and Other 
Commitments) to Financial Statements in this Report. 

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, see Note 18 
(Derivatives) to Financial Statements in this Report. 

Commitments to Lend 
We enter into commitments to lend to customers, which are 
usually at a stated interest rate, if funded, and for specific 
purposes and time periods. When we enter into 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 
not funded. For more information, see Note 6 (Loans and 
Allowance for Credit Losses) to Financial Statements in this 
Report. 

Commitments to Purchase Debt and Equity Securities 
We enter into commitments to purchase securities under resale 
agreements. 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 Note 16 (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, see Note 10 
(Securitizations and Variable Interest Entities) to Financial 
Statements in this Report. 

54 

Wells Fargo & Company 

Contractual Cash Obligations 
In the ordinary course of business, we enter into other 
contractual obligations that may require future cash payments, 
including debt issuances for the funding of operations and leases 
for premises and equipment. 

Table 15 summarizes these contractual obligations as of 

December 31, 2019, excluding accrued expenses and other 
liabilities, short-term borrowings and obligations for pension and 
postretirement benefit plans. For more information, see Note 14 
(Short-Term Borrowings) and Note 23 (Employee Benefits and 
Other Expenses) to Financial Statements in this Report. 

Table 15:  Contractual Cash Obligations 

(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 

13 

15 

7 

24 

16 

$ 

88,259 

39,646 

6,805 

1,006 

5 

2,706 

855 

21,484 

73,329 

8,748 

1,942 

— 

— 

1,009 

6,036 

29,776 

5,733 

1,347 

— 

— 

438 

December 31, 2019 

Indeterminate 
maturity 

Total 

1,203,777 

1,322,626 

— 

— 

— 

3,676 

— 

— 

228,191 

40,934 

5,967 

3,681 

2,724 

2,616 

More 
than 
5 years 

3,070 

85,440 

19,648 

1,672 

— 

18 

314 

Total contractual obligations 

$ 

139,282 

106,512 

43,330 

110,162 

1,207,453 

1,606,739 

(1) 
(2) 
(3) 

(4) 

(5) 

Includes interest-bearing and noninterest-bearing checking, and market rate and other savings accounts. 
Balances are presented net of unamortized debt discounts and premiums and purchase accounting adjustments. 
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 $7.1 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, 2019, 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. 
Includes unfunded commitments to purchase debt securities of $18 million and equity securities of $2.7 billion, respectively. Substantially all of our equity commitments are included in the ‘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. 
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 non-U.S. 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 24 (Income Taxes) to 
Financial Statements in this Report for more information. 

Wells Fargo & Company 

55 

  
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, shareholders, regulators and 
other stakeholders. 

Risk is Part of our Business Model  The Company measures and 
manages risk as part of our business, including in connection with 
the products and services we offer to our customers. The risks 
we take include financial, such as credit, interest rate, market, 
liquidity and funding risks, and non-financial, such as operational 
including compliance and model risks, strategic and reputation 
risks. 

Risk Profile  Our risk profile is a holistic view of all risks we hold 
at a point in time, including emerging risks. The Company 
monitors its risk profile, and the Board periodically reviews 
reports and analysis concerning our risk profile. 

Risk Capacity  Risk capacity refers to the maximum level of risk 
that the Company could assume given its current level of 
resources before triggering regulatory and other constraints on 
its capital and liquidity needs. 

Risk Appetite  Management defines and the Board approves the 
Company’s risk appetite, which is the amount of risk the 
Company is comfortable taking given its current level of 
resources. Risk appetite defines which risks are acceptable and at 
what level and guides business and risk leaders. Risk appetite 
boundaries are set within the Company’s risk capacity. The 
Company’s risk appetite is articulated in a statement of risk 
appetite, which is approved at least annually by the Board. The 
Company continuously monitors its risk appetite, and the Board 
reviews periodic risk appetite reports and analysis. 

Risk and Strategy  The Company’s risk profile, risk capacity, risk 
appetite, and risk management effectiveness (e.g., the holistic 
measure of the quality and effectiveness of the Company’s risk 
management activities, including the functional or programmatic 
use of controls and capabilities to manage risks) are considered 
in the strategic planning process, which is closely linked with the 
Company’s capital planning process. The Company’s Independent 
Risk Management (IRM) organization participates in strategic 
planning at several points in the process, providing challenge to 
and independent assessment of the Company’s self-assessment 
of the risks associated with strategic planning initiatives. IRM 
also independently assesses the impact of the strategic plan on 
risk capacity, risk appetite, and risk management effectiveness at 
the business group, enterprise function, and aggregate Company 
level. Risk decisions related to the strategic plan are approved by 
the Enterprise Risk & Control Committee (ERCC), a management 
governance committee that governs the management of all risk 
types. After a critical review, the strategic plan is presented to 
the Board each year for review and approval. 

Everyone Manages Risk  Every team member creates risk in the 
course of performing business activities and is required to 
manage that risk. Risk is everyone’s responsibility. Every team 
member is required to comply with applicable laws, regulations, 
and Company policies. 

Risk and Culture  The Board holds management accountable for 
establishing and maintaining the right risk culture and effectively 
managing risk. Team members are strongly encouraged and 
expected to speak up when they see something that could cause 
harm to the Company’s customers, communities, team 
members, shareholders, or reputation. Because risk management 
is everyone’s responsibility, all team members are expected to 
challenge risk decisions when appropriate and to escalate their 
concerns when they have not been addressed. Team member 
performance evaluations are tied to, and take into account, 
effective risk management. The Company’s performance 
management and incentive compensation programs are 
designed to establish a balanced framework for risk and reward 
under core principles that team members are expected to know 
and practice. The Board, through its Human Resources 
Committee, plays an important role in overseeing and providing 
credible challenge to the Company’s performance management 
and incentive compensation programs. 

Risk Management Framework  The Company’s risk 
management framework sets forth the core principles on how 
the Company seeks to manage and govern its risk. Many 
Company policies and documents anchor to the risk 
management framework’s core principles. The Board’s Risk 
Committee annually reviews and approves the risk management 
framework. 

Risk Governance 
Role of the Board  The Board oversees the Company’s business, 
including its risk management. The Board assesses 
management’s performance, provides credible challenge, and 
holds management accountable for maintaining an effective risk 
management program and for adhering to risk management 
expectations. 

Board Committee Structure  The Board carries out its risk 
oversight responsibilities directly and through its committees. 

The Risk Committee approves the Company’s risk 
management framework and oversees its implementation, 
including the processes established by management to identify, 
assess, measure, monitor, and manage risks. It also monitors the 
Company’s adherence to its risk appetite. In addition, the Risk 
Committee oversees IRM and the performance of the Chief Risk 
Officer (CRO) who reports functionally to the Risk Committee 
and administratively to the CEO. 

Management Committee Structure  The Company has 
established management committees, including those focused 
on risk, that support management in carrying out its governance 
and risk management responsibilities. One type of management 
committee is a governance committee, which is a decision 
making body that operates for a particular purpose. 

Each management governance committee is expected to 
discuss, document, and make decisions regarding significant risk 
issues, emerging risks, and risk acceptances; review and monitor 
progress related to critical and high-risk issues and remediation 
efforts within its scope, including lessons learned; and report key 
challenges, decisions, escalations, other actions, and open issues 
as appropriate. 

56 

Wells Fargo & Company 

Table 16 below presents the structure of the Company’s 

Board committees and management governance committees, 
including relevant reporting and escalation paths. 

Table 16:  Board and Management-level Governance Committee Structure 

Wells Fargo & Company 

Audit 
Committee (1) 

Finance 
Committee 

Corporate
Responsibility
Committee 

Risk 
Committee 

Governance & 
Nominating
Committee 

Credit 
Committee 

Human 
Resources 
Committee 

Management Governance Committees 

Regulatory and 
Risk Reporting 
Oversight 
Committee 

Capital 
Management 
Committee 

Enterprise 
Risk & Control 
Committee 

Allowance for 
Credit Losses 
Approval 
Governance 
Committee 

Incentive 
Compensation 
Committee 

Disclosure 
Committee 

Corporate 
Asset/Liability 
Committee 

Recovery and 
Resolution 
Committee 

(1) 

The Audit 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. 

Management Governance Committees Reporting to the Risk 
Committee of the Board  The ERCC governs the management of 
all risk types, including financial risks and non-financial risks. The 
ERCC receives information about risk and control events, 
addresses escalated risks and issues, actively oversees risk 
control, and provides regular updates to the Risk Committee 
regarding current and emerging risks and management’s 
assessment of the effectiveness of the Company’s risk 
management program. 

The ERCC is chaired by the CRO, with membership made up 

of the CEO and the heads of business groups and certain 
enterprise functions. The Chief Auditor attends all meetings of 
the ERCC. The ERCC has a direct escalation path to the Risk 
Committee. The ERCC also escalates credit risks and issues to 
the Credit Committee and certain human capital risks and issues 
to the Human Resources Committee. In addition, the CRO has 
the authority to escalate anything directly to the Board. Risks 
and issues are escalated to the ERCC in accordance with 
applicable policies and procedures governing escalations. 

Each business group and enterprise function has a risk and 

control committee, which are management governance 
committees with mandates that align with the ERCC but with 
their scope limited to the relevant business groups or enterprise 
functions. The focus of these committees is on the risks that 
each business group or enterprise function generates and is 
responsible for managing, and the controls each business group 
or enterprise function is expected to have in place. 

In addition to each risk and control committee, management 

governance committees dedicated to specific risk types and risk 
topics also report to the ERCC to help provide more 
comprehensive governance of risks. 

Risk Operating Model - Roles and Responsibilities 
The Company has three lines of defense: the front line, 
Independent Risk Management, and Internal Audit. Our risk 
operating model creates necessary interaction, 
interdependencies, and ongoing engagement among the lines of 
defense: 
• 

Front Line  The front line, which is composed of business 
groups and certain activities of enterprise functions, is the 
first line of defense. In the course of its business activities, 
the front line identifies, measures and assesses, manages, 
controls, monitors, and reports on risk associated with its 
business activities and balances risk and reward in decision 
making while remaining within the Company’s risk appetite. 
Independent Risk Management  IRM is the second line of 
defense. It establishes and maintains the Company’s risk 
management program and provides oversight, including 
challenge to and independent assessment of the front line’s 
execution of its risk management responsibilities. 
Internal Audit  Internal Audit is the third line of defense. It is 
responsible for acting as an independent assurance function 
and validates that the risk management program is 
adequately designed and functioning effectively. 

• 

• 

Risk Type Classifications 
The Company uses common classifications, hierarchies, and 
ratings to enable consistency across risk management programs 
and aggregation of information. Risk type classifications permit 
the Company to identify and prioritize its risk exposures, 
including emerging risk exposures. 

Wells Fargo & Company 

57 

  
Risk Management (continued) 

Operational Risk Management 
Operational risk, which in addition to those discussed in this 
section, includes compliance risk and model risk, is the risk 
resulting from inadequate or failed internal processes, people 
and systems, or from external events. 

The Board’s Risk Committee has primary oversight 

responsibility for all aspects of operational risk, including 
significant supporting programs and/or policies regarding the 
Company’s business resiliency and disaster recovery, data 
management, information security, 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 operational risk management program. 
At the management level, the Operational Risk Group 

organization, which is part of IRM, has primary oversight 
responsibility for operational risk. The Operational Risk Group 
reports to the CRO and also provides periodic reports related to 
operational risk to the Board’s Risk Committee. Technology, 
Third Party and Information Risk Oversight, which is part of the 
Operational Risk Group, has oversight responsibility for 
technology risk, third-party risk, information risk management, 
and information security risk. Enterprise Data Governance, which 
is part of the Operational Risk Group, has oversight responsibility 
for data management risk. Oversight of human capital risk, an 
operational risk, is performed by the Human Resources function 
with reporting paths to relevant management governance 
committees including to the ERCC. 

Information security is a significant operational risk for 
financial institutions such as Wells Fargo, and includes the risk 
arising from unauthorized access, use, disclosure, disruption, 
modification, or destruction of information or information 
systems. The 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. A Technology Subcommittee of the Risk Committee 
assists the Risk Committee in providing oversight of technology, 
information security, and cybersecurity risks as well as data 
management risk. The Technology Subcommittee reviews and 
recommends to the Risk Committee for approval any significant 
supporting information security risk (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, 
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 (a type of operational risk) is the risk resulting 
from the failure to comply with laws (legislation, regulations and 
rules) and regulatory guidance, and the failure to appropriately 
address associated impacts, including to customers. Compliance 
risk encompasses violations of applicable internal policies, 
program requirements, procedures, and standards related to 
ethical principles applicable to the banking industry. 

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 
supporting compliance risk and financial crimes risk policies and 
programs, and oversees the Company’s compliance risk 
management and financial crimes risk management programs. A 
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. 

Conduct risk, a sub-category of compliance risk, is the risk of 

inappropriate, unethical, or unlawful behavior on the part of 
team members or individuals acting on behalf of the Company, 
caused by deliberate or unintentional 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). 
The Board’s Risk Committee has primary oversight responsibility 
for enterprise-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 enterprise-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, Wells Fargo Compliance, which is 

part of IRM, monitors the implementation of the Company’s 
compliance and conduct risk programs. 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 reports related to 
compliance risk to the Board’s Risk Committee and Compliance 
Subcommittee. 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. 

Model Risk Management 
Model risk (a type of operational risk) is the risk arising from the 
potential for adverse consequences from decisions made based 
on model outputs that may be incorrect or used inappropriately. 

The Board’s Risk Committee has primary oversight 

responsibility for model risk. As part of its oversight 

58 

Wells Fargo & Company 

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 Model Risk function, which is 
part of IRM, has primary oversight responsibility for model risk 
and is responsible for governance, validation and monitoring of 
model risk across the Company. The Model Risk function reports 
to the CRO and also provides periodic reports related to model 
risk to the Board’s Risk Committee. 

Strategic Risk Management 
Strategic risk is the risk to earnings, capital, or liquidity arising 
from adverse business decisions, improper implementation of 
strategic initiatives, or inadequate responses to changes in the 
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 and risk management effectiveness. 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 receives updates from 
management regarding new business initiatives activity and risks 
related to new or changing products, as appropriate. 

At the management level, the Strategic Risk Oversight 

function, which is part of IRM, has primary oversight 
responsibility for strategic risk. The Strategic Risk Oversight 
function reports into the CRO and also provides periodic reports 
related to strategic risk to the Board’s Risk Committee. 

Reputation Risk Management 
Reputation risk is the risk arising from the potential that 
negative stakeholder opinion or negative publicity regarding the 
Company’s business practices, whether true or not, will adversely 
impact current or projected financial conditions and resilience, 
cause a decline in the customer base, or result in costly litigation. 
Stakeholders include team members, customers, communities, 
shareholders, regulators, elected officials, advocacy groups, and 
media organizations. 

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 IRM, has primary oversight 
responsibility for reputation risk. The Reputation Risk Oversight 
function reports into the CRO and also provides periodic reports 
related to reputation risk to the Board’s Risk 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, Credit 
Risk, which is part of IRM, has primary oversight responsibility 
for credit risk. Credit Risk reports to the CRO and also provides 
periodic reports related to credit risk to the Board’s Credit 
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: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Dec 31, 2019 

Dec 31, 2018 

$ 

354,125 

121,824 

19,939 

19,831 

515,719 

350,199 

121,014 

22,496 

19,696 

513,405 

Real estate 1-4 family first mortgage 

293,847 

285,065 

Real estate 1-4 family junior lien mortgage 

Credit card 

Automobile 

Other revolving credit and installment 

Total consumer 

Total loans 

29,509 

41,013 

47,873 

34,304 

446,546 

$ 

962,265 

34,398 

39,025 

45,069 

36,148 

439,705 

953,110 

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 
• 

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

Reputation risk 

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. 

Wells Fargo & Company 

59 

  
Risk Management – Credit Risk Management (continued) 

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. 

Credit Quality Overview  Solid credit quality continued in 2019, 
as our net charge-off rate remained low at 0.29% of average 
total loans. Our loss rate reflected improvements in the credit 
performance of our automobile portfolio, partially offset by a 
lower volume of recoveries in other loan portfolios. In particular: 
•  Nonaccrual loans were $5.3 billion at December 31, 2019, 
down from $6.5 billion at December 31, 2018. Commercial 
nonaccrual loans increased to $2.3 billion at December 31, 
2019, compared with $2.2 billion at December 31, 2018, and 
consumer nonaccrual loans declined to $3.1 billion at 
December 31, 2019, compared with $4.3 billion at 
December 31, 2018. A decline in real estate 1-4 family 
mortgage nonaccrual loans reflecting an improved housing 
market, sales of nonaccrual mortgage loans, and the 
reclassification of nonaccrual mortgage loans to MLHFS was 
partially offset by an increase in commercial and industrial 
nonaccrual loans driven by the oil and gas portfolio. 
Nonaccrual loans represented 0.56% of total loans at 
December 31, 2019, compared with 0.68% at December 31, 
2018. 

•  Net charge-offs as a percentage of our average commercial 

• 

and consumer portfolios were 0.13% and 0.48%, 
respectively, in 2019, compared with 0.09% and 0.52% in 
2018. 
Loans that are not government insured/guaranteed and 
90 days or more past due and still accruing were $78 million 
and $855 million in our commercial and consumer 
portfolios, respectively, at December 31, 2019, compared 
with $94 million and $885 million at December 31, 2018. 

•  Our provision for credit losses was $2.7 billion in 2019, 

compared with $1.7 billion in 2018. The provision for credit 
losses in both 2019 and 2018 reflected continuing solid 
underlying credit performance. The provision for credit 
losses in 2018 also reflected a higher level of credit quality 
improvement compared with 2019, as well as an 
improvement in the outlook associated with 2017 
hurricane-related losses. 
The allowance for credit losses declined to $10.5 billion, or 
1.09% of total loans, at December 31, 2019, compared with 
$10.7 billion, or 1.12%, at December 31, 2018. 

• 

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. A nonaccretable 
difference is established for PCI loans to absorb losses expected 
on the contractual amounts of those loans. Amounts absorbed 
by the nonaccretable difference do not affect the income 
statement or the allowance for credit losses. The carrying value 
of PCI loans at December 31, 2019, totaled $568 million, 
compared with $5.0 billion at December 31, 2018. The decline in 
carrying value was due to the sale of $4.0 billion of PCI loans, 
predominantly Pick-a-Pay, during 2019 and paydowns. 

For additional information on PCI loans, see the “Risk 

Management – Credit Risk Management – Real Estate 1-4 Family 
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 segmented among special mention, substandard, 
doubtful and loss categories. 

The commercial and industrial loans and lease financing 

portfolio totaled $374.0 billion, or 39% of total loans, at 
December 31, 2019. The net charge-off rate for this portfolio 
was 0.18% in 2019, compared with 0.13% in 2018. At 
December 31, 2019, 0.44% of this portfolio was nonaccruing, 
compared with 0.43% at December 31, 2018. Nonaccrual loans in 
this portfolio increased $64 million in 2019, due to a customer in 
the utilities industry, as well as increases in the oil, gas and 
pipeline portfolio, partially offset by improvement across various 
industry categories. Also, $16.6 billion of the commercial and 
industrial loan and lease financing portfolio was internally 
classified as criticized in accordance with regulatory guidance at 
December 31, 2019, compared with $15.8 billion at 
December 31, 2018. 

Most of our commercial and industrial loans and lease 
financing portfolio is secured by short-term assets, such as 
accounts receivable, inventory and debt 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. 

60 

Wells Fargo & Company 

  
 
 
Table 18 provides our commercial and industrial loans and 

lease financing by industry, and includes non-U.S. loans of 
$71.7 billion and $63.7 billion at December 31, 2019 and 2018, 
respectively. Significant industry concentrations of non-U.S. 
loans include $31.2 billion and $25.6 billion in the financials 
except banks category and $19.9 billion and $18.1 billion in the 
banks category at December 31, 2019 and 2018, respectively. 
The industry categories were updated in 2019 to align with 
industry groupings that our regulators use to monitor industry 
concentration risks. 

Loans to financials except banks, our largest industry 
concentration, were $117.3 billion, or 12% of total outstanding 
loans, at December 31, 2019, compared with $105.9 billion, or 

11% of total outstanding loans, at December 31, 2018. This 
industry category includes loans to investment firms, financial 
vehicles, and non-bank creditors, including those that invest in 
financial assets backed predominantly by commercial or 
residential real estate or consumer loan assets. We limit our loan 
amounts to a percentage of the value of the underlying assets 
considering underlying credit risk, asset duration, and ongoing 
performance. 

Oil, gas and pipeline loans totaled $13.6 billion, or 1% of 
total outstanding loans, at December 31, 2019, compared with 
$12.8 billion, or 1% of total outstanding loans, at December 31, 
2018. 

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

(in millions) 

Financials except banks 

Equipment, machinery and parts manufacturing 

Technology, telecom and media 

Real estate and construction 

Banks 

Retail 

Materials and commodities 

Automobile related 

Food and beverage manufacturing 

Health care and pharmaceuticals 

Oil, gas and pipelines 

Entertainment and recreation 

Transportation services 

Commercial services 

Agribusiness 

Utilities 

Insurance and fiduciaries 

Government and education 

Other (2) 

Total 

December 31, 2019 

December 31, 2018 

Nonaccrual 
loans 

Total 
portfolio 

% of total 
loans 

Nonaccrual 
loans 

Total 
portfolio 

% of total 
loans 

$ 

112 

117,312 

12% 

$ 

305 

105,925 

11% 

36 

28 

47 

— 

23,457 

22,447 

22,011 

20,070 

105 

19,923 

33 

24 

9 

28 

615 

44 

224 

50 

35 

224 

1 

6 

16,375 

15,996 

14,991 

14,920 

13,562 

13,462 

10,957 

10,455 

7,539 

5,995 

5,525 

5,363 

19 

13,596 

2 

2 

2 

2 

2 

2 

2 

2 

2 

1 

1 

1 

1 

1 

1 

1 

1 

1 

47 

26 

31 

— 

87 

136 

16 

48 

124 

417 

33 

176 

48 

46 

6 

1 

3 

20,850 

25,681 

23,380 

18,407 

19,541 

18,688 

16,801 

15,448 

15,529 

12,840 

14,045 

12,029 

10,591 

7,996 

5,756 

5,510 

6,160 

26 

14,718 

2 

3 

2 

2 

2 

2 

2 

2 

2 

1 

1 

1 

1 

1 

1 

1 

1 

1 

$ 

1,640 

373,956 

39% 

$ 

1,576 

369,895 

39% 

(1) 

(2) 

Industry categories are based on the North American Industry Classification System and the amounts reported include non-U.S. loans. The industry categories were updated in 2019 to align with 
industry groupings that our regulators use to monitor industry concentration risks. The amounts for December 31, 2018, have been reclassified to conform with the current period presentation. See 
Note 6 (Loans and Allowance for Credit Losses) to Financial Statements in this Report for a breakout of non-U.S. commercial loans. 
No other single industry had total loans in excess of $4.7 billion and $4.5 billion at December 31, 2019 and 2018, respectively. 

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 
for credit losses 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. 

Wells Fargo & Company 

61 

  
Risk Management – Credit Risk Management (continued) 

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 $8.4 billion of 
non-U.S. CRE loans, totaled $141.8 billion, or 15% of total loans, 
at December 31, 2019, and consisted of $121.8 billion of 
mortgage loans and $19.9 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 

Table 19:  CRE Loans by State and Property Type 

geographic concentrations of CRE loans are in California, New 
York, Florida and Texas, which combined represented 49% of the 
total CRE portfolio. By property type, the largest concentrations 
are office buildings at 26% and apartments at 17% of the 
portfolio. CRE nonaccrual loans totaled 0.43% of the CRE 
outstanding balance at both December 31, 2019, and 
December 31, 2018. At December 31, 2019, we had $3.8 billion 
of criticized CRE mortgage loans, compared with $4.5 billion at 
December 31, 2018, and $187 million of criticized CRE 
construction loans, compared with $289 million at December 31, 
2018. 

Real estate mortgage 

Real estate construction 

Nonaccrual 
loans 

Total 
portfolio 

Nonaccrual 
loans 

Total 
portfolio 

Nonaccrual 
loans 

December 31, 2019 

% of 
total
loans 

(in millions) 

By state: 

California 

New York 

Florida 

Texas 

Arizona 

Washington 

North Carolina 

Georgia 

Virginia 

New Jersey 

Other 

Total 

By property: 

Office buildings 

Apartments 

Industrial/warehouse 

Retail (excluding shopping center) 

Shopping center 

Hotel/motel 

Mixed use properties (2) 

Institutional 

Collateral pool 

Agriculture 

Other 

Total 

$ 

149 

$ 

$ 

21 

23 

42 

70 

9 

17 

15 

6 

16 

205 

573 

105 

9 

81 

128 

2 

16 

92 

39 

— 

91 

10 

32,079 

12,076 

8,081 

7,877 

4,212 

3,757 

3,823 

3,819 

2,808 

2,846 

40,446 

121,824 

34,188 

18,243 

15,813 

14,510 

10,816 

10,319 

6,377 

3,617 

2,328 

2,116 

3,497 

$ 

573 

121,824 

12 

2 

4 

5 

— 

— 

4 

— 

— 

— 

14 

41 

6 

— 

2 

5 

— 

— 

1 

10 

— 

— 

17 

41 

4,415 

1,863 

1,450 

1,389 

303 

709 

540 

401 

680 

628 

7,561 

19,939 

2,919 

6,415 

1,492 

210 

1,313 

1,459 

487 

1,924 

198 

10 

3,512 

19,939 

Total 

Total 
portfolio 

36,494 

13,939 

9,531 

9,266 

4,515 

4,466 

4,363 

4,220 

3,488 

3,474 

48,007 

(1) 

141,763 

37,107 

24,658 

17,305 

14,720 

12,129 

11,778 

6,864 

5,541 

2,526 

2,126 

7,009 

161 

23 

27 

47 

70 

9 

21 

15 

6 

16 

219 

614 

111 

9 

83 

133 

2 

16 

93 

49 

— 

91 

27 

4% 

1 

1 

1 

1 

1 

1 

* 

* 

* 

5 

15% 

4% 

3 

2 

2 

1 

1 

1 

* 

* 

* 

1 

614 

141,763 

15% 

Less than 1%. 
Includes 40 states; no state had loans in excess of $3.5 billion. 

* 
(1) 
(2)  Mixed use properties combines residential, commercial, cultural, and other usage within the same building. This also includes data centers, flexible spaces leased to multiple tenants, light 

manufacturing, and other specialized uses. 

NON-U.S. LOANS  Our classification of non-U.S. loans is based on 
whether the borrower’s primary address is outside of the United 
States. At December 31, 2019, non-U.S. loans totaled 
$80.5 billion, representing approximately 8% of our total 
consolidated loans outstanding, compared with $71.9 billion, or 
approximately 8% of total consolidated loans outstanding, at 
December 31, 2018. Non-U.S. loans were approximately 4% of 
our consolidated total assets at both December 31, 2019, and 
December 31, 2018. 

COUNTRY RISK EXPOSURE  Our country risk monitoring process 
incorporates centralized monitoring of economic, political, social, 
legal, and transfer risks in countries where we do or plan to do 

business, along with frequent dialogue with our customers, 
counterparties and regulatory agencies. We establish exposure 
limits for each country through a centralized oversight process 
based on customer needs, and through consideration of the 
relevant and distinct risk of each country. 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 country 
exposure outside the U.S. based on our assessment of risk at 

62 

Wells Fargo & Company 

  
December 31, 2019, was the United Kingdom, which totaled 
$31.6 billion, and included $8.0 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 withdrew from the European Union 

(Brexit) on January 31, 2020, and is currently subject to a 
transition period during which the terms and conditions of its 
exit are being negotiated. As the United Kingdom exits from the 
European Union, 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 those locations. We have an existing 
authorized bank in Ireland and an asset management entity in 
Luxembourg. Additionally, we established a broker dealer in 
France. We are in the process of leveraging these entities to 
continue to serve clients in the European Union and continue to 
take actions to update our business operations in the United 
Kingdom and European Union, including implementing new 

Table 20:  Select Country Exposures 

supplier contracts and staffing arrangements. 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 
consideration to the country of any guarantors and/or underlying 
collateral. With respect to Table 20: 
• 

Lending exposure includes outstanding loans, unfunded 
credit commitments, and deposits with non-U.S. banks. 
These balances are presented prior to the deduction of 
allowance for credit losses or collateral received under the 
terms of the credit agreements, if any. 
Securities exposure represents debt and equity securities of 
non-U.S. issuers. Long and short positions are netted, and 
net short positions are reflected as negative exposure. 
•  Derivatives and other exposure represents foreign exchange 
contracts, derivative contracts, securities resale agreements, 
and securities lending agreements. 

• 

(in millions) 

Top 20 country exposures: 

United Kingdom 

Canada 

Cayman Islands 

Ireland 

China 

Luxembourg 

Bermuda 

Guernsey 

Germany 

Netherlands 

South Korea 

Brazil 

France 

Australia 

India 

Chile 

Switzerland 

Taiwan 

United Arab Emirates 

Hong Kong 

Securities 

Derivatives and other 

December 31, 2019 

Total exposure 

Sovereign 

Non-
sovereign 

Sovereign 

Non-
sovereign 

Sovereign 

Non-
sovereign (1) 

Total 

Lending 

Non-
sovereign 

21,617 

17,661 

— 

(68) 

7,442 

4,971 

4,022 

3,636 

3,824 

3,554 

2,773 

2,019 

2,023 

2,075 

1,882 

1,720 

1,734 

1,698 

1,482 

1,369 

1,323 

1,333 

— 

— 

5 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

881 

194 

31 

102 

408 

654 

103 

1 

128 

364 

268 

1 

137 

145 

130 

(1) 

(51) 

(6) 

— 

(14) 

2 

— 

— 

— 

59 

— 

— 

— 

3 

20 

— 

1 

29 

— 

— 

— 

— 

1 

— 

1 

1,067 

7,991 

272 

126 

137 

20 

83 

54 

65 

42 

126 

6 

1 

9 

8 

— 

— 

57 

2 

3 

2 

(32) 

— 

225 

64 

— 

— 

— 

3 

20 

— 

1 

29 

— 

— 

— 

— 

1 

— 

1 

23,565 

18,127 

31,556 

18,095 

7,599 

5,210 

4,450 

4,373 

3,981 

3,620 

2,943 

2,509 

2,297 

2,077 

2,028 

1,873 

1,864 

1,697 

1,488 

1,365 

1,326 

1,321 

7,599 

5,435 

4,514 

4,373 

3,981 

3,620 

2,946 

2,529 

2,297 

2,078 

2,057 

1,873 

1,864 

1,697 

1,488 

1,366 

1,326 

1,322 

Sovereign 

$ 

7,989 

36 

— 

225 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

Total top 20 country exposures 

$ 

8,250 

88,158 

(63) 

3,475 

116 

2,080 

8,303 

93,713 

102,016 

Eurozone exposure: 

Eurozone countries included in Top 20 above (2) 

$ 

225 

15,281 

Spain 
Belgium 

Austria 

Other Eurozone countries 

Total Eurozone exposure 

— 
— 

— 

— 

401 
766 

305 

230 

$ 

225 

16,983 

— 

— 
— 

— 

— 

— 

1,385 

466 
(72) 

— 

55 

1,834 

52 

— 
— 

— 

— 

52 

397 

30 
1 

— 

1 

429 

277 

— 
— 

— 

— 

277 

17,063 

17,340 

897
695 

305

286 

897 
695 

305 

286 

19,246 

19,523 

(1) 
(2) 

For countries presented in the table, total non-sovereign exposure comprises $53.1 billion exposure to financial institutions and $42.8 billion to non-financial corporations at December 31, 2019. 
Consists of exposure to Ireland, Luxembourg, Germany, Netherlands and France, which are included in the Top 20 country exposures. 

Wells Fargo & Company 

63 

  
Risk Management – Credit Risk Management (continued) 

REAL ESTATE 1-4 FAMILY MORTGAGE LOANS  Our real estate 1-4 
family mortgage loan portfolio is composed of both first and 
junior lien mortgage loans, which are presented in Table 21. 

Table 21:  Real Estate 1-4 Family Mortgage Loans 

(in millions) 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Total real estate 1-4 family mortgage loans 

December 31, 2019 

December 31, 2018 

Balance 

% of 
portfolio 

Balance 

% of 
portfolio 

$ 

293,847 

91% 

$ 

285,065 

29,509 

9 

34,398 

$ 

323,356 

100% 

$ 

319,463 

89% 

11 

100% 

The real estate 1-4 family mortgage loan portfolio includes 

Real estate 1-4 family mortgage loans by state are 

presented in Table 22. Our real estate 1-4 family non-PCI 
mortgage loans to borrowers in California represented 13% of 
total loans at December 31, 2019, 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 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 original appraisals adjusted for the change in Home 
Price Index (HPI) 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 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 mortgage commitments greater than 
$250,000. Additional information about appraisals, 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 3% and 4% of total loans at 
December 31, 2019 and 2018, respectively. We believe we have 
manageable adjustable-rate mortgage (ARM) reset risk across 
our 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 for credit losses 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 on the non-PCI mortgage 
portfolio exclude government insured/guaranteed loans. Loans 
30 days or more delinquent at December 31, 2019, totaled 
$3.0 billion, or 1% of total non-PCI mortgages, compared with 
$4.0 billion, or 1%, at December 31, 2018. Loans with FICO 
scores lower than 640 totaled $7.6 billion, or 2% of total non-PCI 
mortgages at December 31, 2019, compared with $9.7 billion, or 
3%, at December 31, 2018. Mortgages with a LTV/CLTV greater 
than 100% totaled $2.5 billion at December 31, 2019, or 1% of 
total non-PCI mortgages, compared with $3.9 billion, or 1%, at 
December 31, 2018. 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. 

64 

Wells Fargo & Company 

 
  
Table 22:  Real Estate 1-4 Family Mortgage Loans by State 

(in millions) 

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

California 

New York 

New Jersey 

Florida 

Washington 

Virginia 

Texas 

North Carolina 

Colorado 

Other (1) 

Government insured/guaranteed loans (2) 

Real estate 1-4 family loans (excluding PCI) 

Real estate 1-4 family PCI loans 

Total 

December 31, 2019 

Real estate 
1-4 family 
first 

Real 
Total real 
estate 1-4 
estate 1-4 
family 
junior lien 
family 
mortgage  mortgage  mortgage 

% of 
total 
loans 

126,310 

13% 

$  118,256 

31,336 

14,113 

11,804 

10,863 

8,857 

8,963 

5,839 

6,382 

65,709 

11,170 

8,054 

1,508 

2,744 

2,600 

655 

1,712 

596 

1,388 

664 

9,575 

— 

32,844 

16,857 

14,404 

11,518 

10,569 

9,559 

7,227 

7,046 

75,284 

11,170 

293,292 

29,496 

322,788 

555 

13 

568

$  293,847 

29,509 

323,356 

34% 

3 

2 

2 

1 

1 

1 

1 

1 

8 

1 

34 

— 

(1) 
(2) 

Consists of 41 states; no state had loans in excess of $7.0 billion. 
Represents loans whose repayments are predominantly insured by the Federal Housing Administration (FHA) or guaranteed by the Department of Veterans Affairs (VA). 

First Mortgage Portfolio  Our total real estate 1-4 family first 
lien mortgage portfolio (first mortgage) increased $8.8 billion in 
2019. Mortgage loan originations of $67.4 billion in 2019 were 
partially offset by paydowns and $4.0 billion of sales of PCI loans, 
predominantly Pick-a-Pay. Also, we purchased $3.3 billion of 
mortgage loans in 2019 as a result of exercising servicer cleanup 
calls. In addition, during 2019, we reclassified $1.9 billion of 
existing mortgage loans to MLHFS in anticipation of future 
whole loan sales. We also originated $3.4 billion of 
nonconforming mortgage loan originations as MLHFS in 2019, in 
anticipation of the issuance of residential mortgage-backed 
securities. 

The credit performance associated with our real estate 1-4 

family first mortgage portfolio remained strong in 2019, as 

Table 23:  First Mortgage Portfolio Performance 

measured through nonaccrual loans and net charge-offs. 
Nonaccrual loans decreased to $2.2 billion at December 31, 
2019, compared with $3.2 billion at December 31, 2018, driven 
by nonaccrual loan sales, the reclassification of nonaccrual loans 
to MLHFS in anticipation of future sales, and overall continued 
credit improvement. Net charge-offs as a percentage of average 
real estate 1-4 family first mortgage loans was a net recovery of 
0.02% in 2019, compared with a net recovery of 0.03% in 2018. 

Table 23 shows certain delinquency and loss information for 

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

(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, 

2019 

2018 

$ 

118,256 

109,092 

31,336 

14,113 

11,804 

10,863 

95,750 

282,122 

11,170 

555 

28,954 

13,811 

12,350 

9,677 

93,261 

267,145 

12,932 

4,988 

2019 

0.48% 

0.83 

1.40 

1.81 

0.29 

1.20 

0.86 

2018 

0.68 

1.12 

1.91 

2.58 

0.57 

1.70 

1.23 

2019 

(0.02) 

0.02 

0.02 

(0.06) 

(0.02) 

(0.02) 

(0.02) 

2018 

(0.06) 

0.04 

0.03 

(0.17) 

(0.06) 

(0.02) 

(0.03) 

Total first mortgage portfolio 

$ 

293,847 

285,065 

Wells Fargo & Company 

65 

  
  
Risk Management – Credit Risk Management (continued) 

Pick-a-Pay Portfolio  The Pick-a-Pay portfolio was one of the 
consumer residential mortgage portfolios we acquired from 
Wachovia. The Pick-a-Pay portfolio is included in consumer real 
estate 1-4 family first mortgage loans throughout this Report. 
Pick-a-Pay option payment loans may have fixed or adjustable 

rates with payment options that may include a minimum 
payment, an interest-only payment or fully amortizing payment 
(both 15- and 30-year options). Table 24 provides balances by 
types of loans as of December 31, 2019. 

Table 24:  Pick-a-Pay Portfolio 

(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) 

2019 

% of total 

Adjusted 
unpaid principal 
balance (1) 

$ 

$ 

$ 

4,571 

2,161 

2,320 

9,052 

8,936 

50% 

$ 

24 

26 

100% 

$ 

$ 

8,813 

2,848 

6,080 

17,741 

16,115 

December 31, 

2018 

% of total 

50% 

16 

34 

100% 

(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. 

Our Pick-a-Pay portfolio included PCI loans with a carrying 

value of $519 million at December 31, 2019, compared with 
$4.9 billion at December 31, 2018. During 2019, we sold 
$4.0 billion of Pick-a-Pay PCI loans that resulted in a gain of 
$1.6 billion. The accretable yield balance of our Pick-a-Pay PCI 
loan portfolio was $134 million ($229 million for all PCI loans) at 
December 31, 2019, compared with $2.8 billion ($3.0 billion for 
all PCI loans) at December 31, 2018. The decrease was 
predominantly due to Pick-a-Pay PCI loan sales. The estimated 
weighted-average life was approximately 5.1 years and 5.5 years 
at December 31, 2019 and 2018, respectively. The accretable 
yield percentage for Pick-a-Pay PCI loans for fourth quarter 
2019 was 11.69%. 

For additional information on PCI loans, see Note 1 

(Summary of Significant Accounting Policies) to Financial 
Statements in this Report. 

66 

Wells Fargo & Company 

 
  
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, such as junior lien 
mortgage performance when the first mortgage loan is 
delinquent. 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, 2018, predominantly 

Table 25:  Junior Lien Mortgage Portfolio Performance 

reflected loan paydowns. As of December 31, 2019, 4% 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%, 3% were 30 days or more past due. 
CLTV means the ratio of the total loan balance of first 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 1% of the junior lien mortgage portfolio at 
December 31, 2019. 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. 

Outstanding balance 

% of loans 30 days 
or more past due 

Loss (recovery) rate 

December 31, 

December 31, 

Year ended December 31, 

(in millions) 

California 

New Jersey 

Florida 

Virginia 

Pennsylvania 

Other 

Total 

PCI 

$ 

2019 

8,054 

2,744 

2,600 

1,712 

1,674 

12,712 

29,496 

13 

Total junior lien mortgage portfolio 

$ 

29,509 

2019 

1.62% 

2.74 

2.93 

1.97 

2.16 

2.05 

2.07 

2018 

1.67 

2.57 

2.73 

1.91 

2.10 

2.12 

2.08 

2019 

(0.44) 

0.07 

(0.09) 

(0.02) 

(0.10) 

(0.18) 

(0.21) 

2018 

(0.46) 

0.25 

— 

0.19 

0.15 

(0.07) 

(0.11) 

2018 

9,338 

3,152 

3,140 

2,020 

1,929 

14,802 

34,381 

17 

34,398 

Wells Fargo & Company 

67 

  
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 available during the draw 
period of (1) interest-only or (2) 1.5% of outstanding principal 
balance plus accrued interest. As of December 31, 2019, lines of 
credit in a draw period primarily used the interest-only option. 
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 2019, approximately 46% of these borrowers paid 
only the minimum amount due and approximately 51% 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 65% 
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. At December 31, 2019, $488 million, or 2%, of 
lines in their draw period were 30 days or more past due, 
compared with $399 million, or 4%, of amortizing lines of credit. 
Included in the amortizing amounts in Table 26 is $46 million of 
end-of-term balloon payments which were past due. The 
unfunded credit commitments for junior and first lien lines 
totaled $58.9 billion at December 31, 2019. 

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 

% of portfolios 

Outstanding balance 

December 31, 2019 

2020 

$ 

$ 

29,496 

10,384 

39,880 

100% 

334 

139 

473 

1 

Scheduled end of draw/term 

2025 and 

2021 

863 

414 

1,277 

3

2022 

3,308 

1,618 

4,926 

12 

2023 

2,276 

1,214 

3,490 

9 

2024 

1,850 

956 

2,806 

7 

thereafter (1) 

Amortizing 

11,754 

4,328 

16,082 

40 

9,111 

1,715 

10,826 

28 

(1) 

Substantially all lines and loans are scheduled to convert to amortizing loans by the end of 2029, with annual scheduled amounts through 2029 ranging from $1.9 billion to $4.8 billion and averaging 
$3.2 billion per year. 

CREDIT CARDS  Our credit card portfolio totaled $41.0 billion at 
December 31, 2019, which represented 4% of our total 
outstanding loans. The net charge-off rate for our credit card 
portfolio was 3.53% for 2019, compared with 3.51% for 2018. 

AUTOMOBILE  Our automobile portfolio totaled $47.9 billion at 
December 31, 2019. The net charge-off rate for our automobile 
portfolio was 0.67% for 2019, compared with 1.21% for 2018. 
The decrease in the net charge-off rate for 2019, compared with 
2018, was driven by lower early losses on higher quality 
originations. 

OTHER REVOLVING CREDIT AND INSTALLMENT  Other revolving 
credit and installment loans totaled $34.3 billion at 
December 31, 2019, and largely included student and securities-
based loans. Our private student loan portfolio totaled 
$10.6 billion at December 31, 2019. The net charge-off rate for 
other revolving credit and installment loans was 1.59% for 2019, 
compared with 1.53% for 2018. 

68 

Wells Fargo & Company 

  
 
 
 
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 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. 

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

Note 1 (Summary of Significant Accounting Policies – Loans) 

to Financial Statements in this Report describes our accounting 
policy for nonaccrual and impaired loans and foreclosed assets. 
For additional information on impaired loans, see Note 6 (Loans 
and Allowance for Credit Losses) to Financial Statements in this 
Report. 

Nonaccrual loans were $5.3 billion at December 31, 2019, 
down $1.2 billion from a year ago. Consumer nonaccrual loans 
were down $1.2 billion from a year ago predominantly due to a 
decrease in real estate 1-4 family mortgage nonaccrual loans, 
reflecting broad-based credit improvement, sales of nonaccrual 
mortgage loans, and the reclassification of nonaccrual mortgage 
loans to MLHFS. Commercial nonaccrual loans increased 
$66 million from a year ago, predominantly due to an increase in 
commercial and industrial nonaccrual loans, driven by a customer 
in the utilities industry, as well as increases in the oil, gas and 
pipeline portfolio, partially offset by credit improvement across 
various industry categories. Additionally, foreclosed assets 
decreased $148 million from December 31, 2018, driven by sales 
of commercial 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 (1) 

Real estate 1-4 family junior lien mortgage (1) 

Automobile 

Other revolving credit and installment 

Total consumer 

Total nonaccrual loans (2)(3) 

As a percentage of total loans 

Foreclosed assets: 

Government insured/guaranteed (4) 

Non-government insured/guaranteed 

Total foreclosed assets 

Total nonperforming assets 

As a percentage of total loans 

2019 

2018 

2017 

2016 

2015 

December 31, 

$ 

$ 

$ 

$ 

1,545 

573 

41 

95 

2,254 

2,150 

796 

106 

40 

3,092 

5,346 

0.56% 

50 

253 

303 

5,649 

0.59% 

1,486 

580 

32

90 

1,899 

628 

37

76

3,199 

685 

43 

115 

1,363 

969 

66 

26 

2,188 

2,640 

4,042 

2,424 

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 

(1) 
(2) 

(3) 
(4) 

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. 
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, and $464 million at December 31, 2017, 2016, and 2015, respectively. 
Excludes PCI loans because they continue to earn interest income from accretable yield, independent of performance in accordance with their contractual terms. 
Consistent with regulatory reporting requirements, foreclosed real estate resulting from government insured/guaranteed loans are classified as nonperforming. 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. Receivables related to the foreclosure of certain government 
guaranteed real estate mortgage loans 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. 

Wells Fargo & Company 

69 

  
  
Risk Management – Credit Risk Management (continued) 

Table 28 provides a summary of nonperforming assets 

during 2019. 

Table 28:  Nonperforming Assets by Quarter During 2019 

(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 (1) 

Real estate 1-4 family junior lien mortgage (1) 

Automobile 

Other revolving credit and installment 

Total consumer 

Total nonaccrual loans (2) 

Foreclosed assets: 

Government insured/guaranteed (3) 

Non-government insured/guaranteed 

Total foreclosed assets 

Total nonperforming assets 

Change in NPAs from prior quarter 

December 31, 2019 

September 30, 2019 

June 30, 2019 

March 31, 2019 

% of 

total 

loans 

Balance 

% of 

total 

loans 

Balance 

% of 

total 

loans 

Balance 

% of 

total 

loans 

Balance 

$ 

1,545 

0.44%  $ 

1,539 

0.44%  $ 

1,634 

0.47%  $ 

1,986 

0.57% 

0.47 

0.21 

0.48 

0.44 

0.73 

2.70 

0.22 

0.12 

0.69 

0.56 

573 

41 

95 

2,254 

2,150 

796 

106 

40 

3,092 

5,346 

50 

253 

303 

0.55 

0.16 

0.37 

0.45 

0.78 

2.66 

0.24 

0.12 

0.73 

0.58 

669 

32 

72 

2,312 

2,261 

819 

110 

43 

3,233 

5,545 

59 

378 

437 

0.60 

0.17 

0.33 

0.48 

0.85 

2.71 

0.25 

0.13 

0.79 

0.62 

737 

36 

63 

2,470 

2,425 

868 

115 

44 

3,452 

5,922 

68 

309 

377 

0.57 

0.16 

0.40 

0.55 

1.06 

2.77 

0.26 

0.14 

0.94 

0.73 

699 

36 

76 

2,797 

3,026 

916 

116 

50 

4,108 

6,905 

75 

361 

436 

$ 

$ 

5,649 

(333) 

0.59%  $ 

5,982 

0.63%  $ 

6,299 

0.66%  $ 

7,341 

0.77% 

(317) 

(1,042) 

394 

(1) 
(2) 
(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. 
Excludes PCI loans because they continue to earn interest income from accretable yield, independent of performance in accordance with their contractual terms. 
Consistent with regulatory reporting requirements, foreclosed real estate resulting from government insured/guaranteed loans are classified as nonperforming. 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. Receivables related to the foreclosure of certain government 
guaranteed real estate mortgage loans are excluded from this table and included in Accounts Receivable in Other Assets. For more information on the classification of certain government-
guaranteed residential mortgage loans upon foreclosure, see Note 1 (Summary of Significant Accounting Policies) to Financial Statements in this Report. 

70 

Wells Fargo & Company 

  
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 

Total nonaccrual loans 

$ 

Dec 31, 

2019 

2,312 

652 

(124) 

— 

(201) 

(385) 

(710) 

2,254 

3,233 

473 

(227) 

(29) 

(45) 

(313) 

(614) 

3,092 

5,346 

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. 

While nonaccrual loans are not free of loss content, we 

believe exposure to loss is significantly mitigated by the 
following factors at December 31, 2019: 
• 

86% of total commercial nonaccrual loans and 99% of total 
consumer nonaccrual loans are secured. Of the consumer 
nonaccrual loans, 95% are secured by real estate and 88% 
have a combined LTV (CLTV) ratio of 80% or less. 
losses of $360 million and $941 million have already been 
recognized on 19% of commercial nonaccrual loans and 35% 
of consumer nonaccrual loans, respectively, in accordance 
with our charge-off policies. Once we write down loans to 
the net realizable value (fair value of collateral less 
estimated costs to sell), we re-evaluate each loan regularly 
and record additional write-downs if needed. 
71% of commercial nonaccrual loans were current on 
interest and 66% of commercial nonaccrual loans were 
current on both principal and interest. These commercial 
loans were on nonaccrual status because the full or timely 
collection of interest or principal had become uncertain. 

• 

• 

Sep 30, 

2019 

2,470 

710 

(52) 

(78) 

(194) 

(544) 

(868) 

Quarter ended 

Mar 31, 

2019 

2,188 

1,238 

(43) 

(15) 

(158) 

(413) 

(629) 

Jun 30, 

2019 

2,797 

621 

(46) 

(2) 

(187) 

(713) 

(948) 

2,312 

2,470 

2,797 

3,452 

448 

(274) 

(32) 

(44) 

(317) 

(667) 

3,233 

5,545 

4,108 

437 

(250) 

(34) 

(34) 

(775) 

(1,093) 

3,452 

5,922 

4,308 

552 

(248) 

(42) 

(49) 

(413) 

(752) 

4,108 

6,905 

Year ended Dec 31, 

2019 

2018 

2,188 

3,221 

(265) 

(95) 

(740) 

(2,055) 

(3,155) 

2,254 

4,308 

1,910 

(999) 

(137) 

(172) 

(1,818) 

(3,126) 

3,092 

5,346 

2,640 

2,767 

(323) 

(12) 

(636) 

(2,248) 

(3,219) 

2,188 

5,006 

2,433 

(1,304) 

(166) 

(292) 

(1,369) 

(3,131) 

4,308 

6,496 

• 

• 

of the $1.3 billion of consumer loans in bankruptcy or 
discharged in bankruptcy, and classified as nonaccrual, 
$916 million were current. 
the remaining risk of loss of all nonaccrual loans has been 
considered and we believe is adequately covered by the 
allowance for loan losses. 

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 status at year end) had 
been accrued under the original terms, approximately 
$361 million of interest would have been recorded as income on 
these loans, compared with $316 million actually recorded as 
interest income in 2019, versus $446 million and $426 million, 
respectively, in 2018. 

Wells Fargo & Company 

71 

  
 
 
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 

Government insured/guaranteed 

Commercial 

Consumer 

Total foreclosed assets 

Analysis of changes in foreclosed assets 

Balance, beginning of period 

Net change in government insured/guaranteed (1) 

Additions to foreclosed assets (2) 

Reductions: 

Sales 

Write-downs and gains (losses) on sales 

Total reductions 

Balance, end of period 

Dec 31, 

2019 

Sep 30, 

2019 

Jun 30, 

2019 

Mar 31, 

2019 

Year ended Dec 31, 

2019 

2018 

Quarter ended 

$ 

$ 

$ 

50 

62 

191 

303 

437 

(9) 

126 

(250) 

(1) 

(251) 

303 

59 

180 

198 

437 

377 

(9) 

235 

(155) 

(11) 

(166) 

437 

68 

101 

208 

377 

436 

(7) 

144 

(199) 

3 

(196) 

377 

75 

124 

237 

436 

451 

(13) 

193 

(205) 

10 

(195) 

436 

50 

62 

191 

303 

451 

(38) 

698 

(809) 

1 

(808) 

303 

88 

127 

236 

451 

642 

(32) 

778 

(957) 

20 

(937) 

451 

(1) 
(2) 

Foreclosed government insured/guaranteed loans are temporarily transferred to and held by us as servicer, until reimbursement is received from FHA or VA. 
Includes loans moved into foreclosed assets from nonaccrual status, PCI loans transitioned directly to foreclosed assets and repossessed automobiles. 

Foreclosed assets at December 31, 2019, included 

$222 million of foreclosed residential real estate, of which 23% is 
predominantly FHA insured or VA guaranteed and expected to 
have minimal or no loss content. The remaining amount of 
foreclosed assets has been written down to estimated net 
realizable value. Of the $303 million in foreclosed assets at 
December 31, 2019, 69% have been in the foreclosed assets 
portfolio one year or less. 

72 

Wells Fargo & Company 

  
 
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: 

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 

Table 32:  TDRs Balance by Quarter During 2019 

(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 

$ 

$ 

$ 

2019 

1,183 

669 

36 

13 

1,901 

7,589 

1,407 

520 

81 

170 

115 

9,882 

11,783 

2,833 

1,190 

7,760 

$ 

11,783 

2018 

2017 

2016 

2015 

December 31, 

1,623 

704 

39 

56 

2,096 

901 

44 

35 

2,584 

1,119 

91 

6 

2,422 

3,076 

3,800 

10,629 

1,639 

449 

89 

154 

149 

13,109 

15,531 

4,058 

1,299 

10,174 

15,531 

12,080 

1,849 

356 

87 

126 

194 

14,692 

17,768 

4,801 

1,359 

11,608 

17,768 

14,134 

2,074 

300 

85 

101 

299 

16,993 

20,793 

6,193 

1,526 

13,074 

20,793 

1,123 

1,456 

125 

1 

2,705 

16,812 

2,306 

299 

105 

73 

402 

19,997 

22,702 

6,506 

1,771 

14,425 

22,702 

Dec 31, 
2019 

Sep 30, 
2019 

Jun 30, 
2019 

Mar 31, 
2019 

$ 

$ 

$ 

1,183 

669 

36 

13 

1,901 

7,589 

1,407 

520 

81 

170 

115 

9,882 

11,783 

2,833 

1,190 

7,760 

$ 

11,783 

1,162 

598 

40 

16 

1,294 

620 

43 

31 

1,740 

681 

45 

46 

1,816 

1,988 

2,512 

7,905 

1,457 

504 

82 

167 

123 

10,238 

12,054 

2,775 

1,199 

8,080 

12,054 

8,218 

1,550 

486 

85 

159 

127 

10,625 

12,613 

3,058 

1,209 

8,346 

12,613 

10,343 

1,604 

473 

85 

156 

136 

12,797 

15,309 

4,037 

1,275 

9,997 

15,309 

Table 31 and Table 32 provide information regarding the 
recorded investment of loans modified in TDRs. The allowance 
for loan losses for TDRs was $1.0 billion and $1.2 billion at 
December 31, 2019 and 2018, 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. 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 

Wells Fargo & Company 

73 

  
  
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 
equivalent, inclusive of consecutive payments made prior to 

modification. Loans will also be placed on nonaccrual status, 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. 

TDRs of $11.8 billion at December 31, 2019, decreased 
$3.7 billion from December 31, 2018, due to paydowns, as well 
as a reclassification of $1.7 billion in real estate 1-4 family first 
mortgage TDR loans to MLHFS. 

Table 33:  Analysis of Changes in TDRs 

(in millions) 

Commercial TDRs 

Balance, beginning of period 

$ 

Inflows (1) 

Outflows 

Charge-offs 

Foreclosure 

Payments, sales and other (2) 

Balance, end of period 

Consumer TDRs 

Balance, beginning of period 

Inflows (1) 

Outflows 

Charge-offs 

Foreclosure 

Payments, sales and other (2) 

Net change in trial modifications (3) 

Balance, end of period 

Total TDRs 

Dec 31, 
2019 

Sep 30, 
2019 

Jun 30, 
2019 

Mar 31, 
2019 

2019 

2018 

Quarter ended 

Year ended Dec 31, 

1,816 

476 

(48) 

(1) 

(342) 

1,901 

10,238 

350 

(57) 

(61) 

(580) 

(8) 

9,882 

$ 

11,783 

1,988 

293 

(66) 

—

(399) 

1,816 

10,625 

360 

(56) 

(70) 

(617) 

(4) 

10,238 

12,054 

2,512 

232 

(37) 

—

(719) 

1,988 

12,797 

336 

(61) 

(74) 

(2,364) 

(9) 

10,625 

12,613 

2,422 

539 

(44) 

— 

(405) 

2,512 

13,109 

439 

(60) 

(86) 

(593) 

(12) 

12,797 

15,309 

2,422 

1,540 

(195) 

(1) 

(1,865) 

1,901 

13,109 

1,485 

(234) 

(290) 

(4,154) 

(34) 

9,882 

11,783 

3,076 

1,764 

(284) 

(15) 

(2,119) 

2,422 

14,692 

1,747 

(223) 

(470) 

(2,591) 

(46) 

13,109 

15,531 

(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 TDRs that modified in a 
prior period. 

(2)  Other outflows include normal amortization/accretion of loan basis adjustments and loans transferred to held for sale. Occasionally, loans that have been refinanced or restructured at market terms 

(3) 

qualify as new loans, which are also included as other outflows. 
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. 

74 

Wells Fargo & Company 

  
LOANS 90 DAYS OR MORE PAST DUE AND STILL ACCRUING  Loans 90 
days or more past due 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, 2019, were down 

$46 million, or 5%, from December 31, 2018, due to payments, 
other loss mitigation activities, and credit stabilization. 

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 $6.4 billion at 
December 31, 2019, down from $7.7 billion at December 31, 
2018, due to an improvement in delinquencies, as well as a 
reduction in the portfolio. 

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. 

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

(in millions) 

Total (excluding PCI (2)): 

Less: FHA insured/VA guaranteed (3) 

Less: Student loans guaranteed under the FFELP (4) 

Total, not government insured/guaranteed 

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 

2019 

7,285 

6,352 

— 

933 

47 

31 

— 

78 

112 

32 

546 

78 

87 

855 

933 

$ 

$ 

$ 

$ 

2018 

8,704 

7,725 

— 

979 

43 

51 

—

94 

124 

32 

513 

114 

102 

885 

979 

December 31, 

2017 

11,532 

10,475 

— 

1,057 

2016 

11,437 

10,467 

3

967 

2015 

13,866 

12,863 

26 

977 

26 

23 

—

49 

213 

60 

492 

143 

100 

1,008 

1,057 

28 

36 

— 

64

170 

56 

452 

112 

113 

903 

967 

97 

13 

4 

114 

220 

65 

397 

79 

102 

863 

977 

(1) 

(2) 
(3) 
(4) 

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 and $4 million at December 31, 2017, 2016 and 2015, respectively. 
PCI loans totaled $102 million, $370 million, $1.4 billion, $2.0 billion and $2.9 billion at December 31, 2019, 2018, 2017, 2016 and 2015, respectively. 
Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. 
Represents loans whose repayments are largely guaranteed by agencies on behalf of the U.S. Department of Education under the Federal Family Education Loan Program (FFELP). All remaining 
student loans guaranteed under the FFELP were sold as of March 31, 2017. 

Wells Fargo & Company 

75 

  
Risk Management – Credit Risk Management (continued) 

NET CHARGE-OFFS 

Table 35:  Net Charge-offs 

($ in millions) 

2019 

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 

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 

Total 

$ 

$ 

$ 

607 

6 
(12) 

51 

652 

(50) 

(66) 

1,370 
306 

550 

2,110 

2,762 

423 

(28) 

(13) 

47 

429 

(88) 

(40) 

1,292 
584 

567 

2,315 

2,744 

Year ended 

December 31, 

December 31, 

September 30, 

June 30, 

Net loan 

charge-
offs 

% of 

avg. 
loans 

Net loan 

charge-
offs 

% of 

Net loan 

% of 

Net loan 

% of 

Net loan 

avg. 
loans (1) 

charge-
offs 

avg. 
loans (1) 

charge- 
offs 

avg. 
loans (1) 

charge-
offs 

Quarter ended 

March 31, 

% of 

avg. 
loans (1) 

0.17 %  $ 

168 

0.19 %  $ 

147 

0.17 %  $ 

159 

0.18 %  $ 

133 

— 
(0.06) 

0.26 

0.13 

(0.02) 

(0.21) 

3.53 
0.67 

1.59 

0.48 

0.29 %  $ 

0.13 %  $ 

(0.02) 

(0.05) 

0.24 

0.09 

(0.03) 

(0.11) 

3.51 
1.21 

1.53 

0.52 

0.29 %  $ 

4 
— 

31 

203 

0.01 
— 

0.63 

0.16 

(8) 
(8) 

8 

139 

(0.02) 
(0.14) 

0.17 

0.11 

(3) 

— 

(5) 

(0.01) 

(16) 

(0.20) 

(22) 

(0.28) 

350 
87 

148 

566 

769 

132 

(12) 

(1) 

13 

132 

(22) 

(10) 

338 

133 

150 

589 

721 

3.48 

0.73 

1.71 

0.51 

0.32 %  $ 

319 

76 

138 

506 

645 

3.22 

0.65 

1.60 

0.46 

0.27 %  $ 

0.15 %  $ 

148 

0.18 %  $ 

(0.04) 

(0.01) 

0.26 

0.10 

(0.03) 

(0.11) 

3.54 

1.16 

1.64 

0.53 

0.30 %  $ 

(1) 

(2) 

7 

152 

(25) 

(9) 

299 

130 

133 

528 

680 

— 

(0.04) 

0.14 

0.12 

(0.04) 

(0.10) 

3.22 

1.10 

1.44 

0.47 

0.29 %  $ 

4 
(2) 

4 

165 

(30) 

(19) 

349 

52 

136 

488 

653 

58 

— 

(6) 

15 

67 

(23) 

(13) 

323 

113 

135 

535 

602 

0.01 
(0.04) 

0.09 

0.13 

(0.04) 

(0.24) 

3.68 

0.46 

1.56 

0.45 

0.28 %  $ 

0.07 %  $ 

— 

(0.09) 

0.32 

0.05 

(0.03) 

(0.13) 

3.61 

0.93 

1.44 

0.49 

0.26 %  $ 

6 
(2) 

8 

145 

0.15 % 

0.02 
(0.04) 

0.17 

0.11 

(12) 

(0.02) 

(9) 

(0.10) 

352 

91 

128 

550 

695 

85 

(15) 

(4) 

12 

78 

(18) 

(8) 

332 

208 

149 

663 

741 

3.73 

0.82 

1.47 

0.51 

0.30 % 

0.10 % 

(0.05) 

(0.07) 

0.25 

0.06 

(0.03) 

(0.09) 

3.69 

1.64 

1.60 

0.60 

0.32 % 

(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 2019 and 2018. Net charge-offs in 2019 were $2.8 billion 
(0.29% of average total loans outstanding), compared with 
$2.7 billion (0.29%) in 2018. 

The increase in commercial and industrial net charge-offs in 
2019 was driven by lower recoveries, and higher losses in our oil 
and gas portfolio. The decrease in consumer net charge-offs in 
2019 was driven by lower losses, predominantly in the 
automobile portfolio, partially offset by a slight increase in losses 
in the credit card portfolio. 

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 for credit 
losses 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. 

76 

Wells Fargo & Company 

  
 
 
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) 

(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 

Dec 31, 2019 

Dec 31, 2018 

Dec 31, 2017 

Dec 31, 2016 

Dec 31, 2015 

Loans 

as % 
of total 
loans 

ACL 

Loans 

as % 
of total 
loans 

ACL 

Loans 

as % 
of total 
loans 

ACL 

Loans 

as % 
of total 
loans 

ACL 

Loans 

as % 
of total 
loans 

ACL 

$ 

3,600 

37%  $  3,628 

37%  $  3,752 

35%  $  4,560 

34%  $  4,231 

1,236 

1,079 

330 

6,245 

692 

247 

2,252 

459 

561 

4,211 

13 

2 

2 

54 

30 

3 

4 

5 

4 

1,282 

1,200 

307 

6,417 

750 

431 

2,064 

475 

570 

13 

2 

2 

54 

30 

3 

4 

5 

4 

46 

4,290 

46 

1,374 

1,238 

268 

6,632 

1,085 

608 

1,944 

1,039 

652 

5,328 

13 

3 

2 

53 

30 

4 

4 

5 

4 

1,320 

1,294 

220 

7,394 

1,270 

815 

1,605 

817 

639 

14 

2 

2 

52 

29 

5 

4 

6 

4 

1,264 

1,210 

167 

6,872 

1,895 

1,223 

1,412 

529 

581 

33% 

13 

3 

1 

50 

30 

6 

4 

6 

4 

$  10,456 

100%  $  10,707 

100%  $  11,960 

100%  $  12,540 

100%  $  12,512 

100% 

Dec 31, 2019 

Dec 31, 2018 

Dec 31, 2017 

Dec 31, 2016 

Dec 31, 2015 

47 

5,146 

48 

5,640 

50 

$ 

$ 

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 

9,551 

905 

10,456 

0.99% 

346 

1.09 

196 

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 

In addition to the allowance for credit losses, there was 

$387 million at December 31, 2019, and $480 million at 
December 31, 2018, of nonaccretable difference to absorb 
losses on PCI loans of $568 million at December 31, 2019, and 
$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. 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 $251 million, or 

2%, in 2019, due to improvement in the credit quality of our 
commercial and residential real estate portfolios, partially offset 
by an increase in the allowance for the credit card portfolio 
reflecting increased volume and a shift in portfolio mix. Total 

provision for credit losses was $2.7 billion in 2019 and 
$1.7 billion in 2018. The provision for credit losses was 
$75 million less than net charge-offs in 2019, reflecting the 
same changes mentioned above for the allowance for credit 
losses, compared with $1.0 billion less than net charge-offs in 
2018. For a discussion of our 2018 provision for credit losses 
compared with 2017, see the “Risk Management – Credit Risk 
Management – Allowance for Credit Losses” section of our 
Annual Report on Form 10-K for the year ended December 31, 
2018. 

We believe the allowance for credit losses of $10.5 billion at 

December 31, 2019, was appropriate to cover credit losses 
inherent in the loan portfolio, including unfunded credit 
commitments, at that date. The entire allowance for credit losses 
is available to absorb credit losses inherent in the total loan 
portfolio. The allowance for credit losses is subject to change and 
reflects 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 
amounts of the allowance for credit losses will be based on a 
variety of factors, including loan growth, portfolio performance 

Wells Fargo & Company 

77 

  
Risk Management – Credit Risk Management (continued) 

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. 

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 Securities and Exchange 
Commission (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 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 

78 

Wells Fargo & Company 

  
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, 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 Committee (Corporate ALCO), which 
consists of management from finance, risk and business groups, 
to oversee these risks and provide periodic reports 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 
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. 

• 

• 

• 

• 

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. 

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 

$ 

(1.8) - (1.3) 

1.5 - 2.0 

1.1 - 1.6 

($ in billions) 

Base 

First Year of 

Forecasting
Horizon 

Net Interest Income 

Sensitivity to Base 
Scenario 

Key Rates at Horizon 

End 

Fed Funds Target 

1.87  % 

10-year CMT (1) 

1.97 

0.87 

0.97 

2.87 

2.97 

3.87 

3.97 

Second Year of 
Forecasting
Horizon 

Net Interest Income 

Sensitivity to Base 
Scenario 

Key Rates at Horizon 

End 

$ 

(4.4) - (3.9) 

2.0 - 2.5 

2.7 - 3.2 

We assess interest rate risk by comparing outcomes under 

10-year CMT (1) 

2.36 

Fed Funds Target 

2.25  % 

1.25 

1.36 

3.25 

3.36 

4.25 

4.36 

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 

(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 banking activities, and may move in the 
opposite direction of our net interest income. Mortgage 
originations generally decline in response to higher interest rates 
and generally increase, particularly refinancing activity, in 
response to lower interest rates. 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 

Wells Fargo & Company 

79 

  
Risk Management – Asset/Liability Management (continued) 

reduce treasury management deposit service fees. Additionally, 
for the trading portfolio, our trading assets are (before the 
effects of certain economic hedges) generally less sensitive to 
changes in interest rates than the related funding liabilities. As a 
result, net interest income from the trading portfolio contracts 
and expands as interest rates rise and fall, respectively. The 
impact to net interest income does not include the fair value 
changes of trading securities and loans, which, along with the 
effects of related 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, 2019, and December 31, 2018, are presented in 
Note 18 (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 
2017, 2018, and 2019, 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 and 2019 to MLHFS in support of future 
issuances of private label residential mortgage backed securities 
(RMBS). We issued $2.4 billion and $441 million of RMBS in 2019 
and 2018, respectively. 

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 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, costs to service, the value of escrow balances and other 
servicing valuation elements. For key economic assumptions and 
the sensitivity of the fair value of MSRs, see Table 10.6 in 
Note 10 (Securitizations and Variable Interest Entities) to 
Financial Statements in this Report. 

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 

80 

Wells Fargo & Company 

 
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 2019, our economic hedging strategy 
primarily 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. Hedge results may also be impacted as the 
overall level of hedges changes as interest rates change, or 
as there are other changes in the market for mortgage 
forwards that may affect the implied carry on the MSRs. For 
example, the hedge-carry income on our economic hedges 
for the MSRs did not continue at levels consistent with 2018 
as the flat to inverted yield curve resulted in negative hedge 
carry in 2019. 

The total carrying value of our residential and commercial 

MSRs was $12.9 billion and $16.1 billion at December 31, 2019 
and 2018, respectively. The weighted-average note rate on our 
portfolio of loans serviced for others was 4.25% and 4.32% at 
December 31, 2019 and 2018, respectively. The carrying value of 
our total MSRs represented 0.79% and 0.94% of mortgage loans 
serviced for others at December 31, 2019 and 2018, 
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 

Wells Fargo & Company 

81 

Risk Management – Asset/Liability Management (continued) 

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 exposure. This applies to implied volatility risk, 
basis risk, and market liquidity risk. It also includes price risk in 
the trading book, mortgage servicing rights and the 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 IRM, has primary 
oversight responsibility for market risk. The Market and 
Counterparty Risk Management function reports into the CRO 
and also provides periodic reports related to market risk to the 
Board’s Finance 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 risk 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. 

82 

Wells Fargo & Company 

 Table 38 shows the Company’s Trading General VaR by risk 

category. Our Trading General VaR uses a historical simulation 
model which assumes that historical changes in market values 
are representative of the potential future outcomes and 
measures the expected earnings loss of the Company over a       
1-day time interval at a 99% confidence level. Our historical 
simulation model is based on equally weighted data from a       
12-month historical look-back period. We believe using a          
12-month look-back period helps ensure the Company’s VaR is 

responsive to current market conditions. The 99% confidence 
level equates to an expectation that the Company would incur 
single-day trading losses in excess of the VaR estimate on 
average once every 100 trading days. 

Average Company Trading General VaR was $22 million for 
the year ended December 31, 2019, compared with $15 million 
for the year ended December 31, 2018. The increase in average 
Company Trading General VaR for the year ended December 31, 
2019, was mainly driven by changes in portfolio composition. 

Table 38:  Trading 1-Day 99% General VaR by Risk Category 

(in millions) 

Company Trading General VaR Risk Categories 

Credit 

Interest rate 

Equity 

Commodity 

Foreign exchange 

Diversification benefit (1) 

December 31, 2019 

Year ended 

December 31, 2018 

Period 
end 

Average 

Low 

High 

Period 
end 

Average 

Low 

High 

$

15 

14

5 

2

1

17 

27 

5 

2

1

11 

9

4

1

1

(13) 

(30) 

30 

49 

11 

6 

1 

10 

6

2

1

0

55 

52 

16 

4 

3 

18 

28

5 

2

1

(33) 

21 

16 

17 

8 

1

1

(28) 

15 

Company Trading General VaR 

$ 

24 

22 

(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 and observable price changes. 
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, capital needs, the 
viability of its business model, our exit strategy, and observable 
price changes that are similar to the investments held. 
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 

Wells Fargo & Company 

83 

 
  
Risk Management – Asset/Liability Management (continued) 

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 17 (Legal Actions) to Financial Statements in this Report. 
As part of our business to support our customers, we trade 

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 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. 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  We are subject to a rule, issued by the FRB, 
OCC and FDIC, that includes 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 (IDIs) with total assets 
greater than $10 billion. In addition, rules issued by the FRB 

Table 40:  Primary Sources of Liquidity 

impose enhanced liquidity management standards on large bank 
holding companies (BHC) such as Wells Fargo. 

The FRB, OCC and FDIC have proposed a rule that would 
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, 2019, 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 

(1) 
(2) 

Excludes excess HQLA at Wells Fargo Bank, N.A. 
Net of applicable haircuts required under the LCR rule. 

Average for Quarter ended 
December 31, 2019 

$  373,362 

312,019 

120% 

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 IDIs 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. 

(in millions) 

Total 

Encumbered 

Unencumbered 

Total 

Encumbered 

Unencumbered 

Interest-earning deposits with banks 

Debt securities of U.S. Treasury and federal agencies 

Mortgage-backed securities of federal agencies (1) 

Total 

$ 

119,493 

61,099 

258,589 

$ 

439,181 

— 

3,107 

41,135 

44,242 

119,493 

149,736 

57,992 

57,688 

217,454 

244,211 

394,939 

451,635 

— 

1,504 

35,656 

37,160 

149,736 

56,184 

208,555 

414,475 

(1) 

Included in encumbered securities at December 31, 2019, were securities with a fair value of $263 million which were purchased in December 2019, but settled in January 2020. 

December 31, 2019 

December 31, 2018 

84 

Wells Fargo & Company 

 
  
  
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 137% of total loans at 
December 31, 2019, and 135% at December 31, 2018. 

Additional funding is provided by long-term debt and short-
term borrowings. Table 41 shows selected information for short-
term borrowings, which generally mature in less than 30 days. 
For additional information, see Note 14 (Short-Term Borrowings) 
to Financial Statements in this Report. 

Table 41:  Short-Term Borrowings 

(in millions) 

Balance, period end 

Federal funds purchased and securities sold under agreements to repurchase 

Other short-term borrowings 

Total 

Average daily balance for period 

Federal funds purchased and securities sold under agreements to repurchase 

Other short-term borrowings 

Total 

Maximum month-end balance for period 

Dec 31, 
2019 

Sep 30, 
2019 

Jun 30, 
2019 

Mar 31, 
2019 

Dec 31, 
2018 

Quarter ended 

$ 

92,403 

12,109 

$ 

104,512 

$ 

103,614 

12,335 

$ 

115,949 

110,399 

13,509 

123,908 

109,499 

12,343 

121,842 

102,560 

12,784 

115,344 

102,557 

12,197 

114,754 

93,896 

12,701 

92,430 

13,357 

106,597 

105,787 

95,721 

12,930 

93,483 

12,479 

108,651 

105,962 

Federal funds purchased and securities sold under agreements to repurchase (1) 

Other short-term borrowings (2) 

$ 

111,727 

12,708 

110,399 

13,509 

105,098 

12,784 

97,650 

14,129 

93,918 

13,357 

(1) 
(2) 

Highest month-end balance in each of the last five quarters was in October, September, May and January 2019, and November 2018. 
Highest month-end balance in each of the last five quarters was in October, September, June, and February 2019, and December 2018. 

Long-Term Debt  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. We issue long-
term debt in a variety of maturities and currencies to achieve 
cost-efficient funding and to maintain an appropriate maturity 
profile. 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. We issued $53.4 billion of long-term debt in 
2019 and $9.7 billion in January and February of 2020. For 
additional information, see Note 15 (Long-Term Debt) to 
Financial Statements in this Report. 

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, 

Table 42:  Credit Ratings as of December 31, 2019 

Moody’s 

S&P Global Ratings 

Fitch Ratings, Inc. 

DBRS Morningstar 

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. 

On October 21, 2019, DBRS Morningstar confirmed the 

Company’s ratings and maintained the stable trend for all 
ratings. On December 16, 2019, Fitch Ratings, Inc., affirmed the 
Company’s ratings and maintained the stable outlook for all 
ratings. Both the Parent and Wells Fargo Bank, N.A., remain 
among the highest-rated financial firms in the United States. 

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 18 (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, 2019, 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) 

Wells Fargo & Company 

85 

  
  
 
coordinate an enterprise-wide process for managing outreach 
and communications with our customers, and (x) implement a 
process to escalate key risks. When assessing risks associated 
with the transition away from IBORs, the LTO is reviewing both 
orderly and disorderly transition scenarios. 

In an effort to mitigate the risks associated with a transition 
away from IBORs, the LTO is in the process of implementing the 
following initiatives: (i) compiling an enterprise contract 
inventory of IBOR-related terms, (ii) implementing more robust 
fallback language and disclosures related to LIBOR transition, (iii) 
developing a plan to amend legacy contracts to reference 
alternative reference rates, (iv) enhancing systems to support 
new fallback language and new products linked to alternative 
reference rates, (v) preparing internal and external 
communications regarding an IBOR transition, (vi) developing 
internal guidance focused on issues related to IBORs and 
alternative reference rate products, and (vii) evaluating policies 
and procedures in light of the transition away from LIBOR and 
other IBORs and the introduction of new products linked to 
alternative reference rates. 

In addition, the Company is actively working with regulators, 

industry working groups (such as the ARRC) and trade 
associations that are developing guidance to facilitate an orderly 
transition away from the use of LIBOR. We continue to assess 
the risks and related impacts associated with a transition away 
from IBORs. 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. 
Although the Company did not issue any long-term debt 
with an interest rate indexed to the Secured Overnight Financing 
Rate (SOFR) in 2019, we did issue $1.0 billion of long-term debt 
indexed to SOFR in 2018. SOFR is published by the Federal 
Reserve Bank of New York as an alternative to U.S. dollar LIBOR 
and is a broad measure of the cost of borrowing cash overnight 
collateralized by U.S. Treasury securities. 

Risk Management – Asset/Liability Management (continued) 

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. 

LIBOR TRANSITION Due to uncertainty surrounding the suitability 
and sustainability of the London Interbank Offered Rate (LIBOR), 
central banks and global regulators have called for financial 
market participants to prepare for the discontinuation of LIBOR 
by the end of 2021. LIBOR is a widely-referenced benchmark 
rate, which is published in five currencies and a range of tenors, 
and seeks to estimate the cost at which banks can borrow on an 
unsecured basis from other banks. We have a significant number 
of assets and liabilities referenced to LIBOR and other interbank 
offered rates (IBORs) such as commercial loans, adjustable-rate 
mortgage loans, derivatives, debt securities, and long-term debt. 
As of December 31, 2019, we had over $500 billion of assets, 
consisting mostly of commercial loans, over $80 billion of 
liabilities, and over $400 billion of off-balance sheet 
commitments linked to IBORs. These amounts exclude derivative 
assets and liabilities on our consolidated balance sheet. As of 
December 31, 2019, the notional amount of our IBOR-linked 
interest rate derivative contracts was over $10 trillion, of which 
over $8 trillion related to contracts with central counterparty 
clearinghouses. Each of the IBOR-linked amounts referenced 
above will vary in future periods as current contracts expire with 
potential replacement contracts using either IBOR or an 
alternative reference rate. As of December 31, 2019, U.S. dollar 
LIBOR represented substantially all of the IBOR-linked amounts 
referenced above; however, we had exposure to all primary 
IBORs. 

Accordingly, we established a LIBOR Transition Office (LTO) 
in February 2018, with senior management and Board oversight. 
The LTO is responsible for developing a coordinated strategy to 
transition the IBOR-linked contracts and processes across Wells 
Fargo to alternative reference rates and serves as primary 
conduit between Wells Fargo and relevant industry groups, such 
as the Alternative Reference Rates Committee (ARRC). Among 
other activities, the program structure created by the LTO is 
designed to (i) identify the types of exposures (e.g., products, 
systems, models) and risks associated with the transition, (ii) 
assess the provisions in our contracts that could apply in 
connection with the transition, (iii) incorporate more robust 
IBOR fallback language (contractual provisions that provide for 
transition to alternative reference rates upon defined trigger 
events) into new IBOR-linked product contracts, (iv) coordinate 
alternative reference rate product design, (v) appraise 
operational and infrastructure enhancements necessary to use 
alternative reference rates, (vi) facilitate systems and application 
revisions, including model development and validation, (vii) 
assess the funding issues, basis risk, and other finance, 
accounting, and tax impacts of transitioning away from IBORs, 
(viii) develop plans to minimize negative financial outcomes, (ix) 

86 

Wells Fargo & Company 

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 
$8.5 billion from December 31, 2018, predominantly from 
Wells Fargo net income of $19.5 billion, less common and 
preferred stock dividends of $9.9 billion. During 2019, we issued 
48.8 million shares of common stock, excluding conversions of 
preferred shares. During 2019, we repurchased 502.4 million 
shares of common stock at a cost of $24.5 billion. The amount of 
our repurchases are subject to various factors as discussed in the 
“Securities Repurchases” section below. For additional 
information about share repurchases, see Note 1 (Summary of 
Significant Accounting Policies) to Financial Statements in this 
Report. 

In third quarter 2019, we redeemed $1.6 billion of our 
Preferred Stock, Series K. In January 2020, we issued $2.0 billion 
of our Preferred Stock, Series Z. In February 2020, we announced 
a redemption of the remaining outstanding shares of our 
Preferred Stock, Series K, and a partial redemption of our 
Preferred Stock, Series T. For more information, see Note 20 
(Preferred Stock) to Financial Statements in this Report. 

Regulatory Capital Guidelines 
The Company and each of our IDIs 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 rules issued by federal banking regulators to 
implement Basel III capital requirements for U.S. banking 
organizations. 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 9.00%, 
comprised of a 4.50% minimum requirement plus a capital 
conservation buffer of 2.50% and for us, as a global 
systemically important bank (G-SIB), a capital surcharge of 
2.00%; 
a minimum tier 1 capital ratio of 10.50%, comprised of a 
6.00% minimum requirement plus the capital conservation 
buffer of 2.50% and the G-SIB capital surcharge of 2.00%; 
a minimum total capital ratio of 12.50%, comprised of a 
8.00% minimum requirement plus the capital conservation 
buffer of 2.50% and the G-SIB capital surcharge of 2.00%; 
a potential countercyclical buffer of up to 2.50% to be 
added to the minimum capital ratios, which 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; and 
a minimum tier 1 leverage ratio of 4.00%. 

• 

• 

• 

• 

The Basel III capital requirements for calculating CET1 and 
tier 1 capital, along with risk-weighted assets (RWAs), are fully 
phased-in. However, the requirements for determining tier 2 
and total capital are still in accordance with Transition 
Requirements and 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 
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 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 2.50% capital 
conservation buffer under the Standardized Approach, 
whereas the stress leverage buffer would be added to the 
current 4.00% minimum tier 1 leverage ratio. 

As a G-SIB, we are also subject to the FRB’s rule 
implementing the additional capital surcharge of between 
1.00-4.50% on the minimum capital requirements of 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. Because the G-SIB 
capital surcharge is calculated annually based on data that can 
differ over time, the amount of the surcharge is subject to 
change in future years. 

The tables that follow provide information about our risk-

based capital and related ratios as calculated under Basel III 
capital guidelines. Although we continue to report certain capital 
amounts and ratios in accordance with Transition Requirements 
for banking industry regulatory reporting purposes, we are 
managing our capital on a fully phased-in basis. For information 
about our capital requirements calculated in accordance with 
Transition Requirements, see Note 29 (Regulatory and Agency 
Capital Requirements) to Financial Statements in this Report. 

Wells Fargo & Company 

87 

 
Capital Management (continued) 

Table 43 summarizes our CET1, tier 1 capital, total capital, 

RWAs and capital ratios on a fully phased-in basis at 
December 31, 2019 and 2018. 

Table 43:  Capital Components and Ratios (Fully Phased-In) (1) 

(in millions, except ratios) 

Common Equity Tier 1 

Tier 1 Capital 

Total Capital (2) 

Risk-Weighted Assets 

Common Equity Tier 1 Capital Ratio 

Tier 1 Capital Ratio 

Total Capital Ratio (2) 

December 31, 2019 

December 31, 2018 

Required 
Minimum 
Capital Ratios 

Advanced 
Approach 

Standardized 
Approach 

Advanced 
Approach 

Standardized 
Approach 

$ 

138,760 

158,949 

187,813 

138,760 

158,949 

195,703 

146,363 

167,866 

198,103 

146,363 

167,866 

206,346 

1,230,066 

1,245,853 

1,177,350 

1,247,210 

9.00% 

10.50 

12.50 

11.28 

12.92 

15.27  * 

11.14  * 

12.76  * 

15.71 

12.43 

14.26 

16.83 

11.74  * 

13.46  * 

16.54  * 

(A) 

(B) 

(C) 

(D) 

(A)/(D) 

(B)/(D) 

(C)/(D) 

* 
(1) 
(2) 

Denotes the lowest capital ratio as determined under the Advanced and Standardized Approaches. 
See Table 44 for information regarding the calculation and components of CET1, tier 1 capital, total capital and RWAs. 
The 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 our fully phased-in total capital amounts, including a corresponding reconciliation 
to GAAP financial measures. 

88 

Wells Fargo & Company 

  
 
Table 44 provides information regarding the calculation and 

composition of our risk-based capital under the Advanced and 
Standardized Approaches at December 31, 2019 and 
December 31, 2018. 

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) 

Goodwill and other intangibles on nonmarketable equity securities (included in other assets) 
Applicable deferred taxes related to goodwill and other intangible assets (1) 

Other 

Common Equity Tier 1 

Common Equity Tier 1 

Preferred stock 

Additional paid-in capital on ESOP preferred stock 

Unearned ESOP shares 

Other 

Total Tier 1 capital 

Long-term debt and other instruments qualifying as Tier 2 

Qualifying allowance for credit losses (2) 

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) (3)(4): 

Credit risk 

Market risk 

Operational risk 

Total RWAs 

December 31, 2019 

December 31, 2018 

Advanced 
Approach 

Standardized 
Approach 

$ 

187,984 

187,984 

Advanced 
Approach 

197,066 

Standardized 
Approach 

197,066 

(21,549) 

(71) 
1,143 

(838) 
166,669 

(26,390) 
(437) 

(2,146) 
810 

254 
138,760 

138,760 

21,549 

71 

(1,143) 

(288) 

158,949 

26,515 

2,566 

(217) 

28,864 

520 

29,384 

187,813 

520 

188,333 

790,784 

35,644 

403,638 

(21,549) 

(71) 
1,143 

(838) 
166,669 

(26,390) 
(437) 

(2,146) 
810 

254 
138,760 

138,760 

21,549 

71 

(1,143) 

(288) 

158,949 

26,515 

10,456 

(217) 

36,754 

520 
37,274 

195,703 

520 

196,223 

1,210,209 

35,644 

— 

(23,214) 

(95) 
1,502 

(900) 
174,359 

(26,418) 
(559) 

(2,187) 
785 

383 
146,363 

146,363 

23,214 

95 

(1,502) 

(304) 

167,866 

27,946 

2,463 

(172) 

30,237 

695 
30,932 

198,103 

695 

198,798 

803,273 

45,964 

328,113 

(23,214) 

(95) 
1,502 

(900) 
174,359 

(26,418) 
(559) 

(2,187) 
785 

383 

146,363 

146,363 

23,214 

95 

(1,502) 

(304) 

167,866 

27,946 

10,706 

(172) 

38,480 

695 
39,175 

206,346 

695 

207,041 

1,201,246 

45,964 

— 

1,230,066 

1,245,853 

1,177,350 

1,247,210 

(A) 

(B) 

(A)+(B) 

$ 

$ 

$ 

$ 

$ 

$ 

(1) 

(2) 

(3) 

(4) 

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. 
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 0.60% 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. 
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. 
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. 

Wells Fargo & Company 

89 

  
 
Capital Management (continued) 

Table 45 presents the changes in Common Equity Tier 1 
under the Advanced Approach for the year ended December 31, 
2019. 

Table 45:  Analysis of Changes in Common Equity Tier 1 (Advanced Approach) 

(in millions) 

Common Equity Tier 1 at December 31, 2018 

Net income applicable to common stock 

Common stock dividends 

Common stock issued, repurchased, and stock compensation-related items 

Changes in cumulative other comprehensive income 

Cumulative effect from change in accounting policies (1) 

Goodwill 

Certain identifiable intangible assets (other than MSRs) 

Goodwill and other intangibles on nonmarketable equity securities (included in other assets) 

Applicable deferred taxes related to goodwill and other intangible assets (2) 

Other 

Change in Common Equity Tier 1 

Common Equity Tier 1 at December 31, 2019 

$ 

146,363 

17,938 

(8,444) 

(21,719) 

4,544 

(11) 

27 

122 

41 

26 

(127) 

(7,603) 

$ 

138,760 

(1) 

(2) 

Effective January 1, 2019, we adopted Accounting Standards Update (ASU) 2016-02 – Leases (Topic 842) and subsequent related Updates, ASU 2017-08 – Receivables – Nonrefundable Fees and 
Other Costs (Subtopic 310-20): Premium Amortization on Purchased Callable Debt Securities. See Note 1 (Summary of Significant Accounting Policies) for more information. 
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, 2019. 

Table 46:  Analysis of Changes in RWAs 

(in millions) 

RWAs at December 31, 2018 

Net change in credit risk RWAs 

Net change in market risk RWAs 

Net change in operational risk RWAs 

Total change in RWAs 

RWAs at December 31, 2019 

Advanced Approach 

Standardized Approach 

1,177,350 

1,247,210 

(12,489) 

(10,320) 

75,525 

52,716 

8,963 

(10,320) 

— 

(1,357) 

1,230,066 

1,245,853 

$ 

$ 

90 

Wells Fargo & Company 

  
 
  
 
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, 
goodwill, certain identifiable intangible assets (other than MSRs) 
and goodwill and other intangibles on nonmarketable equity 
securities, 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; and 
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, 
2019 

Dec 31, 
2018 

Dec 31, 
2017 

Dec 31, 
2019 

Dec 31, 
2018 

Dec 31, 
2017 

$  187,984 

197,066 

208,079 

197,621 

203,356 

205,654 

(21,549) 

(23,214) 

(25,358) 

(22,522) 

(24,956) 

(25,592) 

(71) 

1,143 

(838) 

(95) 

1,502 

(900) 

(122) 

1,678 

(1,143) 

(81) 

1,306 

(962) 

(125) 

2,159 

(929) 

(139) 

2,143 

(948) 

Total common stockholders’ equity 

(A) 

166,669 

174,359 

183,134 

175,362 

179,505 

181,118 

Adjustments: 

Goodwill 

(26,390) 

(26,418) 

(26,587) 

(26,409) 

(26,453) 

(26,629) 

Certain identifiable intangible assets (other than MSRs) 

(437) 

(559) 

(1,624) 

(493) 

(1,088) 

(2,176) 

Goodwill and other intangibles on nonmarketable equity 

securities (included in other assets) 

Applicable deferred taxes related to goodwill and other 

intangible assets (1) 

Tangible common equity 

Common shares outstanding 

Net income applicable to common stock 

Book value per common share 

Tangible book value per common share 

Return on average common stockholders’ equity (ROE) 

Return on average tangible common equity (ROTCE) 

(2,146) 

(2,187) 

(2,155) 

(2,174) 

(2,197) 

(2,184) 

810 

785 

962 

792 

866 

1,570 

(B) 

(C) 

(D) 

(A)/(C) 

(B)/(C) 

(D)/(A) 

(D)/(B) 

$  138,506 

145,980 

153,730 

147,078 

150,633 

151,699 

4,134.4 

4,581.3 

4,891.6 

N/A 

N/A 

N/A 

$ 

N/A 

40.31 

33.50 

N/A 

N/A 

N/A 

38.06 

31.86 

N/A 

N/A 

N/A 

37.44 

31.43 

N/A 

N/A 

$ 

17,938 

20,689 

20,554 

N/A 

N/A 

10.23% 

12.20 

N/A 

N/A 

11.53 

13.73 

N/A 

N/A 

11.35 

13.55 

(1) 

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. 

Wells Fargo & Company 

91 

  
 
Capital Management (continued) 

SUPPLEMENTARY LEVERAGE RATIO  As a BHC, we are required to 
maintain a supplementary leverage ratio (SLR) of at least 5.00% 
(comprised of a 3.00% minimum requirement plus a 
supplementary leverage buffer of 2.00%) to avoid restrictions on 
capital distributions and discretionary bonus payments. Our IDIs 
are required to maintain a SLR of at least 6.00% to be considered 
well-capitalized under applicable regulatory capital adequacy 
guidelines. In April 2018, the FRB and OCC proposed rules (the 
“Proposed SLR Rules”) that would replace the 2.00% 
supplementary leverage buffer with a buffer equal to one-half of 
our G-SIB capital surcharge. The Proposed SLR Rules would 
similarly tailor the current 6.00% SLR requirement for our IDIs. At 
December 31, 2019, our SLR for the Company was 7.07%, and 
we also exceeded the applicable SLR requirements for each of 
our IDIs. 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: Goodwill and other permitted Tier 1 capital 
deductions (net of deferred tax liabilities) 

Total adjusted average assets 

Plus adjustments for off-balance sheet exposures: 

Derivatives (1) 

Repo-style transactions (2) 

Other (3) 

Total off-balance sheet exposures 

Quarter ended 
December 31, 2019 

(A) 

$ 

158,949 

1,941,843 

28,546 

1,913,297 

67,645 

5,162 

261,625 

334,432 

Total leverage exposure 

(B) 

$ 

2,247,729 

Supplementary leverage ratio 

(A)/(B) 

7.07% 

(1) 

(2) 

(3) 

Adjustment represents derivatives and collateral netting exposures as defined for 
supplementary leverage ratio determination purposes. 
Adjustment represents counterparty credit risk for repo-style transactions where Wells 
Fargo & Company is the principal (i.e., principal counterparty facing the client). 
Adjustment represents credit equivalent amounts of other off-balance sheet exposures 
not already included as derivatives and repo-style transactions exposures. 

OTHER REGULATORY CAPITAL MATTERS As a G-SIB, we are 
required to have a minimum amount of equity and unsecured 
long-term debt for purposes of resolvability and resiliency, often 
referred to as Total Loss Absorbing Capacity (TLAC). 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) 18.00% of RWAs and (ii) 7.50% 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 2.50% of RWAs plus our applicable G-SIB capital 
surcharge calculated under method one plus any applicable 
countercyclical buffer to be added to the 18.00% minimum and 
(ii) an external TLAC leverage buffer equal to 2.00% of total 
leverage exposure to be added to the 7.50% minimum, in order 
to avoid restrictions on capital distributions and discretionary 
bonus payments. U.S. G-SIBs are also required to have a 
minimum amount of eligible unsecured long-term debt equal to 
the greater of (i) 6.00% of RWAs plus our applicable G-SIB capital 
surcharge calculated under method two and (ii) 4.50% of the 
total leverage exposure. Under the Proposed SLR Rules, the 
2.00% external TLAC leverage buffer would be replaced with a 
buffer equal to one-half of our applicable G-SIB capital 
surcharge, and the leverage component for calculating the 
minimum amount of eligible unsecured long-term debt would be 

modified from 4.50% of total leverage exposure to 2.50% of total 
leverage exposure plus one-half of our applicable G-SIB capital 
surcharge. As of December 31, 2019, our eligible external TLAC 
as a percentage of total risk-weighted assets was 23.28% 
compared with a required minimum of 22.00%. 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 capital 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 
10.00%, which includes a 2.00% G-SIB capital 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 the “Capital Management – 
Regulatory Capital Guidelines – Risk-Based Capital and Risk-
Weighted Assets” section of this Report, the FRB has proposed 
including a stress capital buffer to replace the current 2.50% 
capital conservation buffer. Under the proposal, it is expected 
that the adoption of current expected credit loss (CECL) 
accounting would be included in the calculation of the stress 
capital buffer. We expect that implementation of the stress 
capital buffer may increase the level and volatility of minimum 
capital ratio requirements, which may cause our current long-
term CET1 capital ratio target of 10.00% 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, among other things, 
the overall financial condition, risk profile, and capital adequacy 
of BHCs when evaluating capital plans. 

Our 2019 capital plan, which was submitted on April 4, 2019, 

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 2019 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, 2019. On June 27, 2019, the FRB notified us that 
it did not object to our capital plan included in the 2019 CCAR. 

92 

Wells Fargo & Company 

  
 
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. Under the FRB’s stress testing rule, we were required to 
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 2019. In October 2019, the FRB 
finalized rules that 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 

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 2019 Form 10-K, and the “Capital 
Management,” “Forward-Looking Statements” and “Risk 
Factors” sections and Note 29 (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 following provides additional 
information on the Dodd-Frank Act, including 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 

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 share repurchases occur at various price levels. We may 
suspend share repurchase activity at any time. 

In October 2018, the Board authorized the repurchase of 
350 million shares of our common stock. In July 2019, the Board 
authorized the repurchase of an additional 350 million shares of 
our common stock. At December 31, 2019, we had remaining 
authority to repurchase approximately 243 million shares, 
subject to regulatory and legal conditions. For more information 
about share repurchases during fourth quarter 2019, see Part II, 
Item 5 in our 2019 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. 

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 

• 

Wells Fargo & Company 

93 

Regulatory Matters (continued) 

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 became 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 certain 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) jointly 
released a final rule to implement the Volcker Rule’s 
restrictions, and have adopted amendments to the rule to 
streamline and tailor the requirements for compliance. 
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 has 
implemented parallel rules applicable to security-based 
swaps, and is expected to implement additional related 
rules. 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 
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).  The FRB has enacted a rule to implement the 
Durbin Amendment to the Dodd-Frank Act, which limits 

debit card interchange transaction fees to those reasonable 
and proportional to the cost of the transaction. 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. 

Regulatory Capital Guidelines and Capital Plans 
The Company and each of our insured depository institutions are 
subject to various regulatory capital adequacy requirements 
administered by the FRB and the OCC. For example, the 
Company is subject to rules issued by federal banking regulators 
to implement Basel III capital requirements for U.S. banking 
organizations. The Company and its insured depository 
institutions are also required to maintain specified 
supplementary leverage ratios. Federal banking regulators have 
also issued a final rule regarding the U.S. implementation of 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” 
and “Risk Management – Asset/Liability Management – Liquidity 
and Funding – Liquidity Standards” sections 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 submit resolution plans, also known as 
“living wills,” that would facilitate their rapid and orderly 
resolution in the event of material financial distress or failure. 
Under the rules, rapid and orderly resolution means a 
reorganization or liquidation of the covered company under the 
U.S. Bankruptcy Code that can be accomplished in a reasonable 
period of time and in a manner that substantially mitigates the 
risk that failure would have serious adverse effects on the 
financial stability of the United States. In addition to the 
Company’s resolution plan, our national bank subsidiary, Wells 
Fargo Bank, N.A. (the “Bank”), is also required to prepare and 
periodically submit a resolution plan. If the FRB and/or FDIC 
determine 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 and/or FDIC 
ultimately determine that we have been unable to remedy any 
deficiencies, they could require us to divest certain assets or 
operations. On June 27, 2019, we submitted our resolution plan 
to the FRB and FDIC. On December 17, 2019, the FRB and FDIC 
announced that the Company’s 2019 resolution plan did not 
have any deficiencies, but they identified a specific shortcoming 
that would need to be addressed. 

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 

Wells Fargo & Company 

• 

• 

• 

94 

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. 

 The strategy described in our most recent resolution plan is 

a single point of entry strategy, in which the Parent would likely 
be the only material legal entity to enter resolution proceedings. 
However, we are not obligated to maintain a single point of entry 
strategy, and the strategy described in our resolution plan is 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. 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. 

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, 
on June 28, 2017, the Parent entered into a support agreement, 
as amended and restated on June 26, 2019 (the “Support 
Agreement”), with WFC Holdings, LLC, an intermediate holding 
company and subsidiary of the Parent (the “IHC”), the Bank, 
Wells Fargo Securities, LLC (“WFS”), Wells Fargo Clearing 
Services, LLC (“WFCS”), and certain other direct and indirect 
subsidiaries of the Parent designated as material entities for 
resolution planning purposes (the “Covered Entities”) or 
identified as related support entities in our resolution plan (the 
“Related Support Entities”). 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, WFS, WFCS, and the Covered 
Entities pursuant to 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, 
or if the Parent’s board of directors authorizes it to file a case 
under the U.S. Bankruptcy Code, the subordinated notes would 
be forgiven, the committed line of credit would terminate, and 
the IHC’s ability to pay dividends to the Parent would be 
restricted, any of 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 respective obligations under the Support 
Agreement of the Parent, the IHC, the Bank, and the Related 
Support Entities are secured pursuant to a related security 
agreement. 

In addition to our resolution plans, 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 determines that our recovery plan is deficient, they may 
impose fines, restrictions on our business or ultimately require us 
to divest assets. 

Other Regulatory Related Matters 
• 

Broker-dealer standards of conduct.  In June 2019, the SEC 
finalized a rule that requires 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 impacts 
the manner in which business is conducted with customers 
seeking investment advice and may affect certain 
investment product offerings. 
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 
Company continues to engage with the FRB as the Company 
works to address the consent order provisions. The consent 
order also requires the Company, following the FRB’s 
acceptance and approval of the plans and the Company’s 

• 

• 

Wells Fargo & Company 

95 

Regulatory Matters (continued) 

adoption and implementation of the plans, to complete an 
initial third-party review of the enhancements and 
improvements provided for in the plans. Until this third-
party review is 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. 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 penalties to resolve matters 
regarding the Company’s compliance risk management 
program and past practices involving certain automobile 
collateral protection insurance policies and certain 

• 

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 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 increase or decrease the 
allowance for credit losses. While our methodology attributes 
portions of the allowance for credit losses to specific portfolio 

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. 
•  OCC approval of director and senior executive officer 

appointments and certain post-termination payments.  Under 
the April 2018 consent order with the OCC, Wells Fargo 
Bank, N.A., remains subject to requirements that were 
originally imposed in November 2016 to provide prior 
written notice to, and obtain non-objection from, the OCC 
with respect to changes in directors and senior executive 
officers, and remains subject to certain regulatory 
limitations on post-termination payments to certain 
individuals and employees. 

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. 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, including those 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 

96 

Wells Fargo & Company 

 
• 

• 

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. 

SENSITIVITY TO CHANGES  Table 49 demonstrates the impact of 
the sensitivity of our estimates on our allowance for credit 
losses. 

Table 49:  Allowance for Credit Losses Sensitivity Summary 

(in billions) 

Assumption: 

Favorable (1) 

Adverse (2) 

December 31, 2019 

Estimated 

increase/(decrease) 

in allowance 

$ 

(3.1) 

7.1 

(1) 

(2) 

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. 
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 acquired MSRs 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 in the cash flow 
estimates such as from servicing 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 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 10 (Securitizations and Variable Interest Entities), Note 11 
(Mortgage Banking Activities) and Note 19 (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 most of our residential MLHFS are carried at fair value each 
period. Other financial instruments, such as certain MLHFS, 
most nonmarketable equity securities and substantially all of 

Wells Fargo & Company 

97 

  
 
Critical Accounting Policies (continued) 

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 requirements 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 19 (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 active markets to 
measure fair value. If quoted prices in active markets are not 
available, fair value measurement is based upon models that 
generally use 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. 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 19 (Fair Value of Assets and 
Liabilities) to Financial Statements in this Report. 

When using internally-developed models based on 

unobservable inputs, 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. For 
example, we adjust the vendor or broker price using internal 
models based on discounted cash flows when the impact of 
illiquid markets has not already been incorporated in the fair 
value measurement. Additionally, for certain residential MLHFS 
and certain debt and equity 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. 
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. 

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 1 
(Summary of Significant Accounting Policies) 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 to estimate fair 
value. 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 each instrument’s fair value 
measurement in its entirety. If Level 3 inputs are considered 
significant, the instrument is classified as Level 3. 

Table 50 presents our (1) assets and liabilities recorded at 
fair value on a recurring basis and (2) Level 3 assets and liabilities 
recorded at fair value on a recurring basis, both presented as a 
percentage of our total assets and total liabilities. 

Table 50:  Fair Value Level 3 Summary 

December 31, 2019 

December 31, 2018 

($ in billions) 

Total 
balance 

Level 3 (1) 

Assets carried at fair value  $  428.6 

24.3 

Total 
balance 

408.4 

Level 3 (1) 

25.3 

As a percentage 
of total assets 

22% 

Liabilities carried at fair 

value 

$ 

26.5 

As a percentage of 
total liabilities 

2% 

* Less than 1%. 
(1) 

Before derivative netting adjustments. 

1 

1.8 

* 

22 

28.2 

2 

1 

1.6 

* 

See Note 19 (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, non-U.S. 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. 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. 

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 basis 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. 

We do not intend to distribute earnings of certain non-U.S. 

subsidiaries in a taxable manner, and therefore intend to limit 

98 

Wells Fargo & Company 

  
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 17 (Legal Actions) to Financial Statements in this 

Report for further information. 

distributions of non-U.S. 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 non-U.S. 
taxes. All other undistributed non-U.S. earnings will continue to 
be permanently reinvested outside the U.S. and the related tax 
liability on these earnings is insignificant. 

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 international. 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 
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 24 (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, 
governmental, arbitration and other proceedings or 
investigations concerning matters arising from the conduct of its 
business activities, and many of those proceedings and 
investigations expose the Company to potential financial loss. 
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. 

Wells Fargo & Company 

99 

Current Accounting Developments 

Table 51 provides the significant accounting updates applicable 
to us that have been issued by the Financial Accounting 
Standards Board (FASB) but are not yet effective. 

Table 51:  Current Accounting Developments – Issued Standards 

Description 

Effective date and financial statement impact 

ASU 2018-12 – Financial Services – Insurance (Topic 944): 
Targeted Improvements to the Accounting for Long-Duration Contracts and subsequent related updates 

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 guidance becomes effective on January 1, 2022. Certain of our variable annuity reinsurance products meet 
the definition of market risk benefits and will require the associated insurance related reserves for these 
products to be measured at fair value as of the earliest period presented, with the cumulative effect on fair 
value for changes attributable to our own credit risk 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. As of 
December 31, 2019, we held $1.1 billion in insurance-related reserves of which $489 million was in scope of 
the Update. A total of $429 million was associated with products that meet the definition of market risk 
benefits, and of this amount, $17 million was measured at fair value under current accounting standards. The 
market risk benefits are largely indexed to U.S. equity and fixed income markets. Upon adoption, we may incur 
periodic earnings volatility from changes in the fair value of market risk benefits generally due to the long 
duration of these contracts. We plan to economically hedge this volatility, where feasible. The ultimate impact 
of these changes will depend on the composition of our market risk benefits portfolio at the date of adoption. 
Changes in the accounting for the liability of future policy benefits for traditional long-duration contracts and 
deferred acquisition costs will be applied to all outstanding long-duration contracts on the basis of their 
existing carrying amounts at the beginning of the earliest period presented, and are not expected to be 
material. 

We adopted the guidance on January 1, 2020. Our implementation process included development of loss 
forecasting models, evaluation of technical accounting topics, updates to our allowance documentation, 
reporting processes, and related internal controls. 

Upon adoption, we recognized an overall decrease in our ACL of approximately $1.3 billion, as a 
cumulative effect adjustment from change in accounting policies. This adjustment, net of income tax 
adjustments, increased our retained earnings and regulatory capital amounts and ratios. For more information 
on the impact of CECL by type of financial asset, see Table 51b (ASU 2016-03 Adoption Impact to Allowance 
for Credit Losses (ACL)) in this Report. 

Our approach for estimating expected life-time credit losses for loans and debt securities includes the 

following key components: 
• 

ASU 2016-13 – Financial Instruments – Credit Losses (Topic 326): 
Measurement of Credit Losses on Financial Instruments and subsequent related updates 
The Update changes the accounting 
for the measurement of credit losses 
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 contractual term, 
adjusted for prepayments, 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 an insignificant 
deterioration of credit 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. 

• 

• 

• 

• 

An initial loss 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 term, adjusted for prepayments, by 
portfolio segment and class of financing receivables based on the change in key historical economic 
variables during representative historical expansionary and recessionary periods. 
A reversion period of up to two years connecting the initial loss forecast to the historical loss forecast 
based on economic conditions at the measurement date. 
Utilization of discounted cash flow (DCF) methods to measure credit impairment for loans modified in a 
troubled debt restructuring, unless they are collateral dependent and measured at the fair value of 
collateral. The DCF methods 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 
utilize the DCF methods to measure the ACL, which incorporate expected credit losses using the 
conceptual components described above. The ACL on available-for-sale debt securities is subject to a 
limitation based on the fair value of the debt securities. 

We expect future changes in our ACL to be more volatile under CECL. Future amounts of the ACL will be 
based on a variety of factors, including changes in loan volumes, portfolio credit quality, and general economic 
conditions. General economic conditions will be forecasted using economic variables, which will create 
volatility as those variables change over time. See Table 51a for key economic variables used for our loan 
portfolios. 

100 

Wells Fargo & Company 

  
 
Table 51a:  Key Economic Variables 

Loan Portfolio 

Total commercial 

Real estate 1-4 family mortgage 

Other consumer (including credit card, automobile, and other revolving credit and installment) 

Key economic variables 

Gross domestic product 
Commercial real estate asset prices, where applicable 

Home price index 
Unemployment rate 

Unemployment rate 

• 
• 

• 
• 

• 

Table 51b:  ASU 2016-13 Adoption Impact to Allowance for Credit Losses (ACL) (1) 

Balance 
Outstanding 

ACL Balance 

Coverage 

Dec 31, 2019 

ASU 2016-13 
Adoption
Impact 

Jan 1, 2020 

ACL Balance 

Coverage 

(in billions) 

Total commercial (2) 

$ 

Real estate 1-4 family mortgage (3) 

Credit card (4) 

Automobile (4) 

Other revolving credit and installment (4) 

Total consumer 

Total loans 

Available-for-sale and held-to-maturity debt securities 

and other assets (5) 

Total 

515.7 

323.4 

41.0 

47.9 

34.3 

446.5 

962.3 

420.0 

$ 

1,382.3 

6.2 

0.9 

2.3 

0.5 

0.6 

4.2 

10.5 

0.1 

10.6 

1.2%  $ 

(2.9) 

0.3 

5.5 

1.0 

1.6 

0.9 

1.1 

NM 

NM  $ 

— 

0.7 

0.3 

0.6 

1.5 

(1.3) 

— 

(1.3) 

3.4 

0.9 

2.9 

0.7 

1.2 

5.7 

9.1 

0.1 

9.3 

0.7% 

0.3 

7.1 

1.5 

3.5 

1.3 

0.9 

NM 

NM 

NM – Not meaningful 
(1) 
(2) 
(3) 

Amounts presented in this table may not equal the sum of its components due to rounding. 
Decrease reflecting shorter contractual maturities given limitation to contractual term. 
Impact reflects an increase due to longer contractual term, offset by expectation of recoveries in collateral value on mortgage loans previously written down significantly below current recovery 
value. 
Increase due to longer contractual term or indeterminate maturities. 
Excludes other financial assets in the scope of CECL that do not have an allowance for credit losses based on the nature of the asset. 

(4) 
(5) 

Other Accounting Developments 
The following Updates are applicable to us but are not expected 
to have a material impact on our consolidated financial 
statements: 
• 

ASU 2020-01 – Investments - Equity Securities (Topic 321), 
Investments – Equity Method and Joint Ventures (Topic 
323), and Derivatives and Hedging (Topic 815): Clarifying the 
Interactions between Topic 321, Topic 323, and Topic 815 (a 
consensus of the FASB Emerging Issues Task Force) 
ASU 2019-12 – Income Taxes (Topic 740): Simplifying the 
Accounting for Income Taxes 
ASU 2019-04 – Codification Improvements to Topic 326, 
Financial Instruments – Credit Losses, Topic 815, Derivatives 
and Hedging, and Topic 825, Financial Instruments. This 
Update includes guidance on recoveries of financial assets, 
which has been included in the discussion for ASU 2016-13 
above. 

° 

• 

• 

• 

• 

• 

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) 
ASU 2018-13 – Fair Value Measurement (Topic 820): 
Disclosure Framework – Changes to the Disclosure 
Requirements for Fair Value Measurement. We fully adopted 
this guidance in first quarter 2020. 
ASU 2017-04 – Intangibles – Goodwill and Other (Topic 
350): Simplifying the Test for Goodwill Impairment 

Wells Fargo & Company 

101 

  
 
  
 
 
Forward-Looking Statements 

This document contains forward-looking statements. 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 our allowance for 
credit losses; (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, our estimated Common Equity Tier 1 
ratio, and our estimated total loss absorbing capacity ratio; (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) 
expectations regarding our effective income tax rate; (xiii) the 
outcome of contingencies, such as legal proceedings; and (xiv) 
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 
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 
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 or in the level or composition of our 
assets or liabilities 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; 
negative effects from the retail banking sales practices 
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; 
changes to U.S. tax guidance and regulations, as well as the 
effect of discrete items on our effective income tax rate; 
our ability to develop and execute effective business plans 
and strategies; and 
the other risk factors and uncertainties described under 
“Risk Factors” in this Report. 

• 

• 

• 

• 

• 

• 

• 

• 

• 
• 

• 

• 

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 

102 

Wells Fargo & Company 

 
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. 

Any forward-looking statement made by us speaks only as 

of 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. 

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 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 corresponding retaliatory measures, and global 
economic difficulties, may impact the stability of financial 
markets and the global economy. In particular, Britain’s 
withdrawal from the European Union and the final terms of its 
exit following the existing transition period could increase 
economic barriers between 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, 

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. 

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 exit. 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 or 
with the same effectiveness following the end of the transition 
period for 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, 

Wells Fargo & Company 

103 

 
 
Risk Factors (continued) 

wealth management, and investment banking businesses. In 
2019, 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 2019, 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. Moreover, a negative interest rate environment, in 
which interest rates drop below zero, could reduce our net 
interest margin and net interest income due to a likely decline in 
the interest we could earn on loans and other earning assets, 
while also likely requiring us to pay to maintain our deposits with 
the FRB. 

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. 
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. 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 

104 

Wells Fargo & Company 

  
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. 

Uncertainty about the future of the London Interbank Offered 
Rate (LIBOR) may adversely affect our business, results of 
operations, and financial condition.  Due to uncertainty 
surrounding the suitability and sustainability of LIBOR, central 
banks and global regulators have called for financial market 
participants to prepare for the discontinuation of LIBOR by the 
end of 2021. We have a significant number of assets and 
liabilities referenced to LIBOR and other interbank offered rates 
such as commercial loans, adjustable-rate mortgage loans, 
derivatives, debt securities, and long-term debt. When 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, 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. 

This could impact the financial performance of previously 

booked transactions, result in losses on financial instruments we 
hold, require different hedging strategies or result in ineffective 
or increased basis risk on existing hedges, impact the overall 
interest rate environment and the availability or cost of floating-
rate funding, and affect our capital and liquidity planning and 
management. In addition, the transition to using any new 
benchmark rate or other financial metric may require changes to 

existing transaction data, products, systems, models, operations, 
and pricing processes, require substantial changes to existing 
documentation and the renegotiation of a substantial volume of 
previously booked transactions, and could result in significant 
operational, systems, or other practical challenges, increased 
compliance, legal and operational costs, heightened expectations 
and scrutiny from regulators, reputational harm, or other adverse 
consequences. Furthermore, the transition away from widely 
used benchmark rates like LIBOR could result in customers or 
other market participants challenging the determination of their 
interest payments, disputing the interpretation or 
implementation of contract “fallback” provisions and other 
transition related changes, 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. 

For additional information on the discontinuation of LIBOR 
and the steps we are taking to address and mitigate the risks we 
have identified, refer to the “Risk Management - Asset/Liability 
Management - LIBOR Transition” section 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 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 non-U.S. 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 

Wells Fargo & Company 

105 

  
Risk Factors (continued) 

negatively affect our ability to access the capital markets; our 
inability to sell or securitize loans or other assets; disruptions or 
volatility in the repurchase market which also may increase our 
short-term funding costs; 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 18 (Derivatives) to Financial 
Statements in this Report. 

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 
dated June 28, 2017, as amended and restated on June 26, 2019, 
among the Parent, WFC Holdings, LLC, an intermediate holding 
company and subsidiary of the Parent (the “IHC”), Wells Fargo 
Bank, N.A., Wells Fargo Securities, LLC, Wells Fargo Clearing 
Services, LLC, and certain other direct and indirect subsidiaries of 
the Parent designated as material entities for resolution planning 
purposes or identified as related support entities in our 
resolution plan, the IHC may be restricted from making dividend 
payments to the Parent if certain liquidity and/or capital metrics 
fall below defined triggers or if the Parent’s board of directors 
authorizes it to file a case under the U.S. Bankruptcy Code. 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 2019 Form 10-K and to Note 3 (Cash, 
Loan and Dividend Restrictions) and Note 29 (Regulatory and 
Agency Capital Requirements) to Financial Statements in this 
Report. 

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Wells Fargo & Company 

 
  
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 they 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 continue to 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 
non-U.S. 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, which, among other 

things, imposes significant requirements and restrictions 
impacting the financial services industry, became law. The Dodd-
Frank Act has resulted in significant rulemaking by federal 
regulators, including the FRB, OCC, CFPB, FDIC, SEC and CFTC, 
which may continue to impact our business, including the types 
of products and services we can provide, the manner in which we 
operate our businesses, and our compliance and risk 
management activities. The Dodd-Frank Act, including the rules 
implementing its provisions and the interpretation of those 
rules, may continue to 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, the 
CFPB’s rules, which primarily impact our consumer businesses, 
may continue to increase our compliance costs and require 
changes in our business practices, which could limit or negatively 
affect the products and services that we offer our customers. 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. 
Federal banking regulators, the SEC and the CFTC jointly 
released a final rule to implement the Volcker Rule’s restrictions, 
and have adopted amendments to the rule to streamline and 
tailor the requirements for compliance. 

In addition, the Dodd-Frank Act established a 

comprehensive framework for regulating over-the-counter 
derivatives and federal regulators, including the CFTC and SEC, 
have adopted rules regulating swaps, security-based swaps, 
derivatives activities, and other broker-dealer conduct and 
activities. These rules may continue to negatively impact 
customer demand for over-the-counter derivatives, impact our 
ability to offer customers new derivatives or amendments to 
existing derivatives, and increase our costs for engaging in swaps, 
security-based swaps, and other derivatives activities. Moreover, 
these rules may impact the manner in which we conduct business 
with customers seeking investment advice and may affect 
certain investment product offerings. 

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 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 

Wells Fargo & Company 

107 

Risk Factors (continued) 

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. 

In addition, we are subject to consent orders with certain of 
our regulators, including a February 2018 consent order with the 
FRB regarding the Board’s governance and oversight of the 
Company, and the Company’s compliance and operational risk 
management program. The consent order limits the Company’s 
total consolidated assets to the level as of December 31, 2017, 
until certain conditions are met. This limitation could adversely 
affect our results of operations or financial condition. We are also 
subject to April 2018 consent orders with the CFPB and OCC 
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.

 Under the April 2018 consent order with the OCC, Wells 
Fargo Bank, N.A., remains subject to requirements that were 
originally imposed in November 2016 to provide prior written 
notice to, and obtain non-objection from, the OCC with respect 
to changes in directors and senior executive officers, and remains 
subject to certain regulatory limitations on post-termination 
payments to certain individuals and employees. 

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 
February 2018 FRB consent order, the April 2018 CFPB and OCC 
consent orders, and any other consent orders or regulatory 
actions, as well as the implementation of their requirements, 
may continue to increase the Company’s costs, require the 
Company to reallocate resources away from growing its existing 
businesses, and require the Company to undergo significant 
changes to its business, products and services. For more 
information on the February 2018 FRB consent order and the 
April 2018 CFPB and OCC consent orders, refer to the 
“Regulatory Matters” section in this Report. 

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 ending the conservatorships of the GSEs 
and reducing or eliminating over time the role of the GSEs in 
buying mortgage loans or guaranteeing mortgage-backed 
securities (MBS), as well as the implementation of reforms 
relating to borrowers, lenders, and investors in the mortgage 
market. Regulatory changes to limit certain products, phase in a 
minimum down payment requirement for borrowers, tighten 
underwriting standards, or change the loan types and MBS pools 
included in the securitization process are also possible. Congress 
also may consider legislation to reform the mortgage finance 
market in an effort to assist borrowers experiencing difficulty 
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 on the significant regulations and 
regulatory oversight initiatives that have affected or may affect 
our business, refer to the “Regulatory Matters” section in this 
Report and the “Regulation and Supervision” section in our 2019 
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 submitted a 
resolution plan, also known as a “living will,” that is designed to 
facilitate our rapid and orderly resolution in the event of material 
financial 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 and/or FDIC determine 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 and/or FDIC ultimately determine that we 
have been unable to remedy any deficiencies, they could require 
us to divest certain assets or operations. On December 17, 2019, 
the FRB and FDIC announced that the Company’s 2019 
resolution plan did not have any deficiencies, but they identified 
a specific shortcoming that would need to be addressed. 

In addition to our resolution plans, 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. Our insured national bank subsidiary, Wells 
Fargo Bank, N.A. (the “Bank”), must also prepare and submit to 
the OCC a recovery plan. If either 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 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. 

The strategy described in our most recent resolution plan is 
a single point of entry strategy, in which the Parent would likely 

108 

Wells Fargo & Company 

be the only material legal entity to enter resolution proceedings. 
However, we are not obligated to maintain a single point of entry 
strategy, and the strategy described in our resolution plan is 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. 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. 

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, 
on June 28, 2017, the Parent entered into a support agreement, 
as amended and restated on June 26, 2019 (the “Support 
Agreement”), with WFC Holdings, LLC, an intermediate holding 
company and subsidiary of the Parent (the “IHC”), the Bank, 
Wells Fargo Securities, LLC (“WFS”), Wells Fargo Clearing 
Services, LLC (“WFCS”), and certain other direct and indirect 
subsidiaries of the Parent designated as material entities for 
resolution planning purposes (the “Covered Entities”) or 
identified as related support entities in our resolution plan. 
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, 
WFS, WFCS, and the Covered Entities pursuant to 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, or if the Parent’s board of directors authorizes it 
to file a case under the U.S. Bankruptcy Code, the subordinated 
notes would be forgiven, the committed line of credit would 
terminate, and the IHC’s ability to pay dividends to the Parent 
would be restricted, any of 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. 

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 single point of entry strategy or using a multiple point of 
entry strategy, in which the Parent and one or more of its 
subsidiaries would each undergo separate resolution 
proceedings. Furthermore, in a single point of entry or multiple 
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. 

For more information, refer to the “Regulatory Matters - 
‘Living Will’ Requirements and Related Matters” section in this 
Report. 

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 rules issued by federal 
banking regulators to implement Basel III capital requirements 
for U.S. banking organizations. These capital rules, among other 
things, establish required minimum ratios relating capital to 
different categories of assets and exposures. Federal banking 
regulators have also finalized rules to impose a supplementary 
leverage ratio on large BHCs like Wells Fargo and our insured 
depository institutions. The FRB has also 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). 
Similarly, federal banking regulators have issued a final rule that 
implements a liquidity coverage ratio. 

In addition, 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 

Wells Fargo & Company 

109 

Risk Factors (continued) 

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 
continue to 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,” 
“Risk Management – Asset/Liability Management – Liquidity and 
Funding – Liquidity Standards,” and “Regulatory Matters” 
sections in this Report and the “Regulation and Supervision” 
section in our 2019 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, including its target range for the federal 
funds rate or actions taken to increase or decrease the size of its 
balance sheet, 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 
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, 
disease pandemics, or political or social matters, also can 
influence recognition of credit losses in our loan portfolios and 
impact our allowance for credit losses. 

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, 
2019, 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, 
changes in consumer behavior or other market conditions, such 
as in response to climate change and other environmental and 
sustainability concerns, may adversely affect borrowers in certain 
industries or sectors, which may increase our credit risk and 
reduce the demand by these borrowers for our products and 
services. Moreover, 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. 

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 

110 

Wells Fargo & Company 

 
 
 
 
result in materially higher credit losses and have a material 
adverse effect on our financial results and condition. 

Challenges and/or changes in non-U.S. economic conditions 
may increase our non-U.S. credit risk. Our non-U.S. loan exposure 
represented approximately 8% of our total consolidated 
outstanding loans and 4% of our total assets at December 31, 
2019. Economic difficulties in non-U.S. 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 non-U.S. operations. 

Due to regulatory requirements, we must clear certain 

derivative transactions through central counterparty 
clearinghouses (CCPs), which results in credit exposure to these 
CCPs. Similarly, because we are a member of various CCPs, we 
may be required to pay a portion of any losses incurred by the 
CCP in the event that one or more members of the CCP defaults 
on its obligations. In addition, we are exposed to the risk of non-
performance by our clients for which we clear transactions 
through CCPs to the extent such non-performance is not 
sufficiently covered by available collateral. 

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. 

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 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. Similarly, we may not be 
able to timely recover critical business processes or operations 
that have been disrupted, which may further increase any 
associated costs and consequences of such disruptions. Although 
we have business continuity plans and other safeguards in place 
to help provide operational resiliency, 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. Although applications and related workloads were 
systematically re-routed to back-up data centers throughout the 
day, certain of our services, including our online and mobile 
banking systems, certain mortgage origination systems, and 
certain ATM functions, experienced disruptions that delayed 
service to our customers. 

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. 

Wells Fargo & Company 

111 

Risk Factors (continued) 

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 continue to 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 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 continue to 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 

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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, or if a team member fails to comply with applicable 
policies and procedures or inappropriately circumvents controls. 
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. 
Furthermore, certain of our models are subject to regulatory 
review and approval, and any failure to meet regulatory 
standards or expectations could result in fines, penalties, 
restrictions on our ability to engage in certain business activities, 
or other adverse consequences, and any required modifications 
or changes to these models can impact our capital ratios and 
requirements and result in increased operational and compliance 
costs. 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 
remedy sought and granted, could materially adversely affect our 
results of operations and financial condition. We may continue to 
incur additional costs and expenses in order to address and 
defend these pending legal proceedings and government 

investigations, and we may continue to 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. 

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 past practices involving 
certain automobile collateral protection insurance policies and 
certain issues related to the unused portion of guaranteed 
automobile protection waiver or insurance agreements. 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 “– Other Customer Remediation 
Activities” sections and Note 17 (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 non-U.S. 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 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. 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 non-U.S. countries and designated 
nationals of those countries. OFAC may impose penalties or 
restrictions on certain activities for inadvertent or unintentional 

Wells Fargo & Company 

113 

 
Risk Factors (continued) 

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. 

Reputational harm, including as a result of our actual or alleged 
conduct or public opinion of the financial services industry 
generally, could adversely affect our business, results of 
operations, and financial condition.  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 reputation and 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, 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 public opinion of the Company specifically or large 
financial institutions generally will not harm our reputation and 
adversely affect our business, results of operations, and financial 
condition. 

Risks related to legal actions.  Wells Fargo and some of its 
subsidiaries are involved in judicial, regulatory, governmental, 
arbitration, and other proceedings or investigations concerning 
matters arising from the conduct of our business activities, and 
many of those proceedings and investigations expose Wells 
Fargo to potential financial loss. 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 17 (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, which we initially measure 
and carry 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 

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Wells Fargo & Company 

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 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 the 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. In order to meet customer needs, we also 
originate loans that do not conform to either the GSEs 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 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 retain nonconforming loans on our balance 
sheet, whether due to regulatory, business or other reasons, our 
ability to originate new nonconforming loans may be reduced, 
thereby reducing the interest income we could earn from these 
loans. Similarly, if the GSEs or 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 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 (FHFA) acting as conservator. While the FHFA 
has stated that it intends to end the conservatorship, we cannot 
predict if, when or precisely 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 any changes to the GSE’s 
structure, capital requirements, or market presence, 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,” “Critical Accounting Policies – Valuation of 
Residential Mortgage Servicing Rights” and “Critical Accounting 
Policies - Fair Value of Financial Instruments” 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.  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. 

Wells Fargo & Company 

115 

Risk Factors (continued) 

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 certain foreclosure obligations or, if 
applicable, considering alternatives to foreclosure such as loan 
modifications or short-sales, as well as certain servicing 
obligations for properties that fall within a flood zone. If we fail 
to satisfy our servicing obligations, we may face a number of 
consequences, including termination as servicer or master 
servicer, requirements to indemnify the securitization trustee 
against losses from any failure by us to perform our servicing 
obligations, and/or contractual obligations to repurchase a 
mortgage loan or reimburse investors for credit losses, any of 
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. Our net servicing income and 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 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 16 (Guarantees, 
Pledged Assets and Collateral, and Other Commitments) and 
Note 17 (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 and preferences, 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 and preferences. 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 

116 

Wells Fargo & Company 

 
  
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, on 
January 1, 2020, we adopted Accounting Standards Update 
2016-13 – Financial Instruments-Credit Losses (Topic 326), which 
replaced the previous “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. 

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, including information on our adoption 

of CECL, refer to the “Current Accounting Developments” 
section in this Report. 

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. 
Certain of our financial instruments, including derivative 
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 or manage change effectively, our 
competitive standing and results of operations could suffer. 
We are subject to rapid changes in technology, regulation, and 
product innovation, face intense competition for customers, 
sources of revenue, capital, services, qualified team members, 
and other essential business resources, and are subject to 
heightened regulatory expectations particularly with respect to 
compliance and risk management. In order to meet these 
challenges, we may undertake business plans or strategies 
related to, among other things, our organizational structure, our 
compliance and risk management framework, our expenses and 
efficiency, the types of products and services we offer, the types 
of businesses we engage in, 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, require significant financial, 
technological, management and other resources, and may divert 
management attention and resources away from other areas of 
the Company, 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 or manage change effectively, our competitive 
position, reputation, prospects for growth, and results of 
operations may be adversely affected. 

In addition, we regularly explore opportunities to expand 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 

Wells Fargo & Company 

117 

 
  
Risk Factors (continued) 

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. Similarly, from time to time, we may decide to divest 
certain businesses or assets. Difficulties in executing a 
divestiture may cause us not to realize any expected cost savings 
or other benefits from the divestiture, or may result in higher 
than expected losses of team members or harm our ability to 
retain customers. 

*  *  * 

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 2020 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. 

118 

Wells Fargo & Company 

Controls and Procedures 

Disclosure Controls and Procedures 

The Company’s management evaluated the effectiveness, as of December 31, 2019, 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, 2019. 

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 
2019 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, 2019, 
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, 2019, 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. 

Wells Fargo & Company 

119 

 
Report of Independent Registered Public Accounting Firm 

To 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, 
2019, 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, 2019, 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, 2019 and 2018, 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, 2019, and 
the related notes (collectively, the consolidated financial statements), and our report dated February 26, 2020 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 26, 2020 

120 

Wells Fargo & Company 

Financial Statements 

Wells Fargo & Company and Subsidiaries 

Consolidated Statement of Income 

(in millions, except per share amounts) 

Interest income 

Debt securities 

Mortgage loans held for sale 

Loans held for sale 

Loans 

Equity securities 

Other interest income 

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 

Net gains on debt securities (1) 

Net gains from equity securities (2) 

Lease income 

Other 

Total noninterest income 

Noninterest expense 

Salaries 

Commission and incentive compensation 

Employee benefits 

Technology and 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, 

2019 

2018 

2017 

$ 

14,955 

14,406 

12,946 

813 

79 

44,146 

962 

5,128 

66,083 

8,635 

2,316 

7,350 

551 

18,852 

47,231 

2,687 

44,544 

4,798 

14,072 

4,016 

3,084 

2,715 

378 

993 

140 

2,843 

1,612 

3,181 

37,832 

18,382 

10,828 

5,874 

2,763 

2,945 

108 

526 

16,752 

58,178 

24,198 

4,157 

20,041 

492 

19,549 

1,611 

17,938 

4.08 

4.05 

4,393.1 

4,425.4 

$ 

$ 

$ 

777 

140 

43,974 

992 

4,358 

64,647 

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 

786 

50 

41,388 

799 

2,940 

58,909 

3,013 

758 

5,157 

424 

9,352 

49,557 

2,528 

47,029 

5,111 

14,495 

3,960 

3,557 

4,350 

1,049 

542 

479 

1,779 

1,907 

1,603 

36,413 

38,832 

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 

4.14 

4.10 

4,964.6 

5,017.3 

(1) 

(2) 

Total other-than-temporary impairment (OTTI) losses were $64 million, $17 million and $205 million for the years ended December 31, 2019, 2018 and 2017, respectively. Of total OTTI, losses of 
$63 million, $28 million and $262 million were recognized in earnings, and losses (reversal of losses) of $1 million, $(11) million and $(57) million were recognized as non-credit-related OTTI in other 
comprehensive income for the years ended December 31, 2019, 2018 and 2017, respectively. 
Includes OTTI losses of $245 million, $352 million and $344 million for the years ended December 31, 2019, 2018 and 2017, respectively. 

The accompanying notes are an integral part of these statements. 

Wells Fargo & Company 

121 

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 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 

2019 

$ 

19,549 

Year ended December 31, 

2018 

22,393 

2017 

22,183 

5,439 

122 

(4,493) 

248 

(24) 

299 

(40) 

133 

73 

6,002 

(1,458) 

4,544 

— 

4,544 

24,093 

492 

$ 

24,585 

(532) 

294 

(434) 

253 

(156) 

(4,820) 

1,144 

(3,676) 

(2) 

(3,674) 

18,719 

481 

19,200 

2,719 

(737) 

(540) 

(543) 

49 

153 

96 

1,197 

(434) 

763 

(62) 

825 

23,008 

215 

23,223 

(1) 

The year ended December 31, 2017, includes net unrealized gains (losses) arising during the period from equity securities of $81 million and reclassification of net (gains) losses to net income related 
to equity securities of $(456) million. In connection with our adoption in first quarter 2018 of Accounting Standards Update (ASU) 2016-01, the years ended December 31, 2018, and December 31, 
2019, reflect 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. 

122 

Wells Fargo & Company 

Wells Fargo & Company and Subsidiaries 

Consolidated Balance Sheet 

(in millions, except shares) 

Assets 

Cash and due from banks 

Interest-earning deposits with banks 

Total cash, cash equivalents, and restricted cash 

Federal funds sold and securities purchased under resale agreements 

Debt securities: 

Trading, at fair value 

Available-for-sale, at fair value 

Held-to-maturity, at cost (fair value $156,860 and $142,115) 

Mortgage loans held for sale (includes $16,606 and $11,771 carried at fair value) (1) 

Loans held for sale (includes $972 and $1,469 carried at fair value) (1) 

Loans (includes $171 and $244 carried at fair value) (1) 

Allowance for loan losses 

Net loans 

Mortgage servicing rights: 

Measured at fair value 

Amortized 

Premises and equipment, net 

Goodwill 

Derivative assets 

Equity securities (includes $41,936 and $29,556 carried at fair value) (1) 

Other assets 

Total assets (2) 

Liabilities 

Noninterest-bearing deposits 

Interest-bearing deposits 

Total deposits 

Short-term borrowings 

Derivative liabilities 

Accrued expenses and other liabilities 

Long-term debt 

Total liabilities (3) 

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 – 1,347,385,537 shares and 900,557,866 shares 

Unearned ESOP shares 

Total Wells Fargo stockholders’ equity 

Noncontrolling interests 

Total equity 

Total liabilities and equity 

$ 

$ 

$ 

Dec 31, 

2019 

21,757 

119,493 

141,250 

102,140 

79,733 

263,459 

153,933 

23,342 

977 

962,265 

(9,551) 

952,714 

11,517 

1,430 

9,309 

26,390 

14,203 

68,241 

78,917 

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 

1,927,555 

1,895,883 

344,496 

978,130 

1,322,626 

104,512 

9,079 

75,163 

228,191 

349,534 

936,636 

1,286,170 

105,787 

8,499 

69,317 

229,044 

1,739,571 

1,698,817 

21,549 

9,136 

61,049 

166,697 

(1,311) 

(68,831) 

(1,143) 

187,146 

838 

187,984 

23,214 

9,136 

60,685 

158,163 

(6,336) 

(47,194) 

(1,502) 

196,166 

900 

197,066 

$ 

1,927,555 

1,895,883 

Parenthetical amounts represent assets and liabilities that we are required to carry at fair value or have elected the fair value option. 

(1) 
(2)  Our consolidated assets at December 31, 2019 and 2018, 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, $16 million and $139 million; Interest-bearing deposits with banks, $284 million and $8 million; Debt securities, $540 million and $562 million; Net loans, $13.2 billion and 
$13.6 billion; Derivative assets, $1 million and $0 million; Equity securities, $118 million and $85 million; Other assets, $239 million and $227 million; and Total assets, $14.4 billion and $14.6 billion, 
respectively. Prior period balances have been conformed to current period presentation. 

(3)  Our consolidated liabilities at December 31, 2019 and 2018, include the following VIE liabilities for which the VIE creditors do not have recourse to Wells Fargo: Short-term borrowings, $401 million 
and $493 million; Derivative liabilities, $3 million and $0 million; Accrued expenses and other liabilities, $235 million and $199 million; Long-term debt, $587 million and $816 million; and Total 
liabilities, $1.2 billion and $1.5 billion, respectively. Prior period balances have been conformed to current period presentation. 

The accompanying notes are an integral part of these statements. 

Wells Fargo & Company 

123 

 
Wells Fargo & Company and Subsidiaries 

Consolidated Statement of Changes in Equity 

(in millions, except shares) 

Balance December 31, 2016 

Cumulative effect from change in hedge accounting (1) 

Balance January 1, 2017 

Net income 

Other comprehensive income (loss), net of tax 

Noncontrolling interests 

Common stock issued 

Common stock repurchased 

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, 2017 

Cumulative effect from change in accounting policies (2) 

Balance January 1, 2018 

Adoption of accounting standard related to certain tax effects stranded in accumulated 

other comprehensive income (loss)(3) 

Net income 

Other comprehensive income (loss), net of tax 

Noncontrolling interests 

Common stock issued 

Common stock repurchased 

Preferred stock redeemed (4) 

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 

Preferred stock 

Common stock 

Shares 

Amount 

Shares 

Amount 

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 

11,677,235  $ 

25,358 

4,891,616,628  $ 

9,136 

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) 
(2) 

(3) 

(4) 

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. 
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. 
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 third quarter 2018. 
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. 

(continued on following pages) 

124 

Wells Fargo & Company 

 
Additional 
paid-in 
capital 

60,234 

60,234 

— 

(133) 

750 

31 

(35) 

97 

(133) 

(13) 

50 

875 

(830) 

659 

60,893 

Retained 
earnings 

133,075 

(381) 

132,694 

22,183 

(277) 

(7,708) 

(1,629) 

12,569 

145,263 

94 

60,893 

145,357 

Cumulative 
other 
comprehensive 
income (loss) 

(3,137) 

168 

(2,969) 

825 

825 

(2,144) 

(118) 

(2,262) 

(400) 

(3,674) 

400 

22,393 

(321) 

(155) 

(7,955) 

(1,556) 

7 

(76) 

— 

43 

(70) 

6 

(325) 

— 

66 

1,041 

(900) 

(208) 

60,685 

Wells Fargo stockholders’ equity 

Unearned 
ESOP 
shares 

Total 
Wells Fargo 
stockholders’ 
equity 

(1,565) 

199,581 

Treasury 
stock 

(22,713) 

(22,713) 

(1,565) 

2,758 

(10,658) 

736 

(981) 

868 

(15) 

(7,179) 

(29,892) 

(113) 

(1,678) 

(213) 

199,368 

22,183 

825 

— 

2,348 

(9,908) 

— 

833 

— 

(133) 

677 

(7,658) 

(1,629) 

875 

(845) 

7,568 

206,936 

(24) 

Noncontrolling 
interests 

916 

916 

277 

(62) 

12 

227 

1,143 

Total 
equity 

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 

(24) 

(29,892) 

(1,678) 

206,912 

1,143 

208,055 

2,073 

(20,633) 

1,243 

(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) 

(10,746) 

196,166 

483 

(2) 

(724) 

(243) 

900 

— 

22,876 

(3,676) 

(717) 

1,676 

(20,633) 

(2,150) 

— 

1,249 

— 

(325) 

— 

(7,889) 

(1,556) 

1,041 

(885) 

(10,989) 

197,066 

12,806 

158,163 

(4,074) 

(6,336) 

15 

(17,302) 

(47,194) 

176 

(1,502) 

Wells Fargo & Company 

125 

(continued from previous pages) 

Wells Fargo & Company and Subsidiaries 

Consolidated Statement of Changes in Equity 

(in millions, except shares) 

Balance December 31, 2018 

Cumulative effect from change in accounting policies (1) 

Balance January 1, 2019 

Net income 

Other comprehensive income (loss), net of tax 

Noncontrolling interests 

Common stock issued 

Common stock repurchased 

Preferred stock redeemed (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 

Stock incentive compensation expense 

Net change in deferred compensation and related plans 

Net change 

Balance December 31, 2019 

Preferred stock 

Common stock 

Shares 

Amount 

Shares 

Amount 

9,377,216 

$ 

23,214 

4,581,253,608 

$ 

9,136 

9,377,216 

23,214 

4,581,253,608 

9,136 

48,771,064 

(502,418,179) 

(1,550,000) 

(1,330) 

— 

— 

(335,047) 

(335) 

6,819,444 

— 

— 

(1,885,047) 

(1,665) 

(446,827,671) 

— 

7,492,169 

$ 

21,549 

4,134,425,937 

$ 

9,136 

(1) 

(2) 

Effective January 1, 2019, we adopted ASU 2016-02 – Leases (Topic 842) and subsequent related Updates, ASU 2017-08 – Receivables – Nonrefundable Fees and Other Costs (Subtopic 310-20): 
Premium Amortization on Purchased Callable Debt Securities. See Note 1 (Summary of Significant Accounting Policies) in this Report for more information. 
Represents the impact of the partial redemption of preferred stock, series K, in third quarter 2019. 

The accompanying notes are an integral part of these statements. 

126 

Wells Fargo & Company 

Cumulative 
other 
comprehensive 
income (loss) 

(6,336) 

481 

(5,855) 

4,544 

Retained 
earnings 

158,163 

(492) 

157,671 

19,549 

(382) 

(220) 

(8,530) 

(1,391) 

Additional
 paid-in 
capital 

60,685 

60,685 

— 

9 

— 

— 

(24) 

(16) 

— 

— 

86 

1,234 

(925) 

364 

61,049 

Wells Fargo stockholders’ equity 

Unearned 
ESOP 
shares 

Total 
Wells Fargo 
stockholders’ 
equity 

Noncontrolling 
interests 

Total 
equity 

(1,502) 

196,166 

900 

197,066 

Treasury 
stock 

(47,194) 

(47,194) 

(1,502) 

196,155 

(11) 

2,530 

(24,533) 

351 

— 

359 

900 

492 

— 

(554) 

(62) 

838 

(11) 

197,055 

20,041 

4,544 

(554) 

2,157 

(24,533) 

(1,550) 

— 

335 

— 

— 

— 

(8,444) 

(1,391) 

1,234 

(910) 

(9,071) 

187,984 

19,549 

4,544 

— 

2,157 

(24,533) 

(1,550) 

— 

335 

— 

— 

— 

(8,444) 

(1,391) 

1,234 

(910) 

(9,009) 

187,146 

9,026 

166,697 

4,544 

(1,311) 

15 

(21,637) 

(68,831) 

359 

(1,143) 

Wells Fargo & Company 

127 

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 
Stock-based compensation 

Originations and purchases of mortgage loans held for sale 
Proceeds from sales of and paydowns on mortgage loans held for sale 
Net change in: 

Debt and equity securities, held for trading 
Loans held for sale 
Deferred income taxes 
Derivative assets and liabilities 
Other assets 
Other accrued expenses and liabilities 

Net cash provided by operating activities 

Cash flows from investing activities: 

Net change in: 

Federal funds sold and securities purchased under resale agreements 

Available-for-sale debt securities: 

Proceeds from sales 
Prepayments and maturities 
Purchases 

Held-to-maturity securities: 

Paydowns and maturities 
Purchases 

Equity securities, not held for trading: 

Proceeds from sales and capital returns 
Purchases 

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 

Proceeds from sales of foreclosed assets and short sales 
Other, net (1) 

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 used by financing activities 

Net change in cash, cash equivalents, and restricted cash 

Cash, cash equivalents, and restricted cash at beginning of year 

Cash, cash equivalents, and restricted cash at end of year 

Supplemental cash flow disclosures: 

Cash paid for interest 
Cash paid for income taxes 

Year ended December 31, 

2019 

2018 

2017 

$ 

20,041 

22,876 

22,460 

2,687 
3,702 
7,075 
(5,500) 
2,274 
(158,673) 
112,718 

22,066 
788 
(3,246) 
(2,665) 
3,034 
2,429 

6,730 

(21,933) 

9,386 
46,542 
(57,015) 

13,684 
(8,649) 

6,143 
(6,865) 

(23,698) 
12,038 
(2,033) 
3,912 
(5,274) 
2,666 
1,465 

(29,631) 

36,137 
(1,275) 

53,381 
(60,996) 

— 
(1,550) 
(1,391) 

380 
(302) 
(24,533) 
(8,198) 
(513) 
(276) 

(9,136) 

(32,037) 

173,287 

141,250 

18,834 
7,557 

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 

(1,184) 

(21,497) 

7,320 
36,725 
(60,067) 

10,934 
— 

6,242 
(6,433) 

(18,619) 
16,294 
(2,088) 
6,791 
(6,482) 
3,592 
(779) 

(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 

14,366 
1,977 

42,067 
45,688 
(103,656) 

10,673 
— 

5,451 
(3,735) 

317 
10,439 
(3,702) 
7,448 
(6,814) 
5,198 
(1,029) 

(13,152) 

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 

9,103 
6,592 

$ 

$ 

(1) 

Prior periods have been revised to conform to the current period presentation. 

The accompanying notes are an integral part of these statements. See Note 1 (Summary of Significant Accounting Policies) for noncash activities. 

128 

Wells Fargo & Company 

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, investment and mortgage 
products and services, as well as consumer and commercial 
finance, through banking locations and offices, the internet and 
other distribution channels to individuals, businesses and 
institutions in all 50 states, the District of Columbia, and in 
countries outside the U.S. 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. 

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 10 (Securitizations and Variable Interest Entities) and 
Note 11 (Mortgage Banking Activities)); 
valuations of financial instruments (Note 18 (Derivatives) 
and Note 19 (Fair Values of Assets and Liabilities)); 
liabilities for contingent litigation losses (Note 17 (Legal 
Actions)); and 
income taxes (Note 24 (Income Taxes)). 

• 

• 

• 

• 

Actual results could differ from those estimates. 

Accounting Standards Adopted in 2019 
In 2019, we adopted the following new accounting guidance: 
• 

Accounting Standards 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 2017-08 – Receivables – Nonrefundable Fees and 
Other Costs (Subtopic 310-20): Premium Amortization on 
Purchased Callable Debt Securities 
ASU 2016-02 – Leases (Topic 842) and subsequent related 
Updates, including early adoption of ASU 2019-01 – Leases 
(Topic 842): Codification Improvements 

• 

• 

ASU 2018-16 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 London Interbank Offered Rate (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 is applied prospectively for qualifying new or re-
designated hedging relationships entered into on or after 
adoption date. 

We adopted the guidance in first quarter 2019. The Update 
has not had an impact as we have not designated SOFR OIS as a 
benchmark interest rate in any hedging relationships. 

ASU 2017-08 changes the interest income recognition model for 
purchased callable debt securities carried at a premium, as the 
premium will be amortized to the earliest call date rather than to 
the contractual maturity date. Accounting for purchased callable 
debt securities held at a discount does not change, as the 
discount will continue to accrete to the contractual maturity 
date. The Update impacted our investments in purchased callable 
debt securities classified as available-for-sale (AFS) and held-to-
maturity (HTM), which predominantly consist of debt securities 
of U.S. states and political subdivisions. 

We adopted the Update in first quarter 2019 and recorded a 

cumulative-effect adjustment as of January 1, 2019, that 
decreased total stockholders’ equity by $111 million. Retained 
earnings was reduced by $592 million which reflects both the 
incremental premium amortization under the new guidance from 
the acquisition date of our impacted AFS and HTM debt 
securities through the date of adoption and the fact that the 
incremental premium amortization is not deductible for federal 
income tax purposes. Other comprehensive income (OCI) was 
increased by $481 million which reflects the corresponding 
adjustment to the adoption date unrealized gain or loss of 
impacted AFS debt securities. Going forward, interest income 
recognized prior to the call date will be reduced because the 
premium will be amortized over a shorter period. 

ASU 2016-02 modifies the guidance used by lessors and lessees 
to account for leasing transactions. For our transition to the new 
guidance, we elected several available practical expedients, 
including to not reassess the classification of our existing leases, 
any initial direct costs associated with our leases, or whether any 
existing contracts are or contain leases. In addition, we elected 
not to provide a comparative presentation for 2018 and 2017 
financial statements. 

We adopted the Update in first quarter 2019 and recorded a 

cumulative-effect adjustment that increased retained earnings 
by $100 million related to deferred gains on our prior sale-
leaseback transactions. We also recognized operating lease right-
of-use (ROU) assets and liabilities, substantially all of which 
relate to our leasing of real estate as a lessee, of $4.9 billion and 
$5.6 billion, respectively. 

Wells Fargo & Company 

129 

 
Note 1:  Summary of Significant Accounting Policies (continued) 

Table 1.1 summarizes financial assets and liabilities by form 

and measurement accounting model. 

Table 1.1:  Accounting Model for Financial Assets and Financial Liabilities 

Balance sheet caption 

Measurement model(s) 

Financial statement Note reference 

Cash and due from banks 

Interest-earning deposits with banks 

Amortized cost 

Amortized cost 

Note 3: Cash, Loan and Dividend Restrictions 

Note 3: Cash, Loan and Dividend Restrictions 

Federal funds sold and securities purchased under resale  Amortized cost 

N/A 

agreements 

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 

FV-NI (1) 

FV-OCI (2) 

Note 4:  Trading Activities 
Note 19:  Fair Values of Assets and Liabilities 

Note 5:  Available-for-Sale and Held-to-Maturity Debt Securities 
Note 19:  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) 

Note 19:  Fair Values of Assets and Liabilities 

Note 19:  Fair Values of Assets and Liabilities 

Note 6:  Loans and Allowance for Credit Losses 
Note 19:  Fair Values of Assets and Liabilities 

Note 4:  Trading Activities 
Note 18:  Derivatives 
Note 19:  Fair Values of Assets and Liabilities 

Note 4:  Trading Activities 
Note 8:  Equity Securities 
Note 19:  Fair Values of Assets and Liabilities 

Note 4:  Trading Activities 
Note 8:  Equity Securities 
Note 19:  Fair Values of Assets and Liabilities 

Amortized cost (5) 

Note 9:  Premises, Equipment, and Other Assets 

Amortized cost 

Amortized cost 

Note 13:  Deposits 

Note 14:  Short-Term Borrowings 

Accrued expenses and other liabilities 

Amortized cost (6) 

Note 4:  Trading Activities 
Note 7:  Leasing Activity 
Note 19:  Fair Values of Assets and Liabilities 

Long-term debt 

Amortized cost 

Note 15:  Long-Term Debt 

FV-NI represents the fair value through net income accounting model. 
FV-OCI represents the fair value through other comprehensive income accounting model. 
LOCOM represents the lower of cost or fair value accounting model. 

(1) 
(2) 
(3) 
(4)  MA represents the measurement alternative accounting model. 
(5)  Other assets are generally measured at amortized cost, except for bank-owned life insurance which is measured at cash surrender value. 
(6) 

Accrued expenses and other liabilities are generally measured at amortized cost, except for trading short-sale liabilities which are measured at FV-NI. 

Consolidation 
Our consolidated financial statements include the accounts of 
the Parent and our subsidiaries in which we have a controlling 
financial interest. When our consolidated subsidiaries follow 
specialized industry accounting, that accounting is retained in 
consolidation. 

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 (collectively 
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, which is when we have 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. 
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. 

130 

Wells Fargo & Company 

  
 
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. Trading assets and liabilities include debt securities, 
equity securities, loans, derivatives and short sales, which are 
reported within the balance sheet based on the accounting 
classification 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, as well as 
short positions, 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 
earnings where the fair value changes and related interest 
income and expense of the positions are recorded. 

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) the 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 earnings where the fair value 
changes and related interest income and expense of the 
positions are recorded. 

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 
Investments in debt securities for which the Company does not 
have the positive intent and ability to hold to maturity are 
classified as AFS. AFS debt securities are measured at fair value 
with unrealized gains and losses reported in cumulative OCI, net 
of applicable income taxes. 

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. We 
recognize OTTI in earnings as a reduction to the amortized cost 
of the security. OTTI related to AFS debt securities is classified as 

net gains (losses) from debt securities within noninterest 
income. 

We recognize OTTI for an AFS debt security that has a 
decline in fair value below amortized cost 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, an OTTI has occurred. In 
performing an assessment of the cash flows 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 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, OTTI is recognized in earnings equal to the 
entire difference between the amortized cost basis and fair value 
of the security. For a 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, 
OTTI 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 less any OTTI 
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 

Wells Fargo & Company 

131 

Note 1:  Summary of Significant Accounting Policies (continued) 

effective interest method, except for purchased callable debt 
securities carried at a premium. For purchased callable debt 
securities carried at a premium, the premium is amortized into 
interest income to the earliest call date using the effective 
interest method. As principal repayments are received on 
securities (e.g., 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  Investments in debt 
securities for which the Company has the positive intent and 
ability to hold to maturity are classified as HTM. HTM debt 
securities are measured at historical cost adjusted for 
amortization of premiums and accretion of discounts under the 
same methods described for AFS debt securities. We recognize 
OTTI when there is a decline in fair value below amortized cost 
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. 
OTTI related to HTM debt securities is classified as net gains 
(losses) from debt securities within noninterest income. 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 cumulative OCI balance is amortized into 
earnings over the same period as the unamortized premiums and 
discounts 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 
from AFS to HTM. 

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 as well as the collateral pledged 
and received. Additional collateral is pledged or returned to 
maintain the appropriate collateral position for the transactions. 
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 in the securitization or 
whole loan market. We have elected the fair value option for 
substantially all residential MLHFS (see Note 19 (Fair Values of 
Assets and Liabilities)). The remaining residential MLHFS are held 
at the lower of cost or fair value (LOCOM) and are measured on 
an aggregate portfolio basis. Commercial MLHFS are held at 
LOCOM and are measured on an individual loan basis. 

Loans held for sale (LHFS) include commercial loans 
originated for sale and purchased 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. LHFS are measured on an individual loan 
basis. 

Gains and losses on MLHFS are generally recorded in 

mortgage banking noninterest income. Gains and losses on LHFS 

used in trading activities are recognized in net gains from trading 
activities. Gains and losses on LHFS not used in trading activities 
are recognized in other noninterest income. Direct loan 
origination costs and fees for MLHFS and LHFS under the fair 
value option are recognized in earnings at origination. For 
MLHFS and LHFS recorded at LOCOM, loan costs and fees are 
deferred at origination and are recognized in earnings 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 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. Purchased credit-
impaired (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 effective interest method. 
Loan commitment fees are generally deferred and amortized 
into noninterest income on a straight-line basis over the 
commitment period. 

Loans also include financing leases where we are the lessor.  
See the “Leasing Activity” section in this Note for our accounting 
policy for leases. 

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 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. 

• 

• 
• 

132 

Wells Fargo & Company 

 
 
 Credit card loans are not placed on nonaccrual status, but are 

generally fully charged off when the loan reaches 180 days past 
due. 

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 
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. 

• 

• 

• 

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: 

• 

• 

• 

• 

• 

Real estate 1-4 family 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. 
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 pre-modification 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 pre-modification 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 interest 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 

Wells Fargo & Company 

133 

Note 1:  Summary of Significant Accounting Policies (continued) 

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 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 The allowance for credit losses 
(ACL) 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 ACL that assesses the losses inherent 
in our portfolio and related unfunded credit commitments. We 
develop and document our ACL methodology at the portfolio 
segment level – commercial loan portfolio and consumer loan 
portfolio. While we attribute portions of the ACL to our 
respective commercial and consumer portfolio segments, the 

entire ACL 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 
PCI loans, based on the changes in cash flows expected to be 
collected. 

Our ACL amounts 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 ACL 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 ACL 
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. 

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 ACL 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 ACL. This imprecision considers 
economic environmental factors, modeling assumptions and 
performance, process risk, and other subjective factors, including 
industry trends and emerging risk assessments. 

134 

Wells Fargo & Company 

 
 
 
Leasing Activity 
AS LESSOR  We lease equipment to our customers under 
financing or operating leases. Financing leases are presented in 
loans and are recorded at the discounted amounts of lease 
payments receivable plus the estimated residual value of the 
leased asset. Leveraged leases, which are a form of financing 
leases, are reduced by related non-recourse debt from third-
party investors. Lease payments receivable reflect contractual 
lease payments adjusted for renewal or termination options that 
we believe the customer is reasonably certain to exercise. The 
residual value reflects our best estimate of the expected sales 
price for the equipment at lease termination based on sales 
history adjusted for recent trends in the expected exit markets. 
Many of our leases allow the customer to extend the lease at 
prevailing market terms or purchase the asset for fair value at 
lease termination. 

Our allowance for loan losses for financing leases considers 

both the collectability of the lease payments receivable as well as 
the estimated residual value of the leased asset. We typically 
purchase residual value insurance on our financing leases so that 
our risk of loss at lease termination will be less than 10% of the 
initial value of the lease. In addition, we have several channels for 
re-leasing or marketing those assets. 

In connection with a lease, we may finance the customer’s 

purchase of other products or services from the equipment 
vendor and allocate the contract consideration between the use 
of the asset and the purchase of those products or services 
based on information obtained from the vendor. Amounts 
allocated to financing of vendor products or services are 
reported in loans as commercial and industrial loans, rather than 
as lease financing. 

Our primary income from financing leases is interest income 

recognized using the effective interest method. Variable lease 
revenues, such as reimbursement for property taxes associated 
with the leased asset, are included in lease income within 
noninterest income. 

Operating lease assets are presented in other assets, net of 

accumulated depreciation. Periodic depreciation expense is 
recorded on a straight-line basis to the estimated residual value 
over the estimated useful life of the leased asset. On a periodic 
basis, operating lease assets are reviewed for impairment and 
impairment loss is recognized if the carrying amount of 
operating lease assets exceeds fair value and is not recoverable. 
The carrying amount of leased assets is deemed 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. Depreciation of 
leased assets and impairment loss are presented in operating 
leases expense within other noninterest expense. 

Operating lease rental income for leased assets is 
recognized in lease income within noninterest income on a 
straight-line basis over the lease term. Variable revenues on 
operating leases include reimbursements of costs, including 
property taxes, which fluctuate over time, as well as rental 
revenue based on usage. For leases of railcars, revenue for 
maintenance services provided under the lease is recognized in 
lease income. 

We elected to exclude from revenues and expenses any sales 

tax incurred on lease payments which are reimbursed by the 
lessee. Substantially all of our leased assets are protected against 
casualty loss through third-party insurance. 

AS LESSEE  We enter into lease agreements to obtain the right to 
use assets for our business operations, substantially all of which 
are real estate. Lease liabilities and ROU assets are recognized 

when we enter into operating or financing leases and represent 
our obligations and rights to use these assets over the period of 
the leases and may be re-measured for certain modifications, 
resolution of certain contingencies involving variable 
consideration, or our exercise of options (renewal, extension, or 
termination) under the lease. 

Operating lease liabilities include fixed and in-substance 

fixed payments for the contractual duration of the lease, 
adjusted for renewals or terminations which were considered 
probable of exercise when measured. The lease payments are 
discounted using a rate determined when the lease is recognized. 
As we typically do not know the discount rate implicit in the 
lease, we estimate a discount rate that we believe approximates 
a collateralized borrowing rate for the estimated duration of the 
lease. The discount rate is updated when re-measurement events 
occur. The related operating lease ROU assets may differ from 
operating lease liabilities due to initial direct costs, deferred or 
prepaid lease payments and lease incentives. 

We present operating lease liabilities in accrued expenses 
and other liabilities and the related operating lease ROU assets in 
other assets. The amortization of operating lease ROU assets 
and the accretion of operating lease liabilities are reported 
together as fixed lease expense and are included in net 
occupancy expense within noninterest expense. The fixed lease 
expense is recognized on a straight-line basis over the life of the 
lease. 

Some of our operating leases include variable lease 
payments which are periodic adjustments of our payments for 
the use of the asset based on changes in factors such as 
consumer price indices, fair market value rents, tax rates 
imposed by taxing authorities, or lessor cost of insurance. To the 
extent not included in operating lease liabilities and operating 
lease ROU assets, these variable lease payments are recognized 
as incurred in net occupancy expense within noninterest expense. 
For substantially all of our leased assets, we account for 
consideration paid under the contract for maintenance or other 
services as lease payments. In addition, for certain asset classes, 
we have elected to exclude leases with original terms of less than 
one year from the operating lease ROU assets and lease 
liabilities. The related short-term lease expense is included in net 
occupancy expense. 

Finance lease (formerly capital lease) liabilities are presented 

in long-term debt and the associated finance ROU assets are 
presented in premises and equipment. 

Securitizations and Beneficial Interests 
Securitizations are transactions in which financial assets are sold 
to a Special Purpose Entity (SPE), which then issues beneficial 
interests in the form of senior and subordinated interests 
collateralized by the transferred financial assets. In some cases, 
we may obtain beneficial interests issued by the SPE. 
Additionally, from time to time, we may re-securitize certain 
financial 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 or mortgage servicing rights) and 
all liabilities incurred. We record a gain or loss in noninterest 
income for the difference between assets obtained (net of 
liabilities incurred) and the carrying amount of the assets sold. 
Interests obtained from, and liabilities incurred in, securitizations 
with off-balance sheet entities may include debt and equity 
securities, loans, MSRs, derivative assets and liabilities, other 

Wells Fargo & Company 

135 

  
Note 1:  Summary of Significant Accounting Policies (continued) 

assets, and other obligations such as liabilities for mortgage 
repurchase losses or long-term debt and are accounted for as 
described within this Note. 

Mortgage Servicing Rights 
We recognize the rights to service mortgage loans for others, or 
mortgage servicing rights (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 10 (Securitizations and Variable Interest 
Entities), Note 11 (Mortgage Banking Activities) and Note 19 
(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. We 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. 

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, 
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 customer relationship intangible assets on an 

accelerated basis over useful lives not exceeding 10 years. We 
review intangible assets 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 
categorize the derivative as either an accounting hedge, 
economic hedge or part of our customer accommodation trading 
and other portfolio. 

Accounting hedges are either fair value or cash flow hedges. 

Fair value hedges represent the hedge of the fair value of a 
recognized asset or liability or an unrecognized firm 
commitment, including hedges of foreign currency exposure. 
Cash flow hedges represent the hedge of a forecasted 
transaction or the variability of cash flows to be paid or received 
related to a recognized asset or liability. 

Economic hedges and customer accommodation trading 
and other derivatives do not qualify for, or we have elected not to 
apply, hedge accounting. Economic hedges are derivatives we use 
to manage interest rate, foreign currency and certain other risks 
associated with our non-trading activities. Customer 
accommodation trading and other derivatives primarily 
represents derivatives related to our trading business activities. 
We report changes in the fair values of these derivatives in 
noninterest income. 

FAIR VALUE HEDGES We record changes in the fair value of the 
derivative in 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 earnings. 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 

• 

• 

136 

Wells Fargo & Company 

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 
denominated AFS debt securities and long-term debt liabilities 
hedged with cross-currency swaps. The change in fair value of 
these swaps attributable to cross-currency basis spread changes 
is excluded from the assessment of hedge effectiveness. The 
initial fair value of the excluded component is amortized to net 
interest income and the difference between changes in fair value 
of the excluded component and the amount recorded in earnings 
is recorded in OCI. 

CASH FLOW HEDGES  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 earnings in the 
same period(s) that the hedged transaction affects earnings and 
in the same income statement category as the hedged item. For 
cash flow hedges of interest rate risk associated with floating-
rate commercial loans and long-term debt, these amounts are 
reflected in net interest income. For cash flow hedges of foreign 
currency risk associated with fixed-rate long-term debt, these 
amounts are reflected in net interest income. The entire gain or 
loss on these derivatives is included in the assessment of hedge 
effectiveness. 

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 a 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. 

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. The 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. For example, for financial 
debt instruments such as AFS debt securities, loans or long-term 
debt, these amounts are amortized into net interest income over 
the remaining life of the asset or liability similar to other 
amortized cost basis adjustments. If the hedged item is 
derecognized, the accumulated amounts reported in OCI are 
immediately reclassified to net interest 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 earnings at which point the related OCI amount is 
reclassified to net interest 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 
noninterest 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 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 earnings, 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 hybrid 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 noninterest income and 
reported within the balance sheet as a derivative asset or liability. 
The accounting for the remaining host contract is the same as 
other assets and liabilities of a similar type and reported within 
the balance sheet based upon the accounting classification of the 
instrument. 

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 

Wells Fargo & Company 

137 

  
Note 1:  Summary of Significant Accounting Policies (continued) 

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. We 
incorporate adjustments to reflect counterparty credit risk 
(credit valuation adjustments (CVA)) in determining the fair 
value of our derivatives. CVA, which considers the effects of 
enforceable master netting agreements and collateral 
arrangements, reflects market-based views of the credit quality 
of each counterparty. We estimate CVA based on observed credit 
spreads in the credit default swap market and indices indicative 
of the credit quality of the counterparties to our derivatives. 
Cash collateral exchanged related to our interest rate 
derivatives, and certain commodity and equity derivatives, with 
centrally cleared counterparties is recorded as a reduction of the 
derivative fair value asset and liability balances, as opposed to 
separate non-derivative receivables or payables. This cash 
collateral, also referred to as variation margin, is exchanged 
based upon derivative fair value changes, typically on a one-day 
lag. For additional information on our derivatives and hedging 
activities, see Note 18 (Derivatives). 

Equity Securities 
Equity securities exclude investments that represent a 
controlling interest in the investee. 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 net gains 
(losses) on equity securities within noninterest income. Realized 
and unrealized gains and losses from marketable equity 
securities related to our trading activity are recognized in net 
gains from trading activities. The remaining marketable equity 
securities realized and unrealized gains and losses are recognized 
in net gains from equity securities. Dividend income from 
marketable equity securities is recognized in interest income. 
Nonmarketable equity securities do not have readily 
determinable fair values. 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 noninterest income; 
Equity method: This method is applied when we have the 
ability to exert significant influence over the investee. These 
securities are carried at cost and adjusted for our share of 
the investee’s earnings or losses, less any dividends received 
and/or 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 amortized cost 
less any impairments. 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 initially carried at amortized cost and are remeasured to 
fair value as of the date of an orderly observable transaction 
of the same or similar security of the same issuer. These 
securities are also adjusted for any impairments. 

Equity method adjustments for our share of the investee’s 
earnings or losses are recognized in other noninterest income. All 
other realized and unrealized gains and losses, including 
impairment losses, from nonmarketable equity securities are 
recognized in net gains from equity securities. Dividends from 

equity method securities are recognized as a reduction of the 
investment carrying value. Dividend income from all other 
nonmarketable equity securities is recognized in interest income. 
Our review for impairment for equity method, cost method 

and measurement alternative securities 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. 

Pension Accounting 
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. We also sponsor nonqualified defined benefit plans 
that provide supplemental defined benefit pension benefits to 
certain eligible employees. 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, 2019, is 19 years. See Note 23 (Employee 
Benefits and Other Expenses) for additional information on our 
pension accounting. 

138 

Wells Fargo & Company 

Income Taxes 
We file consolidated and separate company U.S. federal income 
tax returns, non-U.S. 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. 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. 

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 basis of 
assets and liabilities, and enacted changes in tax rates and laws 
are recognized in the period in which they occur. Deferred tax 
assets are recognized subject to management’s judgment that 
realization is more likely than not. 

See Note 24 (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 21 (Common Stock and Stock Plans). Our 
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. 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 recognized in commission and 
incentive compensation in our income statement normally over 
the vesting period of the award; awards with graded vesting are 
expensed on a straight-line method. Awards to team members 
who are retirement eligible at the grant date are subject to 
immediate expensing upon grant. Awards to team members who 
become retirement eligible before the final vesting date are 
expensed between the grant date and the date the team 
member becomes retirement eligible. Except for retirement and 
other limited circumstances, RSRs are canceled when 
employment ends. 

Beginning in 2013, certain RSRs and all PSAs granted 
include discretionary conditions that can result in forfeiture and 
are measured at fair value initially and subsequently until the 
discretionary conditions end. 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. The total expense that will be recognized on these 
awards cannot be finalized until the determination of the awards 
that will vest. 

Earnings Per Common Share 
We compute earnings per common share by dividing net income 
applicable to common stock (net income less dividends on 
preferred stock and the excess of consideration transferred over 
carrying value of preferred stock redeemed, if any) by the 
average number of common shares outstanding during the 
period. We compute diluted earnings per common share using 
net income applicable to common stock and adding the effect of 
common stock equivalents (e.g., stock options, restricted share 
rights, convertible debentures and warrants) that are dilutive to 
the average number of common shares outstanding during the 
period. 

Fair Value of Assets and Liabilities 
Fair value is defined as 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. Fair 
value is based on the exit price notion while maximizing the use 
of observable inputs and minimizing the use of unobservable 
inputs. 

We measure our assets and liabilities at fair value when we 
are required to record them at fair value, when we have elected 
the fair value option, and to fulfill fair value disclosure 
requirements. Assets and liabilities are recorded at fair value on a 
recurring or nonrecurring basis. Assets and liabilities that are 
recorded at fair value on a recurring basis require a fair value 
measurement at each reporting period. Those that are recorded 
at fair value on a nonrecurring basis are adjusted to fair value 
only as required through the application of an accounting 
method such as LOCOM, the measurement alternative, or write-
downs of individual assets. Measurements of fair value prioritize 
observable inputs, where available. 

We classify our assets and liabilities measured at fair value 

based upon a three-level hierarchy that assigns the highest 
priority to unadjusted quoted prices in active markets and the 
lowest priority to unobservable inputs. The three levels are as 
follows: 
• 

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. 

• 

• 

For valuations that use several inputs, the determination of 
whether that measurement is Level 2 or Level 3 is based on the 
significance of the unobservable inputs to the entire fair value 
measurement. See Note 19 (Fair Values of Assets and Liabilities) 
for a more detailed discussion of the valuation methodologies 
that we apply to our assets and liabilities. 

Wells Fargo & Company 

139 

Note 1:  Summary of Significant Accounting Policies (continued) 

Share Repurchases 
From time to time we may enter into written repurchase plans 
pursuant to Rule 10b5-1 of the Securities Exchange Act of 1934, 
private forward repurchase contracts, or a combination of the 
two to complement our open-market common stock repurchase 
strategies. The stock repurchase transactions allow us to manage 
our share repurchases in a manner consistent with our capital 
plans submitted annually under the Comprehensive Capital 
Analysis and Review (CCAR) and to provide an economic benefit 
to the Company. 

Under a Rule 10b5-1 repurchase plan, payments and receipt 

of repurchased shares settle on the same day. Shares 
repurchased reduce the total number of outstanding shares of 
common stock upon the settlement of each trade under the 
plan. During 2019 and 2018, we repurchased approximately 
204 million and 12 million shares of our common stock, 
respectively, under Rule 10b5-1 repurchase plans. We had no 
shares repurchased under a Rule 10b5-1 repurchase plan during 
2017. 

We had no shares repurchased under private forward 
repurchase contracts in 2019. During 2018 and 2017, we 
repurchased approximately 82 million and 89 million shares of 

Table 1.2:  Supplemental Cash Flow Information 

our common stock, respectively, under these contracts. We had 
no unsettled private forward repurchase contracts at 
December 31, 2019, December 31, 2018, or December 31, 
2017. Under private forward repurchase contract transactions, 
our payments to counterparties are recognized 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 contemplate a 
fixed dollar amount available per quarter for share repurchases 
pursuant to the Board of Governors of the Federal Reserve 
System (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 contract.  

Supplemental Cash Flow Information 
Significant noncash activities are presented in Table 1.2. 

(in millions) 

Trading debt securities retained from securitization of MLHFS 

$ 

Transfers from loans to MLHFS 

Transfers from available-for-sale debt securities to held-to-maturity debt securities 

Operating lease ROU assets acquired with operating lease liabilities (1) 

2019 

40,650 

6,330 

13,833 

5,804 

Year ended December 31, 

2018 

37,265 

5,366 

16,479 

—

2017 

52,435 

5,500 

50,405 

— 

(1) 

The year ended December 31, 2019, balance includes $4.9 billion from adoption of ASU 2016-02 – Leases (Topic 842) and $904 million attributable to new leases and changes from modified leases. 

Subsequent Events 
We have evaluated the effects of events that have occurred 
subsequent to December 31, 2019, and, except as disclosed in 
Note 17 (Legal Actions), Note 20 (Preferred Stock) and Note 27 
(Operating Segments), there have been no material events that 
would require recognition in our 2019 consolidated financial 
statements or disclosure in the Notes to the consolidated 
financial statements. 

140 

Wells Fargo & Company 

 
  
 
 
Note 2:  Business Combinations 

There were no acquisitions during 2019 or 2018. As of 
December 31, 2019, we had no pending acquisitions. 

During 2019, we completed the sale of our Institutional 

Retirement and Trust (IRT) business in July and the sale of our 
Eastdil Secured (Eastdil) business in October, recognizing pre-tax 
gains within other noninterest income of $1.1 billion and 
$362 million, respectively. 

For the IRT business, we will continue to administer client 
assets at the direction of the buyer for up to 24 months from the 
closing date pursuant to a transition services agreement. The 
buyer will receive post-closing revenue from the client assets and 
will pay us a fee for certain costs that we incur to administer the 
client assets during the transition period. The transition services 
fee will be recognized as other noninterest income, and the 
expenses we incur will be recognized in the same manner as they 
were prior to the close of the sale. Transition period revenue is 
expected to approximate transition period expenses and is 
subject to downward adjustment as client assets transition to 
the buyer’s platform. No IRT client assets were transitioned to 
the buyer’s platform as of December 31, 2019. At December 31, 
2019, we had assets under management (AUM) and assets under 
administration (AUA) associated with the IRT business of 
$21 billion and $915 billion, respectively. 

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. 

Wells Fargo & Company 

141 

 
 
Note 3:  Cash, Loan and Dividend Restrictions 

Cash and cash equivalents may be restricted as to usage or 
withdrawal. 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, 
2019 

Average required reserve balance for FRB (1) 

$ 

11,374 

Reserve balance for non-U.S. central banks 

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 

460 

733 

300 

Dec 31, 
2018 

12,428 

517 

1,135 

147 

(1) 

FRB required reserve balance represents average for the years ended December 31, 2019, 
and December 31, 2018. 

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 ACL 
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 29 (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 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 
$5.4 billion at December 31, 2019, 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, as amended and restated on June 26, 2019, among 
Wells Fargo & Company, the parent holding company (the 
“Parent”), WFC Holdings, LLC, an intermediate holding company 
and subsidiary of the Parent (the “IHC”), Wells Fargo Bank, N.A., 
Wells Fargo Securities, LLC, Wells Fargo Clearing Services, LLC, 
and certain other direct and indirect subsidiaries of the Parent 
designated as material entities for resolution planning purposes 
or identified as related support entities in our resolution plan, the 
IHC may be restricted from making dividend payments to the 
Parent if certain liquidity and/or capital metrics fall below defined 
triggers, or if the Parent’s board of directors authorizes it to file a 
case under the U.S. Bankruptcy Code. Based on retained earnings 
at December 31, 2019, our nonbank subsidiaries could have 
declared additional dividends of $25.9 billion at December 31, 
2019, without obtaining prior regulatory 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 
repurchase or redemption of common or perpetual preferred 
stock as well as to raise the per share quarterly dividend from its 
current level of $0.51 per share as declared by the Company’s 
Board of Directors (Board) on January 28, 2020, payable on 
March 1, 2020. 

142 

Wells Fargo & Company 

  
 
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 Assets 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, 
2019 

Dec 31, 
2018 

$ 

$ 

79,733 

27,440 

972 

34,825 

(21,463) 

13,362 

121,507 

17,430 

33,861 

(26,074) 

7,787 

25,217 

69,989 

19,449 

1,469 

29,216 

(19,807) 

9,409 

100,316 

19,720 

28,717 

(21,178) 

7,539 

27,259 

(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. Net interest income also includes dividend income on 
trading securities and dividend expense on trading securities we 
have sold, but not yet purchased. 

Table 4.2:  Net Interest Income and Net Gains (Losses) on Trading Activities 

Year ended December 31, 

(in millions) 

Interest income: 

Debt securities 

Equity securities 

Loans held for sale 

Total interest income 

Less: Interest expense 

Net interest income 

Net gains (losses) from trading activities (1): 

Debt securities 

Equity securities 

Loans held for sale 

Derivatives (2) 

Total net gains from trading activities 

Total trading-related net interest and noninterest income 

2019 

3,130 

579 

78 

3,787 

525 

3,262 

1,053 

4,795 

12 

(4,867) 

993 

4,255 

$ 

$ 

2018 

2,831 

587 

62 

3,480 

587 

2,893 

(824) 

(4,240) 

(1) 

5,667 

602 

3,495 

2017 

2,313 

515 

38 

2,866 

416 

2,450 

125 

3,394 

45 

(3,022) 

542 

2,992 

(1) 
(2) 

Represents realized gains (losses) from our trading activities and unrealized gains (losses) due to changes in fair value of our trading positions. 
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. 

Wells Fargo & Company 

143 

 
  
 
 
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). 

Table 5.1:  Amortized Cost and Fair Value 

(in millions)

December 31, 2019 

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 

Other (2) 

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 (3) 

Other debt securities 

Total held-to-maturity debt securities 

Total (4) 

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 

Other (2) 

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 (3) 

Other debt securities 

Total held-to-maturity debt securities 

Total (4) 

 Amortized cost 

Gross 
unrealized gains 

Gross 
unrealized losses 

Fair value 

$ 

$ 

$ 

$ 

14,948 
39,381 

160,318 

814 
3,899 

165,031 

6,343 

29,693 

4,664 

260,060 

45,541 

13,486 

94,869 

37 

153,933 

413,993 

13,451 

48,994 

155,974 

2,638 

4,207 

162,819 

6,230 

35,581 

5,396 

272,471 

44,751 

6,286 

93,685 

66 

144,788 

417,259 

13 
992 

2,299 

14 
41 

2,354 

252 

125 

50 

3,786 

617 

286 

2,093 

— 

2,996 

6,782 

3 

716 

369 

142 

40 

551 

131 

158 

100 

1,659 

4 

30 

112 

— 

146 

1,805 

(1) 
(36) 

(164) 

(1) 
(6) 

(171) 

(32) 

(123) 

(24) 

(387) 

(19) 

(13) 

(37) 

— 

(69) 

(456) 

(106) 

(446) 

(3,140) 

(5) 

(22) 

(3,167) 

(90) 

(396) 

(13) 

(4,218) 

(415) 

(116) 

(2,288) 

— 

(2,819) 

(7,037) 

14,960 
40,337 

162,453 

827 
3,934 

167,214 

6,563 

29,695 

4,690 

263,459 

46,139 

13,759 

96,925 

37 

156,860 

420,319 

13,348 

49,264 

153,203 

2,775 

4,225 

160,203 

6,271 

35,343 

5,483 

269,912 

44,340 

6,200 

91,509 

66 

142,115 

412,027 

(1) 

Includes investments in tax-exempt preferred debt securities issued by investment funds or trusts that predominantly invest in tax-exempt municipal securities. The amortized cost and fair value of 
these types of securities was $5.8 billion each at December 31, 2019, and $6.3 billion each at December 31, 2018. 
Largely includes asset-backed securities collateralized by student loans. 
Predominantly consists of federal agency mortgage-backed securities at both December 31, 2019, and December 31, 2018. 

(2) 
(3) 
(4)  We held debt securities from Federal National Mortgage Association (FNMA) and Federal Home Loan Mortgage Corporation (FHLMC) that each exceeded 10% of shareholders’ equity, with an 

amortized cost of $112.1 billion and $89.9 billion and a fair value of $114.0 billion and $91.4 billion at December 31, 2019, and an amortized cost of $99.0 billion and $95.0 billion and a fair value of 
$97.6 billion and $93.0 billion at December 31, 2018, respectively. 

144 

Wells Fargo & Company 

  
 
 
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, 2019 

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 

Total held-to-maturity debt securities 

Total 

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 

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 
 Total held-to-maturity debt securities 

Less than 12 months 

12 months or more 

Total 

Gross 
unrealized 
losses 

Fair value 

Gross 
unrealized 
losses 

Fair value 

Gross 
unrealized 
losses 

Fair value 

$ 

$ 

$ 

— 
(10) 

(50) 
(1) 
(3) 
(54) 

(9) 

(13) 
(12) 
(98) 

(19) 
(9) 
(35) 

(63) 

— 
2,776 

16,807 
149 
998 
17,954 

303 

5,070 
1,587 
27,690 

989 
613 
5,825 

7,427 

(1) 
(26) 

(114) 
— 
(3) 
(117) 

(23) 

(110) 
(12) 
(289) 

— 
(4) 
(2) 

(6) 

2,423 
2,418 

10,641 
— 
244 
10,885 

216 

16,789 
492 
33,223 

— 
57 
31 

88 

(1) 
(36) 

(164) 
(1) 
(6) 
(171) 

(32) 

(123) 
(24) 
(387) 

(19) 
(13) 
(37) 

(69) 

2,423 
5,194 

27,448 
149 
1,242 
28,839 

519 

21,859 
2,079 
60,913 

989 
670 
5,856 

7,515 

(161) 

35,117 

(295) 

33,311 

(456) 

68,428 

(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) 

(26) 

(8) 
(6) 
(3,620) 

(412) 
(112) 
(2,283) 
(2,807) 

112,252 
69 
79 
112,400 

298 

553 
159 
128,631 

41,083 
3,992 
77,741 
122,816 

(3,140) 
(5) 
(22) 
(3,167) 

123,231 
467 
2,051 
125,749 

(90) 

2,263 

(396) 
(13) 
(4,218) 

28,859 
978 
183,314 

(415) 
(116) 
(2,288) 
(2,819) 

41,978 
4,590 
82,376
128,944 

Total 

$ 

(610) 

60,811 

(6,427) 

251,447 

(7,037) 

312,258 

Wells Fargo & Company 

145 

  
 
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. 

146 

Wells Fargo & Company 

 
 
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 $7 million and $2.2 billion, 
respectively, at December 31, 2019, and $20 million and 
$5.2 billion, respectively, at December 31, 2018. 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 

(in millions) 

December 31, 2019 

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 

Total held-to-maturity debt securities 

Total 

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 

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 

Total held-to-maturity debt securities 

Total 

Investment grade 

Non-investment grade 

Gross 
unrealized losses 

Fair value 

Gross 
unrealized losses 

Fair value 

$ 

$ 

$ 

$ 

(1) 

(32) 

(164) 

(1) 

(3) 

(168) 

(3) 

(123) 

(13) 

(340) 

(19) 

(13) 

(25) 

(57) 

(397) 

(106) 

(425) 

2,423 

5,019 

27,448 

149 

1,158 

28,755 

155 

21,859 

1,499 

59,710 

989 

670 

5,428 

7,087 

66,797 

6,702 

18,447 

(3,140) 

123,231 

(2) 

(20) 

(3,162) 

(17) 

(396) 

(7) 

(4,113) 

(415) 

(116) 

(2,278) 

(2,809) 

(6,922) 

295 

1,999 

125,525 

791 

28,859 

726 

181,050 

41,978 

4,590 

81,977 

128,545 

309,595 

— 

(4) 

— 

— 

(3) 

(3) 

(29) 

— 

(11) 

(47) 

— 

— 

(12) 

(12) 

(59) 

— 

(21) 

— 

(3) 

(2) 

(5) 

(73) 

— 

(6) 

(105) 

— 

— 

(10) 

(10) 

(115) 

— 

175 

— 

— 

84 

84 

364 

— 

580 

1,203 

— 

— 

428 

428 

1,631 

— 

316 

— 

172 

52 

224 

1,472 

— 

252 

2,264 

— 

— 

399 

399 

2,663 

Wells Fargo & Company 

147 

  
 
 
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:  Available-for-Sale Debt Securities – Fair Value by Contractual Maturity 

(in millions) 

December 31, 2019 

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 

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 

14,960 

40,337 

162,453 

827 

3,934 

167,214 

6,563 

29,695 

4,690 

1.96%  $ 

4.82 

3.43 

2.78 

3.44 

3.43 

4.83 

3.33 

2.57 

9,980 

2,687 

1.88%  $ 

2.91 

4,674 

3,208 

2.12%  $ 

46 

1.83%  $ 

260 

3.31 

4,245 

3.21 

30,197 

2.25% 

5.38 

— 

— 

— 

— 

460 

— 

35 

— 

— 

— 

— 

5.37 

— 

4.16 

152 

— 

31 

183 

2,251 

— 

687 

3.40 

— 

4.03 

3.51 

4.93 

— 

3.15 

1,326 

— 

235 

1,561 

3,070 

12,137 

1,408 

2.52 

— 

3.22 

2.62 

4.64 

3.43 

1.80 

160,975 

827 

3,668 

165,470 

782 

17,558 

2,560 

3.44 

2.78 

3.45 

3.43 

4.98 

3.27 

2.81 

$ 

263,459 

3.57%  $ 

13,162 

2.22%  $ 

11,003 

3.12%  $ 

22,467 

3.39%  $  216,827 

3.69% 

(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. 

Table 5.5 shows the amortized cost and weighted-average 

yields of held-to-maturity debt securities by contractual 
maturity. 

Table 5.5:  Held-to-Maturity Debt Securities – Amortized Cost by Contractual Maturity 

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 

(in millions) 

December 31, 2019 

Held-to-maturity debt securities (1): 

Amortized cost: 

Securities of U.S. Treasury and federal agencies 

$ 

45,541 

2.12%  $ 

1,296 

1.75%  $  42,242 

2.13%  $ 

1,244 

2.00%  $ 

759 

2.33% 

Securities of U.S. states and political subdivisions 

Federal agency and other mortgage-backed securities 

Other debt securities 

13,486 

94,869 

37 

4.89 

3.08 

3.18 

— 

— 

— 

— 

— 

— 

87 

15 

— 

5.95 

3.10 

— 

1,866 

— 

37 

4.80 

— 

3.18 

11,533 

94,854 

— 

4.90 

3.08 

— 

Total held-to-maturity debt securities at amortized 

cost 

$  153,933 

2.95%  $ 

1,296 

1.75%  $  42,344 

2.14%  $ 

3,147 

3.68%  $  107,146 

3.27% 

(1)  Weighted-average yields displayed by maturity bucket are weighted based on amortized cost and predominantly represent contractual coupon rates. 

148 

Wells Fargo & Company 

  
 
  
 
 
Table 5.6 shows the fair value of held-to-maturity debt 

securities by contractual maturity. 

Table 5.6:  Held-to-Maturity Debt Securities – Fair Value by Contractual Maturity 

(in millions) 

December 31, 2019 

Held-to-maturity debt securities: 

Fair value: 

Total 

amount 

Within 
one year 

Amount 

After one year 
through five years 

After five years 
through ten years 

Amount 

Amount 

After ten years 

Amount 

Remaining contractual maturity 

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 

46,139 

13,759 

96,925 

37 

1,301 

42,830 

— 

— 

— 

87 

15 

— 

Total held-to-maturity debt securities at fair value 

$ 

156,860 

1,301 

42,932 

1,268 

1,940 

— 

37 

3,245 

740 

11,732 

96,910 

— 

109,382 

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 

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, 2019, 2018 or 2017. 

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 

$ 

Year ended December 31, 

2019 

2018 

2017 

$ 

227 

(24) 

(63) 

$ 

140 

155 

(19) 

(28) 

108 

948 

(207) 

(262) 

479 

Year ended December 31, 

2019 

2018 

2017 

$ 

33 

— 

17 

13 

— 

63 

2 

4 

18 

— 

4 

28 

150 

11 

80 

21 

— 

262 

Wells Fargo & Company 

149 

  
 
  
 
  
 
 
Note 5:  Available-for-Sale and Held-to-Maturity Debt Securities (continued) 

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 

Other debt securities 

Total changes to OCI for non-credit-related OTTI 

Total OTTI losses recorded on debt securities 

Year ended December 31, 

2019 

2018 

2017 

$ 

27 

36 

63 

(1) 

(1) 

2 

1 

1 

$ 

64 

27 

1 

28 

(2) 

2 

(11) 

— 

(11) 

17 

119 

143 

262 

(5) 

(1) 

(51) 

— 

(57) 

205 

(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. 

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. We have not 
recognized OTTI on held-to-maturity debt securities we still 

own. Recognized credit loss represents the difference between 
the present value of expected 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. 

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 

Year ended December 31, 

2019 

$ 

562 

2018 

742 

2017 

1,043 

6 

21 

27 

(390) 

— 

(390) 

$ 

199 

1

26 

27 

(204) 

(3) 

(207) 

562 

9 

110 

119 

(414) 

(6) 

(420) 

742 

(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. 

150 

Wells Fargo & Company 

  
 
  
 
 
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 
unearned income, net deferred loan fees or costs, and 
unamortized discounts and premiums. These amounts were less 
than 1% of our total loans outstanding at December 31, 2019, 
and December 31, 2018. 

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 non-U.S. loans are reported by respective class of 
financing receivable in the table above. Substantially all of our 
non-U.S. loan portfolio is commercial loans. Table 6.2 presents 
total non-U.S. commercial loans outstanding by class of financing 
receivable. 

Table 6.2:  Non-U.S. Commercial Loans Outstanding 

2019 

2018 

2017 

2016 

2015 

December 31, 

$ 

354,125 

121,824 

19,939 

19,831 

515,719 

350,199 

121,014 

22,496 

19,696 

333,125 

126,599 

24,279 

19,385 

330,840 

132,491 

23,916 

19,289 

299,892 

122,160 

22,164 

12,367 

513,405 

503,388 

506,536 

456,583 

293,847 

285,065 

284,054 

275,579 

273,869 

29,509 

41,013 

47,873 

34,304 

446,546 

$ 

962,265 

34,398 

39,025 

45,069 

36,148 

439,705 

953,110 

39,713 

37,976 

53,371 

38,268 

453,382 

956,770 

46,237 

36,700 

62,286 

40,266 

461,068 

967,604 

53,004 

34,039 

59,966 

39,098 

459,976 

916,559 

(in millions) 

Non-U.S. commercial loans: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

2019 

2018 

2017 

2016 

2015 

December 31, 

$ 

70,494 

62,564 

60,106 

7,004 

1,434 

1,220 

6,731 

1,011 

1,159 

8,033 

655 

1,126 

55,396 

8,541 

375 

972 

49,049 

8,350 

444 

274 

Total non-U.S. commercial loans 

$ 

80,152 

71,465 

69,920 

65,284 

58,117 

Wells Fargo & Company 

151 

 
  
 
  
 
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

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. 
Commercial and industrial loans and lease financing to borrowers 
in the financial institutions except banks industry represented 
12% and 11% of total loans at December 31, 2019 and 2018, 
respectively. At December 31, 2019 and 2018, we did not have 
concentrations representing 10% or more of our total loan 
portfolio in the commercial real estate (CRE) portfolios (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 13% and 12% of 
total loans at December 31, 2019 and 2018, respectively, 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 mortgage loans include 

an interest-only feature as part of the loan terms. These interest-
only loans were approximately 3% and 4% of total loans at 
December 31, 2019 and 2018, respectively. 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 with a majority of the 
portfolio 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, 2019, these option payment loans 
were less than 1% of total loans. 

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, 2019, our lines of credit portfolio had an 
outstanding balance of $37.9 billion, of which $9.1 billion, or 
24%, is in its amortization period, another $1.6 billion, or 4%, of 
our total outstanding balance, will reach their end of draw period 
during 2020 through 2021, $11.1 billion, or 29%, during 2022 
through 2024, and $16.1 billion, or 43%, will convert in 
subsequent years. This portfolio had unfunded credit 
commitments of $58.9 billion at December 31, 2019. 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, 2019, $399 million, or 4%, of 
outstanding lines of credit that are in their amortization period 
were 30 or more days past due, compared with $488 million, or 
2%, for lines in their draw period. We have considered this 
increased inherent risk in our ACL 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. The table excludes PCI 
loans, loans for which we have elected the fair value option, and 
government insured/guaranteed real estate 1-4 family first 
mortgage loans because their loan activity normally does not 
impact the ACL. 

(in millions) 

Purchases 

Sales 

Transfers to MLHFS/LHFS 

$ 

Commercial 

Consumer 

2,028 

(1,797) 

(123) 

3,126 

(530) 

(1,889) 

Year ended December 31, 

2019 

Total 

5,154 

(2,327) 

(2,012) 

Commercial 

Consumer 

2,065 

(1,905) 

(617) 

16 

(261) 

(1,995) 

2018 

Total 

2,081 

(2,166) 

(2,612) 

152 

Wells Fargo & Company 

 
  
 
 
Commitments to Lend 
A commitment to lend is a legally binding agreement to lend 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. The 
unfunded amount of these temporary advance arrangements 
totaled approximately $75.4 billion at December 31, 2019. 

We issue commercial letters of credit to assist customers in 
purchasing goods or services, typically for international trade. At 
December 31, 2019 and 2018, we had $862 million and 
$919 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 16 (Guarantees, 
Pledged Assets and Collateral, and Other Commitments) for 
additional information on standby letters of credit. 

When we enter into 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 not funded. 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: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Total commercial 

Consumer: 

Dec 31, 
2019 

Dec 31, 
2018 

$  346,991 

330,492 

8,206 

17,729 

6,984 

16,400 

372,926 

353,876 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Credit card 

Other revolving credit and installment 

Total consumer 

34,391 

36,916 

114,933 

25,898 

212,138 

Total unfunded credit commitments 

$  585,064 

29,736 

37,719 

109,840 

27,530 

204,825 

558,701 

Wells Fargo & Company 

153 

  
 
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

Allowance for Credit Losses 
Table 6.5 presents the ACL, 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: 

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 

2019 

$ 

10,707 

2,687 

(147) 

(802) 

(38) 

(1) 

(70) 

(911) 

(129) 

(118) 

(1,714) 

(647) 

(674) 

(3,282) 

(4,193) 

195 

32 

13 

19 

259 

179 

184 

344 

341 

124 

Year ended December 31, 

2018 

11,960 

1,744 

(166) 

(727) 

(42) 

— 

(70) 

(839) 

(179) 

(179) 

(1,599) 

(947) 

(685) 

(3,589) 

(4,428) 

304 

70 

13 

23

410 

267 

219 

307 

363 

118 

2017 

12,540 

2,528 

(186) 

(789) 

(38) 

— 

(45) 

(872) 

(240) 

(279) 

(1,481) 

(1,002) 

(713) 

(3,715) 

(4,587) 

297 

82 

30 

17

426 

288 

266 

239 

319 

121 

2016 

12,512 

3,770 

(205) 

(1,419) 

(27) 

(1) 

(41) 

(1,488) 

(452) 

(495) 

(1,259) 

(845) 

(708) 

(3,759) 

(5,247) 

263 

116 

38

11 

428 

373 

266 

207 

325 

128 

2015 

13,169 

2,442 

(198) 

(734) 

(59) 

(4) 

(14) 

(811) 

(507) 

(635) 

(1,116) 

(742) 

(643) 

(3,643) 

(4,454) 

252 

127 

37 

8 

424 

245 

259 

175 

325 

134 

1,172 

1,431 

(2,762) 

(29) 

1,274 

1,684 

1,233 

1,659 

1,299 

1,727 

1,138 

1,562 

(2,744) 

(2,928) 

(3,520) 

(2,892) 

(87) 

6 

(17) 

(9) 

$ 

10,456 

10,707 

11,960 

12,540 

12,512 

$ 

9,551 

905 

$ 

10,456 

0.29% 

0.99 

1.09 

9,775 

932 

10,707 

0.29 

1.03 

1.12 

11,004 

956 

11,960 

0.31 

1.15 

1.25 

11,419 

1,121 

12,540 

0.37 

1.18 

1.30 

11,545 

967 

12,512 

0.33 

1.26 

1.37 

(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. 

154 

Wells Fargo & Company 

  
 
 
Table 6.6 summarizes the activity in the ACL by our 

commercial and consumer portfolio segments. 

Table 6.6:  Allowance for Credit Losses Activity by Portfolio Segment 

(in millions) 

Balance, beginning of year 

Provision for credit losses 

Interest income on certain impaired loans 

Loan charge-offs 

Loan recoveries 

Net loan charge-offs 

Other 

Balance, end of year 

Commercial 

Consumer 

$ 

6,417 

518 

(46) 

(911) 

259 

(652) 

8 

4,290 

2,169 

(101) 

(3,282) 

1,172 

(2,110) 

(37) 

Year ended December 31, 

2019 

Total 

10,707 

2,687 

(147) 

(4,193) 

1,431 

(2,762) 

(29) 

Commercial 

Consumer 

6,632 

281 

(47) 

(839) 

410 

(429) 

(20) 

5,328 

1,463 

(119) 

(3,589) 

1,274 

(2,315) 

(67) 

2018 

Total 

11,960 

1,744 

(166) 

(4,428) 

1,684 

(2,744) 

(87) 

$ 

6,245 

4,211 

10,456 

6,417 

4,290 

10,707 

Table 6.7 disaggregates our ACL and recorded investment in 

loans by impairment methodology. 

Table 6.7:  Allowance for Credit Losses by Impairment Methodology 

(in millions) 

December 31, 2019 

Collectively evaluated (1) 

Individually evaluated (2) 

PCI (3) 

Total 

December 31, 2018 

Collectively evaluated (1) 

Individually evaluated (2) 

PCI (3) 

Total 

Allowance for credit losses 

Recorded investment in loans 

Commercial 

Consumer 

Total 

Commercial 

Consumer 

Total 

$ 

$ 

$ 

$ 

5,778 

3,364 

467 

— 

847 

— 

9,142 

1,314 

— 

512,586 

436,081 

948,667 

3,133 

— 

9,897 

568 

13,030 

568 

6,245 

4,211 

10,456 

515,719 

446,546 

962,265 

5,903 

514 

— 

3,361 

929 

— 

9,264 

1,443 

— 

510,180 

421,574 

931,754 

3,221 

4 

13,126 

5,005 

16,347 

5,009 

6,417 

4,290 

10,707 

513,405 

439,705 

953,110 

(1) 
(2) 
(3) 

Represents non-impaired loans evaluated collectively for impairment. 
Represents impaired loans evaluated individually for impairment. 
Represents the allowance for loan losses and related loan carrying value 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 ACL. 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, 2019. 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. 

Wells Fargo & Company 

155 

  
 
  
 
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

Table 6.8:  Commercial Loans by Risk Category 

(in millions) 

December 31, 2019 

By risk category: 

Pass 

Criticized 

Total commercial loans (excluding PCI) 

Total commercial PCI loans (carrying value) 

$ 

338,740 

15,385 

354,125 

— 

118,054 

3,770 

121,824 

— 

Total commercial loans 

$ 

354,125 

121,824 

December 31, 2018 

By risk category: 

Pass 

Criticized 

Total commercial loans (excluding PCI) 

Total commercial PCI loans (carrying value) 

$ 

335,412 

14,783 

350,195 

4 

116,514 

4,500 

121,014 

— 

Total commercial loans 

$ 

350,199 

121,014 

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 

Commercial and 
industrial 

Real estate 
mortgage 

Real estate 
construction 

Lease financing 

Total 

19,752 

187 

19,939 

— 

19,939 

22,207 

289 

22,496 

— 

22,496 

18,655 

1,176 

19,831 

— 

19,831 

18,671 

1,025 

19,696 

— 

19,696 

495,201 

20,518 

515,719 

— 

515,719 

492,804 

20,597 

513,401 

4 

513,405 

(in millions) 

December 31, 2019 

By delinquency status: 

Commercial and 
industrial 

Real estate 
mortgage 

Real estate 
construction 

Lease financing 

Total 

Current-29 days past due (DPD) and still accruing 

$ 

352,110 

120,967 

19,845 

19,484 

512,406 

30-89 DPD and still accruing 

90+ DPD and still accruing 

Nonaccrual loans 

Total commercial loans (excluding PCI) 

Total commercial PCI loans (carrying value) 

423 

47 

1,545 

253 

31 

573 

354,125 

121,824 

— 

— 

Total commercial loans 

$ 

354,125 

121,824 

53 

— 

41 

19,939 

— 

19,939 

252 

— 

95 

19,831 

— 

19,831 

981 

78 

2,254 

515,719 

— 

515,719 

December 31, 2018 

By delinquency status: 

Current-29 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 

Total commercial loans (excluding PCI) 

Total commercial PCI loans (carrying value) 

508 

43 

1,486 

207 

51 

580 

350,195 

121,014 

4 

— 

Total commercial loans 

$ 

350,199 

121,014 

53 

— 

32 

22,496 

— 

22,496 

163 

— 

90 

19,696 

— 

19,696 

931 

94 

2,188 

513,401 

4 

513,405 

156 

Wells Fargo & Company 

  
 
  
 
 
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 ACL for the consumer portfolio 
segment. 

Table 6.10:  Consumer Loans by Delinquency Status 

Many of our loss estimation techniques used for the ACL 

rely on delinquency-based models; therefore, delinquency is an 
important indicator of credit quality and the establishment of 
our ACL. Table 6.10 provides the outstanding balances of our 
consumer portfolio by delinquency status. 

(in millions) 

December 31, 2019 

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 

$ 

279,722 

28,870 

39,935 

46,650 

33,981 

429,158 

1,136 

404 

197 

160 

503 

10,999 

171 

216 

115 

69 

71 

155 

— 

— 

311 

221 

202 

343 

1 

— 

— 

882 

263 

77 

1 

— 

— 

— 

140 

81 

74 

18 

10 

— 

— 

2,685 

1,084 

619 

593 

669 

10,999 

171 

Total consumer loans (excluding PCI) 

293,292 

29,496 

41,013 

47,873 

34,304 

445,978 

Total consumer PCI loans (carrying value) (2) 

555 

13 

— 

— 

— 

568 

Total consumer loans 

$ 

293,847 

29,509 

41,013 

47,873 

34,304 

446,546 

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 

Total consumer loans (excluding PCI) 

Total consumer PCI loans (carrying value) (2) 

$ 

263,881 

33,644 

38,008 

1,411 

549 

257 

225 

822 

12,688 

244 

280,077 

4,988 

247 

126 

74 

77 

213 

— 

— 

292 

212 

192 

320 

1 

— 

— 

43,604 

1,040 

314 

109 

2 

— 

— 

— 

35,794 

414,931 

140 

87 

80 

27 

20 

— 

— 

3,130 

1,288 

712 

651 

1,056 

12,688 

244 

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 

(1) 

(2) 

Represents loans whose repayments are predominantly insured by the Federal Housing Administration (FHA) or guaranteed by the Department of Veterans Affairs (VA). Loans insured/guaranteed by 
the FHA/VA and 90+ DPD totaled $6.4 billion at December 31, 2019, compared with $7.7 billion at December 31, 2018. 
26% of the adjusted unpaid principal balance for consumer PCI loans are 30+ DPD at December 31, 2019, compared with 18% at December 31, 2018. 

Of the $1.9 billion of consumer loans not government 

insured/guaranteed that are 90 days or more past due at 
December 31, 2019, $855 million was accruing, compared with 
$2.4 billion past due and $885 million accruing at December 31, 
2018. 

Wells Fargo & Company 

157 

  
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

Table 6.11 provides a breakdown of our consumer portfolio 

by FICO. Substantially all 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 $9.1 billion at 
December 31, 2019, and $8.9 billion at December 31, 2018. 

Real estate 1-4 
family first 
mortgage 

Real estate 
1-4 family junior 
lien mortgage 

Credit card 

Automobile 

Other revolving 
credit and 
installment 

Table 6.11:  Consumer Loans by FICO 

(in millions) 

December 31, 2019 

By FICO: 

< 600 

600-639 

640-679 

680-719 

720-759 

760-799 

800+ 

No FICO available 

FICO not required 

Government insured/guaranteed loans (1) 

Total consumer loans (excluding PCI) 

Total consumer PCI loans (carrying value) (2) 

$ 

3,264 

2,392 

5,068 

12,844 

27,879 

61,559 

165,460 

3,656 

— 

11,170 

293,292 

555 

Total consumer loans 

$ 

293,847 

December 31, 2018 

By FICO: 

< 600 

600-639 

640-679 

680-719 

720-759 

760-799 

800+ 

No FICO available 

FICO not required 

Government insured/guaranteed loans (1) 

Total consumer loans (excluding PCI) 

Total consumer PCI loans (carrying value) (2) 

$ 

4,273 

2,974 

5,810 

13,568 

27,258 

57,193 

151,465 

4,604 

— 

12,932 

280,077 

4,988 

Total consumer loans 

$ 

285,065 

1,164 

782 

1,499 

3,192 

4,407 

5,483 

11,851 

1,118 

— 

— 

29,496 

13 

29,509 

1,454 

994 

1,898 

3,908 

5,323 

6,315 

13,190 

1,299 

— 

— 

34,381 

17 

34,398 

3,373 

2,853 

6,626 

9,732 

8,376 

5,648 

4,037 

368 

— 

— 

41,013 

— 

41,013 

3,292 

2,777 

6,464 

9,445 

7,949 

5,227 

3,794 

77 

— 

— 

39,025 

— 

39,025 

6,041 

4,230 

6,324 

7,871 

7,839 

7,624 

7,900 

44 

— 

— 

47,873 

— 

47,873 

7,071 

4,431 

6,225 

7,354 

6,853 

5,947 

7,099 

89 

— 

— 

45,069 

— 

45,069 

Total 

14,546 

10,927 

21,247 

36,851 

52,598 

85,229 

196,833 

7,502 

9,075 

11,170 

704 

670 

1,730 

3,212 

4,097 

4,915 

7,585 

2,316 

9,075 

— 

34,304 

445,978 

— 

568 

34,304 

446,546 

697 

725 

1,822 

3,384 

4,395 

5,322 

8,411 

2,507 

8,885 

— 

36,148 

— 

36,148 

16,787 

11,901 

22,219 

37,659 

51,778 

80,004 

183,959 

8,576 

8,885 

12,932 

434,700 

5,005 

439,705 

(1) 
(2) 

Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. 
41% of the adjusted unpaid principal balance for consumer PCI loans have FICO scores less than 680 and 19% where no FICO is available to us at December 31, 2019, compared with 45% and 15%, 
respectively, at December 31, 2018. 

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 mortgage loan 
portfolios. We consider the trends in residential real estate 
markets as we monitor credit risk and establish our ACL. 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. 

158 

Wells Fargo & Company 

  
 
Table 6.12:  Consumer Loans by LTV/CLTV 

(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) 

Total consumer loans (excluding PCI) 

Total consumer PCI loans (carrying value) (3) 

December 31, 2019 

December 31, 2018 

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 

$ 

151,478 

114,795 

13,867 

860 

338 

784 

11,170 

293,292 

555 

Total 

166,081 

124,458 

17,441 

1,838 

674 

1,126 

11,170 

14,603 

9,663 

3,574 

978 

336 

342 

— 

29,496 

322,788 

13 

568 

Total 

163,419 

115,660 

17,246 

2,807 

1,062 

1,332 

12,932 

15,753 

11,183 

4,874 

1,596 

578 

397 

— 

34,381 

314,458 

17 

5,005 

34,398 

319,463 

147,666 

104,477 

12,372 

1,211 

484 

935 

12,932 

280,077 

4,988 

285,065 

Total consumer loans 

$ 

293,847 

29,509 

323,356 

(1) 
(2) 
(3) 

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. 
Represents loans whose repayments are predominantly insured by the FHA or guaranteed by the VA. 
9% of the adjusted unpaid principal balance for consumer PCI loans have LTV/CLTV amounts greater than 80% at December 31, 2019, compared with 10% at December 31, 2018. 

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 $3.5 billion and 
$4.6 billion at December 31, 2019 and 2018, respectively, which 
included $2.8 billion and $3.2 billion, respectively, of loans that 
are government insured/guaranteed. Under the Consumer 
Financial Protection Bureau guidelines, we do not commence the 
foreclosure process on real estate 1-4 family mortgage 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. 

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: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Dec 31, 
2019 

Dec 31, 
2018 

$ 

1,545 

573 

41 

95 

1,486 

580 

32 

90 

2,254 

2,188 

Real estate 1-4 family first mortgage 

2,150 

3,183 

Real estate 1-4 family junior lien mortgage 

Automobile 

Other revolving credit and installment 

Total consumer 

Total nonaccrual loans 
(excluding PCI) 

796 

106 

40 

945 

130 

50 

3,092 

4,308 

$ 

5,346 

6,496 

Wells Fargo & Company 

159 

  
  
 
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

LOANS 90 DAYS OR MORE PAST DUE AND STILL ACCRUING   Certain 
loans 90 days or more past due 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 
$102 million at December 31, 2019, and $370 million at 
December 31, 2018, are not included in these past due and still 
accruing loans even when they are 90 days or more contractually 
past due. 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 

$ 

$ 

$ 

(in millions) 

Total (excluding PCI): 

Less: FHA insured/VA guaranteed (1) 

Total, not government insured/

guaranteed 

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 

Dec 31, 
2019 

7,285 

6,352 

Dec 31, 
2018 

8,704 

7,725 

933 

979 

47 

31 

78 

112 

32 

546 

78 

87 

855 

43 

51 

94 

124 

32 

513 

114 

102 

885 

979 

Total, not government insured/

guaranteed 

$ 

933 

(1) 

Represents loans whose repayments are predominantly insured by the FHA or guaranteed 
by the VA. 

160 

Wells Fargo & Company 

 
  
 
 
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. 
Impaired loans generally have estimated losses which are 
included in the ACL. We do have impaired loans with no ACL 
when the loss content has been previously recognized through 
charge-offs, such as collateral dependent loans, or when loans 

are currently performing in accordance with their terms and no 
loss has been estimated. Impaired loans exclude PCI loans and 
loans that have been fully charged off or otherwise have zero 
recorded investment. Table 6.15 includes trial modifications that 
totaled $115 million at December 31, 2019, and $149 million at 
December 31, 2018. 

For additional information on our impaired loans and ACL, 

see Note 1 (Summary of Significant Accounting Policies). 

Table 6.15:  Impaired Loans Summary 

(in millions) 

December 31, 2019 

Commercial: 

Commercial and industrial 

Real estate mortgage 

Real estate construction 

Lease financing 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage (1) 

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, 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) 

Recorded investment 

Unpaid 
principal 
balance 

Impaired loans 

Impaired loans 
with related 
allowance for 
credit losses 

Related 
allowance for 
credit losses 

$ 

$ 

$ 

$ 

2,792 

1,137 

81 

131 

4,141 

8,107 

1,586 

520 

138 

178 

10,529 

14,670 

3,057 

1,228 

74 

146 

4,505 

12,309 

1,886 

449 

153 

162 

14,959 

19,464 

2,003 

1,903 

974 

51 

105 

803 

41 

105 

3,133 

2,852 

7,674 

1,451 

520 

81 

171 

9,897 

13,030 

2,030 

1,032 

47 

112 

3,221 

10,738 

1,694 

449 

89 

156 

13,126 

16,347 

4,433 

925 

520 

42 

155 

6,075 

8,927 

1,730 

1,009 

46 

112 

2,897 

4,420 

1,133 

449 

43 

136 

6,181 

9,078 

311 

110 

11 

35 

467 

437 

144 

209 

8 

49 

847 

1,314 

319 

154 

9 

32 

514 

525 

183 

172 

8 

41 

929 

1,443 

(1) 
(2) 

Impaired loans includes reduction of $1.7 billion reclassified to MLHFS during 2019. 
Includes the recorded investment of $1.2 billion and $1.3 billion at December 31, 2019 and 2018, respectively, of government insured/guaranteed loans that are predominantly insured by the FHA or 
guaranteed by the VA and generally do not have an ACL. Impaired loans may also have limited, if any, ACL when the recorded investment of the loan approximates estimated net realizable value as a 
result of charge-offs prior to a TDR modification. 

Wells Fargo & Company 

161 

 
  
 
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

Commitments to lend additional funds on loans whose 
terms have been modified in a TDR amounted to $500 million 
and $513 million at December 31, 2019 and 2018, 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: 

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 impaired loans (excluding PCI) 

$ 

Interest income: 

Cash basis of accounting 

Other (1) 

Total interest income 

Average 
recorded 
investment 

2019 

Recognized 
interest 
income 

Average 
recorded 
investment 

2018 

Recognized 
interest 
income 

Year ended December 31, 

Average 
recorded 
investment 

2017 

Recognized 
interest 
income 

2,287 

1,193 

60 

125 

3,665 

11,522 

1,804 

407 

86 

142 

13,961 

17,626 

2,150 

1,067 

52 

93 

3,362 

9,031 

1,586 

488 

84 

162 

11,351 

14,713 

$ 

$ 

129 

59 

6 

1 

195 

506 

99 

64 

12 

13 

694 

889 

241 

648 

889 

173 

89 

7

1

270 

664 

116 

50 

11 

10

851 

1,121 

338 

783 

1,121 

3,241 

1,328 

66

105 

4,740 

13,326 

2,041 

323 

86 

117 

15,893 

20,633 

118 

91 

14 

1 

224 

730 

121 

36 

11 

8 

906 

1,130 

299 

831 

1,130 

(1) 

Includes interest recognized on accruing TDRs, interest recognized related to certain impaired loans which have an ACL 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 are paid 
off or written-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 
$11.8 billion and $15.5 billion at December 31, 2019 and 2018, 
respectively. The majority of the decline in consumer TDRs was 
due to a reclassification of $1.7 billion in real estate 1-4 family 
first mortgage TDR loans to MLHFS. 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. 

162 

Wells Fargo & Company 

  
 
 
 
Table 6.17:  TDR Modifications 

(in millions) 

Year ended December 31, 2019 

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, 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 

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) 

$ 

$ 

$ 

$ 

$ 

$ 

13 
— 

13 

— 

26 

110 
5 

— 
8 

1 
— 

124 

150 

13 

— 

— 

— 

13 

209 

7 

— 

13 

— 

— 

229 

242 

24 

5 

— 

— 

29 

231 

25 

— 

2 

— 

— 

258 

287 

90 
38 

1 

— 

129 

13 
37 

376 
9 

51 
— 

486 

615 

29 

44 

— 

— 

73 

26 

41 

336 

16 

49 

— 

468 

541 

45 

59 

1 

— 

105 

140 

82 

257 

15 

47 

— 

541 

646 

1,286 
417 

32 

2 

1,737 

868 
82 

— 
51 

7 
13 

1,021 

2,758 

2,310 

375 

25 

63 

2,773 

1,042 

113 

— 

55 

12 

8 

1,230 

4,003 

2,912 

507 

26 

37 

3,482 

1,389 
455 

46 

2 

1,892 

991 
124 

376 
68 

59 
13 

1,631 

3,523 

2,352 

419 

25 

63 

2,859 

1,277 

161 

336 

84 

61 

8 

1,927 

4,786 

2,981 

571 

27 

37 

3,616 

1,035 

1,406 

81 

— 

67 

8 

(28) 

1,163 

4,645 

188 

257 

84 

55 

(28) 

1,962 

5,578 

104 
— 

— 

— 

104 

2 
3 

— 
29 

— 
— 

34 

0.40%  $ 
0.69 

1.00 

— 

0.49 

2.04 
2.35 

12.91 
4.86 

8.07 
— 

10.19 

138 

8.33%  $ 

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%  $ 

90 
38 

1 

— 

129 

68 
39 

376 
9 

52 
— 

544 

673 

29 

44 

— 

— 

73 

119 

45 

336 

16 

49 

— 

565 

638 

45 

59 

1 

— 

105 

257 

93 

257 

15 

47 

— 

669 

774 

(1) 

(2) 

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 $1.1 billion, $1.9 billion and $2.1 billion, for the years ended December 31, 
2019, 2018 and 2017, respectively. 
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 

(4) 

(5) 

(6) 

reduce the contractual interest rate. 
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 deferring or 
legally forgiving principal (actual or contingent) of $24 million, $28 million and $32 million for the years ended December 31, 2019, 2018 and 2017, respectively. 
Recorded investment related to interest rate reduction 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. 
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. 

Wells Fargo & Company 

163 

  
 
 
Note 6:  Loans and Allowance for Credit Losses (continued) 

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. 

Recorded investment of defaults 

Year ended December 31, 

2019 

2018 

2017 

$ 

$ 

111 

48 

17 

— 

176 

41 

13 

88 

12 

8 

162 

338 

198 

76 

36 

— 

310 

60 

14 

79 

14 

6 

173 

483 

173 

61 

4 

1 

239 

114 

19 

74 

15 

5 

227 

466 

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 
Table 6.19 presents PCI loans net of any remaining purchase 
accounting adjustments. Total consumer loans are 
predominantly Pick-a-Pay loans (real estate 1-4 family 
mortgage). 

Table 6.19:  PCI Loans 

(in millions) 

Total commercial 

Total consumer 

Total PCI loans (carrying value) 

Total PCI loans (unpaid principal balance) 

Dec 31, 
2019 

— 

568 

568 

990 

$ 

$ 

$ 

Dec 31, 
2018 

4 

5,005 

5,009 

7,348 

For the years ended December 31, 2019 and 2018, we sold 

$4.0 billion and $6.2 billion of PCI loans, respectively, that 
resulted in gains within other noninterest income of $1.6 billion 
and $2.4 billion, respectively. 

164 

Wells Fargo & Company 

  
 
  
 
 
 
 
Note 7:  Leasing Activity 

The information below provides a summary of our leasing 
activities as a lessor and lessee. 

Table 7.3 presents future lease payments owed by our 

lessees. 

As a Lessor 
Table 7.1 presents the composition of our leasing revenue and 
Table 7.2 provides the components of our investment in lease 
financing. 

Table 7.1:  Leasing Revenue 

(in millions) 

Interest income on lease financing 

Other lease revenues: 

Variable revenues on lease financing 

Fixed revenues on operating leases 

Variable revenues on operating leases 

Other lease-related revenues (1) 

Lease income 

Total leasing revenue 

Year ended 
December 31, 2019 

$ 

869 

96 

1,393 

66 

57 

1,612 

2,481 

$ 

Table 7.3:  Maturities of Lease Receivables 

(in millions) 

2020 

2021 

2022 

2023 

2024 

Thereafter 

December 31, 2019 

Direct financing
and sales- type
leases 

Operating
leases 

$ 

5,953 

4,997 

2,951 

1,634 

862 

1,717 

883 

614 

434 

298 

199 

447 

Total lease receivables 

$ 

18,114 

2,875 

As a Lessee 
Substantially all of our leases are operating leases. Table 7.4 
presents balances for our operating leases. 

(1) 

Predominantly includes net gains on disposition of assets leased under operating leases or 
lease financings. 

Table 7.4:  Operating Lease Right of Use (ROU) Assets and Lease 
Liabilities 

Table 7.2:  Investment in Lease Financing 

(in millions) 

Lease receivables 

Residual asset values 

Unearned income 

Lease financing 

Dec 31, 2019 

$ 

18,114 

4,208 

(2,491) 

$ 

19,831 

(in millions) 

ROU assets 

Lease liabilities 

Dec 31, 2019 

$ 

4,724 

5,297 

Table 7.5 provides the composition of our lease costs, which 

are predominantly included in net occupancy expense. 

Our net investment in financing and sales-type leases 
includes $1.9 billion of leveraged leases at December 31, 2019. 
As shown in Table 9.2, included in Note 9 (Premises, 
Equipment and Other Assets), we had $8.2 billion in operating 
lease assets at December 31, 2019, which was net of $3.1 billion 
of accumulated depreciation. Depreciation expense for the 
operating lease assets was $848 million in 2019. 

Table 7.5:  Lease Costs 

(in millions) 

Fixed lease expense - operating leases 

Variable lease expense 

Other (1) 

Total lease costs 

Year ended 
December 31, 2019 

$ 

$ 

1,212 

314 

(68) 

1,458 

(1) 

Predominantly includes gains recognized from sale leaseback transactions and sublease 
rental income. 

Net operating lease rental expense was $1.3 billion for the 

years 2018 and 2017 and is predominantly included in net 
occupancy expense. 

Wells Fargo & Company 

165 

  
 
  
  
 
  
 
  
 
 
Note 7: Leasing Activity (continued) 

Tables Table 7.6 and 7.7 provide the future lease payments 

under operating leases as of December 31, 2018, and 
December 31, 2019, respectively. Table 7.7 also includes 
information on the remaining average lease term and discount 
rate. 

Table 7.6:  Lease Payments on Operating Leases Prior to Adoption of 
ASU 2016-02 – Leases 

(in millions) 

December 31, 2018 

2019 

2020 

2021 

2022 

2023 

Thereafter 

Total lease payments 

$ 

$ 

1,174 

1,056 

880 

713 

577 

1,654 

6,054 

Table 7.7:  Lease Payments on Operating Leases Subsequent to 
Adoption of ASU 2016-02 – Leases 

(in millions, except for weighted averages) 

December 31, 2019 

2020 

2021 

2022 

2023 

2024 

Thereafter 

Total lease payments 

Less: imputed interest 

Total operating lease liabilities 

Weighted average remaining lease term (in years) 

Weighted average discount rate 

$ 

$ 

1,006 

1,045 

897 

750 

597 

1,672 

5,967 

670 

5,297 

7.1 

3.1% 

Our operating leases predominantly expire within the next 

15 years, with the longest lease expiring in 2105. We do not 
include renewal or termination options in the establishment of 
the lease term when we are not reasonably certain that we will 
exercise them. As of December 31, 2019, we had additional 
operating leases commitments of $159 million, predominantly 
for real estate, which leases had not yet commenced. These 
leases are expected to commence during 2020 and have lease 
terms of 2 years to 17 years. 

166 

Wells Fargo & Company 

  
 
  
 
 
 
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, 
2019 

Dec 31, 
2018 

Marketable equity securities 

$  27,440 

19,449 

Not held for trading: 

Fair value: 

Marketable equity securities (1) 

Nonmarketable equity securities 

6,481 

8,015 

4,513 

5,594 

Total equity securities at fair value 

14,496 

10,107 

Equity method: 

Low-income housing tax credit invest 

ments 

11,343 

10,999 

Private equity 

Tax-advantaged renewable energy 

New market tax credit and other 

3,459 

3,811 

387 

3,832 

3,073 

311 

Total equity method 

19,000 

18,215 

Other: 

Federal Reserve Bank stock and other 

at cost (2) 

Private equity (3) 

4,790 

2,515 

Total equity securities not held for trading 

40,801 

Total equity securities 

$  68,241 

5,643 

1,734 

35,699 

55,148 

(1) 

(2) 

(3) 

Includes $3.8 billion and $3.2 billion at December 31, 2019 and 2018, respectively, related 
to securities held as economic hedges of our deferred compensation plan obligations. 
Includes $4.8 billion and $5.6 billion at December 31, 2019 and 2018, respectively, related 
to investments in Federal Reserve Bank and Federal Home Loan Bank stock. 
Represents nonmarketable equity securities accounted for under the measurement 
alternative. 

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). 

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 account for certain 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 $1.3 billion for 2019 
and $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 
2019, 2018 and 2017, which included tax credits recorded to 
income taxes of $1.2 billion for 2019 and 2018, and $1.1 billion 
for 2017. We are periodically required to provide additional 
financial support during the investment period. A liability is 
recognized for unfunded commitments that are both legally 
binding and probable of funding. These commitments are 
predominantly funded within three years of initial investment. 
Our liability for unfunded commitments was $4.3 billion and 
$3.9 billion at December 31, 2019 and 2018, respectively. This 
liability for unfunded commitments 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. 

Wells Fargo & Company 

167 

 
 
 
Note 8:  Equity Securities (continued) 

Realized Gains and Losses Not Held for Trading 
Table 8.2 provides a summary of the net gains and losses for 
equity securities not held for trading. 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 Not Held for Trading 

(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 

Net gains (losses) from nonmarketable equity securities not carried at fair value: 

Impairment write-downs 

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 

Net losses from economic hedge derivatives (1) 

Year ended December 31, 

2019 

2018 

2017 

$ 

1,067 

2,413 

3,480 

(245) 

567 

1,161 

— 

1,483 

(2,120) 

(389) 

709 

320 

(352) 

418 

1,504 

33 

1,603 

(408) 

1,515 

967 

1,557 

2,524 

(339) 

— 

980 

97 

738 

(1,483) 

1,779 

Total net gains from equity securities not held for trading 

$ 

2,843 

(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:  Net Gains (Losses) from Measurement Alternative Equity Securities 

(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 

Table 8.4 presents cumulative carrying value adjustments to 

nonmarketable equity securities accounted for under the 
measurement alternative that were still held as of December 31, 
2019 and 2018. 

Table 8.4:  Measurement Alternative Cumulative Gains (Losses) 

(in millions) 

Cumulative gains (losses): 

Gross unrealized gains due to observable price changes 

Gross unrealized losses due to observable price changes 

Impairment write-downs 

$ 

$ 

$ 

Year ended December 31, 

2019 

584 

(17) 

(116) 

163 

614 

2018 

443 

(25) 

(33) 

274 

659 

Year ended December 31, 

2019 

973 

(42) 

(134) 

2018 

415 

(25) 

(33) 

168 

Wells Fargo & Company 

  
 
  
  
 
 
Note 9: Premises, Equipment and Other Assets 

Table 9.1:  Premises and Equipment 

Table 9.2 presents the components of other assets. 

Dec 31, 2019 

Dec 31, 2018 

Table 9.2:  Other Assets 

(in millions) 

Land 

Buildings 

Furniture and equipment 

Leasehold improvements 

Finance lease ROU assets 

$ 

1,857 

9,499 

7,189 

2,597 

33 

1,757 

8,974 

6,896 

2,387 

75 

Total premises and equipment 

21,175 

20,089 

Less: Accumulated depreciation and 

amortization 

Net book value, premises and 

equipment 

11,866 

11,169 

Foreclosed assets: 

$ 

9,309 

8,920 

Depreciation and amortization expense for premises and 
equipment was $1.4 billion, $1.3 billion and $1.2 billion in 2019, 
2018 and 2017, respectively. 

Dispositions of premises and equipment resulted in net 
gains of $82 million, $32 million and $128 million in 2019, 2018 
and 2017, respectively, included in other noninterest expense. 

(in millions) 

Corporate/bank-owned life insurance 

Accounts receivable (1) 

Interest receivable 

Customer relationship and other amortized 

intangibles 

Dec 31, 
2019 

$  20,070 

29,137 

5,586 

Dec 31, 
2018 

19,751 

34,281 

6,084 

423 

545 

Residential real estate: 

Government insured/guaranteed (1) 

Non-government insured/guaranteed 

Other 

Operating lease assets (lessor) 

Operating lease ROU assets (lessee) (2) 

Due from customers on acceptances 

Other 

50 

172 

81 

8,221 

4,724 

253 

10,200 

Total other assets 

$  78,917 

88 

229 

134 

9,036 

— 

258 

9,444 

79,850 

(1) 

Certain government-guaranteed residential real estate mortgage loans upon foreclosure 
are included in Accounts receivable. For more information, see Note 1 (Summary of 
Significant Accounting Policies). 

(2)  We recognized operating lease right of use (ROU) assets effective January 1, 2019, in 

connection with the adoption of ASU 2016-02 – Leases. For more information, see Note 1 
(Summary of Significant Accounting Policies). 

Wells Fargo & Company 

169 

  
 
  
 
 
Note 10:  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. SPEs are often formed 
in connection with securitization transactions in which assets are 
transferred to an SPE. The SPE may alter the risk profile of the 
asset by entering into derivative transactions or obtaining credit 
support, and issues various forms of interests in those assets to 
investors. In a securitization transaction where we transferred 
assets from our balance sheet, we typically receive cash and 
sometimes other interests in an SPE as proceeds for the assets 
we transfer. 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 whose total equity 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 consistent with their investment 
in the entity. A VIE is consolidated by its primary beneficiary 
which is 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. 

Secured borrowings are transactions involving transfers of 

our financial assets to unconsolidated third parties that are 
accounted for as financings with the assets pledged as collateral. 
Accordingly, the transferred assets remain recognized on our 
balance sheet. See also Repurchase and Securities Lending 
Agreements in Note 16 (Guarantees, Pledged Assets and 
Collateral, and Other Commitments) for additional transactions 
accounted for as secured borrowings. 

170 

Wells Fargo & Company 

 
Table 10.1 provides the classifications of assets and 
liabilities in our balance sheet for our transactions with VIEs. 

Table 10.1:  Balance Sheet Transactions with VIEs 

(in millions) 

December 31, 2019 

Cash and due from banks 

Interest-earning deposits with banks 

Debt securities (1): 

Trading debt securities 

Available-for-sale debt securities 

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, 2018 

Cash and due from banks 

Interest-earning deposits with banks 

Debt securities (1): 

Trading debt securities 

Available-for-sale debt securities 

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 (2) 

Transfers 
that we account 
for as secured 
borrowings (2) 

$ 

$ 

$ 

— 

— 

792 

1,696 

791 

2,127 

11,884 

142 

11,401 

1,268 

30,101 

— 

1 

189 

4,817 

5,007 

— 

25,094 

— 

— 

2,110 

2,686 

510 

2,657 

14,761 

53 

11,041 

— 

33,818 

— 

26 

231 

5,094 

5,351 

— 

$ 

28,467 

16 

284 

339 

201 

— 

13,170 

— 

1 

118 

239 

14,368 

401 

3 

235 

587 

1,226 

43 

13,099 

139 

8 

245 

317 

— 

13,564 

— 

— 

85 

227 

14,585 

493 

— 

199 

816 

1,508 

34 

13,043 

— 

— 

— 

— 

— 

80 

— 

— 

— 

— 

80 

— 

— 

— 

79 

79 

— 

1 

— 

— 

— 

— 

— 

94 

— 

— 

— 

— 

94 

— 

— 

— 

93 

93 

— 

1 

Total 

16 

284 

1,131 

1,897 

791 

15,377 

11,884 

143 

11,519 

1,507 

44,549 

401 

4 

424 

5,483 

6,312 

43 

38,194 

139 

8 

2,355 

3,003 

510 

16,315 

14,761 

53 

11,126 

227 

48,497 

493 

26 

430 

6,003 

6,952 

34 

41,511 

(1) 

(2) 

Excludes certain debt securities related to loans serviced for the Federal National Mortgage Association (FNMA), Federal Home Loan Mortgage Corporation (FHLMC) and Government National 
Mortgage Association (GNMA). 
Certain structures included in transfers that we account for as secured borrowings at December 31, 2018 were presented in VIEs that we consolidate to conform with the current period 
presentation. 

Wells Fargo & Company 

171 

  
 
 
Note 10:  Securitizations and Variable Interest Entities (continued) 

Transactions with Unconsolidated VIEs 
Our transactions with unconsolidated VIEs include 
predominantly securitizations of residential and commercial 
mortgage loans and investments in tax credit structures. We 
have various forms of involvement with VIEs, including servicing, 
holding senior or subordinated interests, and entering into 
liquidity arrangements and 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. 

Table 10.2 provides a summary of our exposure to 

unconsolidated VIEs with which we have significant continuing 
involvement but for which we are not the primary beneficiary. 
We include transactions where we were the sponsor or 
servicer and also have other significant forms of continuing 

Table 10.2:  Unconsolidated VIEs 

involvement. Sponsorship includes transactions where we solely 
or materially participated in the initial design or structuring of 
the VIE or marketed the transaction to investors. We consider 
investments in securities, loans, guarantees, liquidity 
agreements, commitments and certain derivatives to be other 
forms of continuing involvement that may be significant. We also 
include transactions where we transferred assets to a VIE, 
account for the transfer as a sale, and service the VIE collateral or 
have other forms of continuing involvement that may be 
significant (as described above). We exclude certain transactions 
with unconsolidated VIEs when our continuing involvement is 
temporary in nature or insignificant in size. We also exclude 
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, 2019 

Residential mortgage loan securitizations: 

Conforming (2) 

Other/nonconforming 

Commercial mortgage loan securitizations 

Tax credit structures 

Other asset-based finance structures 

Other 

Total 

Residential mortgage loan securitizations: 

Conforming (2) 

Other/nonconforming 

Commercial mortgage loan securitizations 

Tax credit structures 

Other asset-based finance structures 

Other 

Total 

(continued on following page) 

Total 
VIE 
assets 

Debt and 
equity
interests (1) 

Servicing assets
and advances 

Derivatives 

Carrying value – asset (liability) 

Debt, 
guarantees and
other 
commitments 

Net assets 

$ 

1,098,103 

5,178 

169,736 

39,091 

1,355 

1,167 

1,528 

6 

2,239 

12,826 

157 

51 

11,931 

152 

1,069 

— 

— 

— 

— 

— 

80 

— 

61 

— 

(683) 

— 

(43) 

(4,260) 

(20) 

— 

12,776 

158 

3,345 

8,566 

198 

51 

$ 

1,314,630 

16,807 

13,152 

141 

(5,006) 

25,094 

Maximum exposure to loss 

Debt and 
equity
interests (1) 

Servicing assets
and advances 

Derivatives 

Guarantees and 
other 
commitments 

Total 
exposure 

$ 

972 

6 

2,239 

12,826 

157 

51 

11,931 

152 

1,069 

— 

— 

— 

— 

— 

80 

— 

63 

— 

937 

— 

11,667 

1,701 

91 

157 

13,840 

158 

15,055 

14,527 

311 

208 

$ 

16,251 

13,152 

143 

14,553 

44,099 

172 

Wells Fargo & Company 

  
 
(continued from previous page) 

(in millions) 

December 31, 2018 

Residential mortgage loan securitizations: 

Conforming (2) 

Other/nonconforming 

Commercial mortgage loan securitizations 

Tax credit structures 

Other asset-based finance structures 

Other 

Total 

Residential mortgage loan securitizations: 

Conforming (2) 

Other/nonconforming 

Commercial mortgage loan securitizations 

Tax credit structures 

Other asset-based finance structures 

Other 

Total 

Total 
VIE 
assets 

Debt and 
equity 
interests (1) 

Servicing 
assets 

Derivatives 

Carrying value - asset (liability) 

Debt, 
guarantees 
and other 
commitments 

Net assets 

$  1,172,833 

10,596 

153,350 

35,185 

1,520 

1,318 

3,601 

453 

2,409 

12,087 

271 

183 

13,811 

57 

893 

— 

— 

— 

$  1,374,802 

19,004 

14,761 

— 

— 

(22) 

— 

49 

— 

27 

(1,395) 

16,017 

— 

(40) 

(3,870) 

(20) 

— 

510 

3,240 

8,217 

300 

183 

(5,325) 

28,467 

Maximum exposure to loss 

Debt and 
equity 
interests (1) 

Servicing 
assets 

Derivatives 

Guarantees 
and other 
commitments 

Total 
exposure 

$ 

2,377 

453 

2,409 

12,087 

271 

183 

13,811 

57 

893 

— 

— 

— 

$ 

17,780 

14,761 

— 

— 

28 

— 

50 

— 

78 

1,183 

— 

11,563 

1,420 

91 

158 

17,371 

510 

14,893 

13,507 

412 

341 

14,415 

47,034 

(1) 

(2) 

Includes total equity interests of $11.4 billion and $11.0 billion at December 31, 2019 and 2018, 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. 
Carrying values include assets and related liabilities of $556 million and $1.2 billion at December 31, 2019 and 2018, respectively, related to certain unexercised unconditional repurchase options. 
These amounts represent the carrying value of the loans and associated debt that would be payable if the option was exercised to repurchase eligible loans from GNMA loan securitizations. These 
amounts are excluded from maximum exposure to loss as we are not obligated to exercise the options. 

In Table 10.2, “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” is determined 
as the carrying value of our investment in the VIEs excluding the 
unconditional repurchase options that have not been exercised, 
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 disclosure is not an indication of expected loss. 

RESIDENTIAL MORTGAGE LOAN SECURITIZATIONS  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. 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 include conforming and nonconforming 
securitizations. 

Conforming residential mortgage loan securitizations are 

those that are guaranteed by the government-sponsored 
entities (GSEs), such as FNMA and FHLMC, and GNMA. We do 
not consolidate these securitizations because the GSEs or GNMA 
hold the power over the VIEs. 

The loans sold to the VIEs in nonconforming residential 
mortgage loan securitizations are those that do not qualify for a 
GSE guarantee and are not GNMA guaranteed mortgage 
securitizations of FHA-insured or VA-guaranteed mortgages. We 
may hold variable interests issued by the VIEs, including senior 
securities. The nonconforming residential mortgage loan 
securitizations included in the table are not consolidated because 
we do not hold any variable interests, or hold variable interests 
that we do not consider potentially significant, or we are not the 
primary servicer for a majority of the VIE assets. 

Guarantees and other commitments 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. 

Wells Fargo & Company 

173 

 
 
Note 10:  Securitizations and Variable Interest Entities (continued) 

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. In commercial mortgage loan 
securitizations, the most significant decisions impacting the 
performance of the VIE are generally made by the special 
servicer and the primary and master servicer do not have power 
over the VIE. We do not consolidate the commercial mortgage 
loan securitizations included in the disclosure because we do not 
have power over the majority of the SPE’s assets or we do not 
have a variable interest that could potentially be significant to 
the VIE. 

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. The projects are typically managed by 
project sponsors who have the power over the VIE’s assets. 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 because we are 
not the project sponsors. 

OTHER ASSET-BASED FINANCE STRUCTURES  We engage in various 
forms of structured finance arrangements with other VIEs, 
including collateralized loan obligations (CLOs), collateralized 
debt obligations, and other securitizations collateralized by asset 
classes other than mortgages. Collateral may include asset-

Table 10.3:  Transfers With Continuing Involvement 

backed securities, automobile and other transportation loans and 
leases, student loans and general corporate credit. Generally, a 
third party sponsors the VIE and also selects and manages the 
assets. We may participate in structuring or marketing the 
arrangements, provide financing to the VIE, service one or more 
of the underlying VIE assets, or enter into derivatives with the 
VIEs and receive fees for those services. We are not the primary 
beneficiary of these structures because we neither select nor 
manage the assets of the VIE. 

Loan Sales and Securitization Activity 
We periodically transfer consumer and commercial 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. 
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 10.3 presents information about transfers during the 
period of assets to unconsolidated VIEs or third-party investors 
for which we recorded the transfers as sales and have continuing 
involvement with the transferred assets. In connection with 
these transfers, we recorded servicing assets, securities, and a 
liability for repurchase losses which reflects management’s 
estimate of probable losses related to various representations 
and warranties for the loans transferred. Each of these interests 
are initially measured at fair value. Servicing rights are classified 
as Level 3 measurements, and securities are initially 
predominantly classified as Level 2. 

Sales with continuing involvement include securitizations of 

conforming residential mortgages that are sold to the GSEs or 
GNMA. Substantially all transfers to these entities resulted in no 
gain or loss because the loans were already measured at fair 
value on a recurring basis. 

(in millions) 

Net gains (losses) on sale 

Asset balances sold 

Servicing rights recognized 

Securities recognized 

Liability for repurchase losses recognized 

Year ended December 31, 

2019 

2018 

2017 

Residential 
mortgages 

Commercial 
mortgages 

Residential 
mortgages 

Commercial 
mortgages 

Residential 
mortgages 

Commercial 
mortgages 

$ 

89 

170,384 

1,896 

2,747 

18 

330 

18,191 

161 

51 

— 

(10) 

177,805 

1,903 

5,030 

17 

280 

17,882 

158 

81 

— 

342 

213,562 

2,122 

1,414 

24 

359 

16,696 

166 

65 

— 

174 

Wells Fargo & Company 

 
 
  
 
 
Table 10.4 presents the key weighted-average assumptions 

we used to measure residential MSRs at the date of 
securitization. 

Table 10.4:  Residential Mortgage Servicing Rights 

Prepayment speed (1) 

Discount rate 

Cost to service ($ per loan) (2) 

Residential mortgage servicing rights 

Year ended December 31, 

2019 

12.8% 

7.5 

101 

$ 

2018 

10.6 

7.4 

128 

2017 

11.5 

7.0 

132 

(1) 

(2) 

The prepayment speed assumption for residential MSRs 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 due to changes in model assumptions and the mix of modified government-guaranteed loans sold to 
GNMA. 

Table 10.5 presents the proceeds related to transfers 
accounted for as sales in which we have continuing involvement 
with the transferred financial assets as well as current period 
cash flows from continuing involvement with previous transfers 
accounted for as sales. Cash flows from other interests held 
predominantly include principal and interest payments received 
on retained bonds and excess cash flows received on interest-
only strips. Repurchases of assets represents cash paid to 

repurchase loans from investors under representation and 
warranty obligations or in connection with the exercise of 
cleanup calls on securitizations. Loss reimbursements is cash paid 
to reimburse investors for losses on individual loans that are 
already liquidated. Government insured loans are delinquent 
loans that we service and have exercised our option to purchase 
out of GNMA pools. These loans are insured by the FHA or 
guaranteed by the VA. 

Table 10.5:  Cash Inflows (Outflows) From Sales and Securitization Activity 

(in millions) 

Proceeds from securitizations and whole loan sales 

Fees from servicing rights retained 

Cash flows from other interests held 

Repurchases of assets/loss reimbursements: 

Non-agency securitizations and whole loan transactions 

Government insured loans 

Agency securitizations 

Servicing advances, net of recoveries (1) 

2019 

$ 

186,615 

3,149 

468 

(4,441) 

(6,168) 

(95) 

187 

Mortgage loans 

Year ended December 31, 

2018 

193,721 

3,337 

698 

(3) 

(7,775) 

(96) 

154 

2017 

228,282 

3,352 

2,218 

(12) 

(8,600) 

(92) 

269 

(1) 

Cash flows from servicing advances includes principal and interest payments to investors required by servicing agreements. 

Wells Fargo & Company 

175 

  
 
  
 
 
Note 10:  Securitizations and Variable Interest Entities (continued) 

Retained Interests from Unconsolidated VIEs 
Table 10.6 provides key economic assumptions and the 
sensitivity of the current fair value of residential MSRs, and other 
interests held related to unconsolidated VIEs, to immediate 
adverse changes in those assumptions. Amounts for residential 
MSRs include purchased servicing rights as well as servicing 
rights resulting from the transfer of loans. See Note 19 (Fair 
Values of Assets and Liabilities) for additional information on key 
economic assumptions for residential MSRs. “Other interests 
held” were obtained when we securitized residential and 
commercial mortgage loans. Residential mortgage-backed 

securities retained in securitizations issued through GSEs or 
GNMA are excluded from the table because these securities have 
a remote risk of credit loss due to the GSE or government 
guarantee. These securities also have economic characteristics 
similar to GSE or GNMA 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. 

Table 10.6:  Retained Interests from Unconsolidated VIEs 

Residential 
mortgage 
servicing 
rights 

$ 

11,517 

5.3 

Other int

erests held 

C

ommercial 

In

terest-only 
strips 

Su

bordinated 
bonds 

Senior bonds 

2 

3.1 

909 

7.3 

352 

5.5 

($ in millions, except cost to service amounts) 

Fair value of interests held at December 31, 2019 

Expected weighted-average life (in years) 

Key economic assumptions: 

Prepayment speed assumption 

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 

11.9% 

19.5 

537 

1,261 

— 

— 

7.2% 

12.8 

$ 

$ 

464 

889 

102 

253 

632 

— 

— 

$ 

16 

3.6 

4.0 

53 

103 

3.1% 

1 

4 

668 

7.0 

4.3 

37 

72 

5.1% 

2 

5 

2.9 

16 

32 

— 

— 

— 

309 

5.7 

3.7 

14 

28 

— 

— 

— 

Fair value of interests held at December 31, 2018 

Expected weighted-average life (in years) 

$ 

14,649 

6.5 

Key economic assumptions: 

Prepayment speed assumption 

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 

$ 

$ 

9.9% 

17.7 

530 

1,301 

1 

1 

8.1% 

14.5 

615 

1,176 

106 

316 

787 

— 

1 

$ 

176 

Wells Fargo & Company 

  
 
 
In addition to residential MSRs included in the previous 
table, we have a small portfolio of commercial MSRs which are 
carried at LOCOM with a fair value of $1.9 billion and $2.3 billion 
at December 31, 2019 and 2018, respectively. Prepayment 
assumptions do not significantly impact values of commercial 
MSRs and commercial mortgage bonds as most commercial 
loans include contractual restrictions on prepayment. Servicing 
costs are not a driver of our MSR value as we are typically 
primary or master servicer; the higher costs of servicing 
delinquent and foreclosed loans is generally born by the special 
servicer. 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, 2019 and 2018, results in a decrease in fair value 
of $205 million and $320 million, respectively. See Note 11 
(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 

Table 10.7:  Off-Balance Sheet Loans Sold or Securitized 

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 10.7 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. 

Total loans 

December 31, 

Delinquent loans and 
foreclosed assets (1) 

December 31, 

Net charge-offs (3) 

Year ended 

December 31, 

2019 

2018 

2019 

2018 

2019 

2018 

(in millions) 

Commercial: 

Real estate mortgage 

Total commercial 

Consumer: 

Real estate 1-4 family first mortgage 

Real estate 1-4 family junior lien mortgage 

Total consumer 

$ 

112,507 

112,507 

105,173 

105,173 

1,008,446 

1,097,128 

13 

— 

1,008,459 

1,097,128 

776 

776 

6,664 

2 

6,666 

7,442 

1,008 

1,008 

8,947 

— 

8,947 

9,955 

179 

179 

229 

— 

229 

408 

739 

739 

466 

— 

466 

1,205 

Total off-balance sheet sold or securitized loans (2) 

$ 

1,120,966 

1,202,301 

(1) 
(2) 

(3) 

Includes $492 million and $675 million of commercial foreclosed assets and $356 million and $582 million of consumer foreclosed assets at December 31, 2019 and 2018, respectively. 
At December 31, 2019 and 2018, the table includes total loans of $1.0 trillion and $1.1 trillion, delinquent loans of $5.2 billion and $6.4 billion, and foreclosed assets of $251 million and $442 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. 

Wells Fargo & Company 

177 

  
 
 
Note 10:  Securitizations and Variable Interest Entities (continued) 

Transactions with Consolidated VIEs and Secured 
Borrowings 
Table 10.8 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 

Table 10.8:  Transactions with Consolidated VIEs and Secured Borrowings 

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. 

Total VIE 
assets 

Assets 

Liabilities 

Noncontrolling 
interests 

Net assets 

Carrying value 

(in millions) 

December 31, 2019 

Secured borrowings: 

Residential mortgage securitizations 

Total secured borrowings 

Consolidated VIEs: 

Commercial and industrial loans and leases 

Nonconforming residential mortgage loan securitizations 

Commercial real estate loans 

Municipal tender option bond securitizations 

Other 

Total consolidated VIEs 

$ 

81 

81 

8,054 

935 

4,836 

401 

279 

14,505 

Total secured borrowings and consolidated VIEs 

$ 

14,586 

December 31, 2018 

Secured borrowings: 

Residential mortgage securitizations 

Total secured borrowings 

Consolidated VIEs: 

Commercial and industrial loans and leases 

Nonconforming residential mortgage loan securitizations 

Commercial real estate loans 

Municipal tender option bond securitizations (1) 

Other 

Total consolidated VIEs 

$ 

95 

95 

8,215 

1,947 

3,957 

627 

169 

14,915 

Total secured borrowings and consolidated VIEs 

$ 

15,010 

80 

80 

8,042 

809 

4,836 

402 

279 

14,368 

14,448 

94 

94 

8,204 

1,732 

3,957 

523 

169 

14,585 

14,679 

(79) 

(79) 

(529) 

(290) 

— 

(401) 

(6) 

(1,226) 

(1,305) 

(93) 

(93) 

(477) 

(521) 

— 

(501) 

(9) 

(1,508) 

(1,601) 

— 

— 

(16) 

— 

— 

— 

(27) 

(43) 

(43) 

— 

— 

(14) 

— 

— 

— 

(20) 

(34) 

(34) 

1 

1 

7,497 

519 

4,836 

1 

246 

13,099 

13,100 

1 

1 

7,713 

1,211 

3,957 

22 

140 

13,043 

13,044 

(1)  Municipal tender option bond securitizations were reported as secured borrowings at December 31, 2018. These structures were reported as consolidated VIEs at December 31, 2019 to conform 

with our presentation of other transactions where we transfer assets to a consolidated VIE and use secured borrowing accounting. 

178 

Wells Fargo & Company 

  
 
 
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. 

COMMERCIAL AND INDUSTRIAL LOANS AND LEASES  We securitize 
dealer floor plan loans and leases in a revolving master trust 
entity and retain the subordinated notes and residual equity 
interests. At December 31, 2019 and 2018, total assets held by 
the master trust were $6.5 billion and $6.7 billion, respectively, 
and the outstanding senior notes were $300 million and 
$299 million, respectively. As servicer and residual interest 
holder, we control the key decisions of the trust. We also provide 
the majority of debt and equity financing to an SPE that engages 
in lending and leasing to specific vendors and service the 
underlying collateral. We control the key decisions of the entity 
and consolidate the entity as primary beneficiary. 

NONCONFORMING RESIDENTIAL MORTGAGE LOAN 
SECURITIZATIONS  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 we also hold variable interests that 
we have determined to be significant. The nature of our variable 
interests in these entities may include senior or subordinated 
beneficial interests issued by the VIE, MSRs and recourse or 
repurchase reserve liabilities. 

COMMERCIAL REAL ESTATE LOANS  We purchase local industrial 
development bonds and credit enhancement from GSEs, which 
bonds and credit enhancement are placed with a custodian who 
issues beneficial interests. We own all of the beneficial interests 
and may also service the underlying mortgages. Through our 
ownership of the beneficial interests we control the key decisions 
of the trust including the decision to invest in or divest of a bond 
and whether to purchase or retain credit support. 

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 
vehicle. We may also serve as remarketing agent or liquidity 
provider for the trusts should the investors exercise their right to 
tender the certificates at specified dates. If we cannot 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. 

Other Transactions 
In addition to the transactions included in the previous tables, we 
have used wholly-owned trust preferred security VIEs to issue 
debt securities or preferred equity exclusively to third-party 
investors. As the sole assets of the VIEs are receivables from us, 
we do not consolidate the VIEs 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 
third-party securities under certain circumstances. See Note 15 
(Long-Term Debt) and Note 20 (Preferred Stock) for additional 
information about trust preferred securities. 

Certain money market funds are also excluded from the 
previous tables because they are exempt from the consolidation 
analysis. We voluntarily waived a portion of our management 
fees for these money market funds to maintain a minimum level 
of daily net investment income. The amount of fees waived in 
2019, 2018 and 2017 was $40 million, $45 million, and 
$53 million, respectively. 

Wells Fargo & Company 

179 

 
  
  
 
Note 11:  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 11.1 
presents the changes in MSRs measured using the fair value 
method. 

Table 11.1:  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 (7) 

Total changes in fair value 

Fair value, end of year 

Year ended December 31, 

2019 

2018 

2017 

$ 

14,649 

13,625 

12,959 

— 

1,933 

(286) 

1,647 

— 

2,010 

(71) 

541 

2,263 

(23) 

1,939 

2,781 

(2,406) 

1,337 

(103) 

48 

145 

(356) 

(2,569) 

(2,210) 

(4,779) 

818 

(830) 

(365) 

960 

(1,875) 

(915) 

96 

13 

(132) 

(126) 

(1,989) 

(2,115) 

$ 

11,517 

14,649 

13,625 

(1) 

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

(7) 

Includes impacts associated with exercising cleanup calls on securitizations as well as our right to repurchase delinquent loans from Government National Mortgage Association (GNMA) loan 
securitization pools. Total reported MSRs may increase upon repurchase due to servicing liabilities associated with these delinquent GNMA loans. 
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. 
Reflects discount rate assumption change, excluding portion attributable to changes in mortgage interest rates. 
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. 
Represents the reduction in the MSR fair value for the cash flows expected to be collected during the period, net of income accreted due to the passage of time 

Table 11.2 presents the changes in amortized MSRs. 

Table 11.2:  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 

$ 

$ 

$ 

2019 

1,443 

100 

161 

(274) 

1,430 

2,288 

1,872 

Year ended December 31, 

2018 

1,424 

127 

158 

(266) 

1,443 

2,025 

2,288 

2017 

1,406 

115 

166 

(263) 

1,424 

1,956 

2,025 

(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. 

180 

Wells Fargo & Company 

  
 
  
 
 
We present the components of our managed servicing 
portfolio in Table 11.3 at unpaid principal balance for loans 
serviced and subserviced for others and at book value for owned 
loans serviced. 

Table 11.3:  Managed Servicing Portfolio 

(in billions) 

Residential mortgage servicing: 

Serviced for others 

Owned loans serviced (1) 

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 

(1) 

Excludes loans serviced by third parties. 

Table 11.4 presents the components of mortgage banking 

noninterest income. 

Table 11.4:  Mortgage Banking Noninterest Income 

(in millions) 

Servicing income, net: 

Servicing fees: 

Dec 31, 
2019 

Dec 31, 
2018 

$ 

1,063 

343 

2 

1,408 

566 

124 

9 

699 

$ 

$ 

2,107 

1,629 

0.79% 

1,164 

334 

4 

1,502 

543 

121 

9 

673 

2,175 

1,707 

0.94 

Year ended December 31, 

2019 

2018 

2017 

Contractually specified servicing fees 

$ 

3,388 

3,613 

3,603 

Late charges 

Ancillary fees 

Unreimbursed direct servicing costs (1) 

Net servicing fees 

Changes in fair value of MSRs carried at fair value: 

Due to changes in valuation model inputs or assumptions (2) 

Changes due to collection/realization of expected cash flows over time (3) 

Total changes in fair value of MSRs carried at fair value 

Amortization 

Net derivative gains (losses) from economic hedges (4) 

Total servicing income, net 

Net gains on mortgage loan origination/sales activities (5) 

(A) 

(B) 

Total mortgage banking noninterest income 

Market-related valuation changes to MSRs, net of hedge results (2)(4) 

(A)+(B) 

$ 

$ 

129 

143 

(403) 

3,257 

(2,569) 

(2,210) 

(4,779) 

(274) 

2,318 

522 

2,193 

2,715 

162 

182 

(331) 

3,626 

960 

(1,875) 

(915) 

(266) 

(1,072) 

1,373 

1,644 

3,017 

(251) 

(112) 

172 

199 

(582) 

3,392 

(126) 

(1,989) 

(2,115) 

(263) 

413 

1,427 

2,923 

4,350 

287 

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

Includes costs associated with foreclosures, unreimbursed interest advances to investors, and other interest costs. 
Refer to the analysis of changes in fair value MSRs presented in Table 11.1 in this Note for more detail. 
Represents the reduction in the MSR fair value for the cash flows expected to be collected during the period, net of income accreted due to the passage of time. 
Represents results from economic hedges used to hedge the risk of changes in fair value of MSRs. See Note 18 (Derivatives) for additional discussion and detail. 
Includes net gains (losses) of $(141) million, $857 million and $35 million at December 31, 2019, 2018 and 2017, respectively, related to derivatives used as economic hedges of mortgage loans held 
for sale and derivative loan commitments. 

Wells Fargo & Company 

181 

  
 
  
 
 
 
Note 12:  Intangible Assets 

Table 12.1 presents the gross carrying value of intangible assets 
and accumulated amortization. 

Table 12.1:  Intangible Assets 

(in millions) 

Amortized intangible assets (1): 

MSRs (2) 

Core deposit intangibles 

Customer relationship and other intangibles 

Total amortized intangible assets 

Unamortized intangible assets: 

MSRs (carried at fair value) (2) 

Goodwill 

Trademark 

December 31, 2019 

December 31, 2018 

Gross carrying 
value 

Accumulated 
amortization 

Net carrying 
value 

Gross carrying 
value 

Accumulated 
amortization 

Net carrying 
value 

$ 

4,422 

$ 

$ 

— 

947 

5,369 

11,517 

26,390 

14 

(2,992) 

—

(524) 

(3,516) 

1,430 

— 

423 

1,853 

4,161 

12,834 

3,994 

20,989 

14,649 

26,418 

14 

(2,718) 

(12,834) 

(3,449) 

(19,001) 

1,443 

— 

545 

1,988 

(1) 
(2) 

Balances are excluded commencing in the period following full amortization. 
See Note 11 (Mortgage Banking Activities) for additional information on MSRs. 

Table 12.2 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, 2019. Future amortization 
expense may vary from these projections. 

Table 12.2:  Amortization Expense for Intangible Assets 

(in millions) 

Year ended December 31, 2019 (actual) 

Estimate for year ended December 31, 

2020 

2021 

2022 

2023 

2024 

Amortized MSRs 

Customer 
relationship and 
other intangibles 

$ 

$ 

274 

263 

227 

203 

176 

152 

114 

95 

81 

68 

59 

48 

Total 

388 

358 

308 

271 

235 

200 

Table 12.3 shows the allocation of goodwill to our reportable 

operating segments. 

Table 12.3:  Goodwill 

(in millions) 

December 31, 2017 (1) 

Reduction in goodwill related to divested businesses and foreign currency translation 

December 31, 2018 (1) 

Reduction in goodwill related to divested businesses and foreign currency translation 

December 31, 2019 (1) 

Community 
Banking 

Wholesale 
Banking 

Wealth and 
Investment 
Management 

Consolidated 
Company 

$ 

$ 

$ 

16,849 

(164) 

16,685 

— 

16,685 

8,455 

(5) 

8,450 

(21) 

8,429 

1,283 

— 

1,283 

(7) 

1,276 

26,587 

(169) 

26,418 

(28) 

26,390 

(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, which closed in February 2018. At 
December 31, 2019, and December 31, 2018, there was no Goodwill classified as held-for-sale in other assets. 

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, 2019 and 2018. The fair 
values exceeded the carrying amount of our respective reporting 
units by approximately 6% to 425% at December 31, 2019. See 
Note 27 (Operating Segments) for further information on 
management reporting. 
182 

Wells Fargo & Company 

  
 
  
 
  
 
 
Note 13:  Deposits 

Table 13.1 presents a summary of the time certificates of 
deposit (CDs) and other time deposits issued by domestic and 
non-U.S. offices. 

The contractual maturities of the domestic time deposits 
with a denomination of $100,000 or more are presented in Table 
13.3. 

Table 13.1:  Time Certificates of Deposits and Other Time Deposits 

Table 13.3:  Contractual Maturities of Domestic Time Deposits 

(in billions) 

Total domestic and Non-U.S. 

Domestic: 

$100,000 or more 

$250,000 or more 

Non-U.S. 

$100,000 or more 

$250,000 or more 

December 31, 

(in millions) 

December 31, 2019 

2019 

118.8 

$ 

2018 

130.6 

43.7 

34.6 

4.0 

4.0 

42.5 

37.1 

4.6 

4.6 

Three months or less 

After three months through six months 

After six months through twelve months 

After twelve months 

Total 

$ 

$ 

18,759 

10,583 

11,766 

2,624 

43,732 

Demand deposit overdrafts of $542 million and $624 million 

were included as loan balances at December 31, 2019 and 2018, 
respectively. 

Substantially all CDs and other time deposits issued by 

domestic and non-U.S. offices were interest bearing. The 
contractual maturities of these deposits are presented in Table 
13.2. 

Table 13.2:  Contractual Maturities of CDs and Other Time Deposits 

(in millions) 

December 31, 2019 

2020 

2021 

2022 

2023 

2024 

Thereafter 

Total 

$ 

88,259 

15,429 

6,055 

4,130 

1,906 

3,070 

$ 

118,849 

Wells Fargo & Company 

183 

  
  
 
 
  
 
 
Note 14:  Short-Term Borrowings 

Table 14.1 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 16 (Guarantees, Pledged Assets and Collateral, and Other 
Commitments). 

Table 14.1:  Short-Term Borrowings 

(in millions) 

As of December 31, 

Amount 

2019 

Rate 

Amount 

2018 

Rate 

Amount 

2017 

Rate 

Federal funds purchased and securities sold under agreements to repurchase 

$ 

92,403 

1.54%  $ 

92,430 

2.65%  $ 

88,684 

1.30% 

Commercial paper 

Other short-term borrowings 

Total 

Year ended December 31, 

Average daily balance 

— 

12,109 

$ 

104,512 

— 

0.60 

1.43 

— 

13,357 

— 

1.63 

— 

14,572 

$ 

105,787 

2.52 

$ 

103,256 

Federal funds purchased and securities sold under agreements to repurchase 

$ 

102,888 

2.11 

$ 

90,348 

1.78 

$ 

82,507 

Commercial paper 

Other short-term borrowings 

Total 

Maximum month-end balance 

— 

12,449 

$ 

115,337 

— 

1.20 

2.01 

— 

13,919 

— 

0.79 

16 

16,399 

$ 

104,267 

1.65 

$ 

98,922 

Federal funds purchased and securities sold under agreements to repurchase (1)  $ 

111,726 

N/A 

$ 

93,918 

N/A  $ 

91,604 

Commercial paper (2) 

Other short-term borrowings (3) 

— 

14,129 

N/A 

N/A 

— 

16,924 

N/A 

N/A 

78 

19,439 

N/A- Not applicable 
(1) 
(2) 
(3) 

Highest month-end balance in each of the last three years was October 2019, November 2018 and November 2017. 
There were no month-end balances in 2019 and 2018; highest month-end balance in 2017 was January. 
Highest month-end balance in each of the last three years was February 2019, January 2018 and February 2017. 

— 

0.72 

1.22 

0.90 

0.95 

0.13 

0.77 

N/A 

N/A 

N/A 

184 

Wells Fargo & Company 

  
 
 
Note 15:  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 18 (Derivatives) 
for further information on qualifying hedge contracts. 

Table 15.1:  Long-Term Debt 

Table 15.1 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, 2019. These interest 
rates do not include the effects of any associated derivatives 
designated in a hedge accounting relationship. 

(in millions) 

Wells Fargo & Company (Parent only) 

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 - 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) 

Floating-rate advances - FHLB 

Structured notes (2) 

Finance 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 

Long-term debt issued by VIE - Floating rate 

Mortgage notes and other debt (5) 

Total long-term debt - Bank 

(continued on following page) 

Maturity date(s) 

Stated interest rate(s) 

2020-2047 

2020-2048 

2025-2030 

0.38 - 6.75% 

$ 

0.02-3.24% 

2.41-3.58% 

2023-2046 

3.45-7.57% 

2029-2036 

2027 

5.95-7.95% 

2.50-3.00% 

2020-2023 

2020-2053 

2021-2022 

2020-2031 

2020-2022 

2.40-3.63% 

1.64-2.55% 

2.08-3.33% 

3.83-7.50% 

1.83-2.31% 

2020-2029 

1.69-17.78% 

2023-2038 

5.25-7.74% 

2027 

2.48-2.65% 

2037 

2020-2038 

2020-2057 

6.00% 

2.38-4.62% 

9.20% 

December 31, 

2019 

2018 

86,618 

16,800 

12,030 

8,390 

77,742 

19,553 

2,901 

7,984 

123,838 

108,180 

27,195 

27,195 

1,428 

318 

1,746 

25,428 

25,428 

1,308 

308 

1,616 

152,779 

135,224 

9,364 

10,617 

5,097 

41 

32,950 

1,914 

32 

60,015 

5,374 

5,374 

363 

363 

17 

570 

6,185 

72,524 

14,222 

6,617 

1,998 

51 

53,825 

1,646 

36 

78,395 

5,199 

5,199 

352 

352 

160 

656 

6,637 

91,399 

Wells Fargo & Company 

185 

  
 
 
Note 15:  Long-Term Debt (continued) 

(continued from previous page) 

(in millions) 

Other consolidated subsidiaries 

Senior 

Fixed-rate notes 

Structured notes (2) 

Finance leases 

Total senior debt - Other consolidated subsidiaries 

Mortgage notes and other 

Total long-term debt - Other consolidated subsidiaries 

Total long-term debt 

Maturity date(s) 

Stated interest rate(s) 

December 31, 

2019 

2018 

2021-2023 

3.04-3.46% 

2020 

2026 

3.71% 

3.27% 

1,352 

1,503 

1 

2,856 

32 

2,888 

2,383 

6 

— 

2,389 

32 

2,421 

$ 

228,191 

229,044 

(1) 
(2) 

(3) 

(4) 

(5) 

Includes $66 million of outstanding zero coupon callable notes at December 31, 2019. 
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 18 (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 $128 million and $131 million in 2019 and 2018, respectively, and debt issuance costs of $2 million in both 2019 and 
2018, to effect a modification of Wells Fargo Bank, N.A., notes. These subordinated notes are carried at their par amount on the balance sheet of the Parent presented in Note 28 (Parent-Only 
Financial Statements). In addition, Parent long-term debt presented in Note 28 also includes affiliate related issuance costs of $281 million and $278 million in 2019 and 2018, respectively. 
Represents junior subordinated debentures held by unconsolidated wholly-owned trusts formed for the sole purpose of issuing trust preferred securities. See Note 10 (Securitizations and Variable 
Interest Entities) for additional information. 
Largely relates to unfunded commitments for LIHTC investments. For additional information, see Note 8 (Equity Securities). 

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 $228.2 billion at 
December 31, 2019, decreased $853 million from December 31, 
2018. We issued $53.4 billion of long-term debt in 2019. 

The aggregate carrying value of long-term debt that 

matures (based on contractual payment dates) as of 
December 31, 2019, in each of the following five years and 
thereafter is presented in Table 15.2. 

Table 15.2:  Maturity of Long-Term Debt 

(in millions) 

Wells Fargo & Company (Parent Only) 

Senior notes 

Subordinated notes 

Junior subordinated notes 

2020 

2021 

2022 

2023 

2024 

Thereafter 

Total 

December 31, 2019 

$ 

13,429 

18,163 

18,091 

11,104 

9,387 

— 

— 

— 

— 

— 

— 

3,653 

— 

737 

— 

53,664 

22,805 

1,746 

123,838 

27,195 

1,746 

Total long-term debt - Parent 

13,429 

18,163 

18,091 

14,757 

10,124 

78,215 

152,779 

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 

23,415 

27,865 

5,585 

— 

— 

— 

— 

2,658 

1,138 

26,073 

29,003 

144 

— 

144 

1,761 

— 

1,761 

— 

— 

633 

6,218 

93 

— 

93 

2,884 

1,071 

— 

224 

4,179 

435 

— 

435 

6 

— 

— 

157 

163 

118 

— 

118 

260 

4,303 

363 

1,962 

6,888 

305 

32 

337 

60,015 

5,374 

363 

6,772 

72,524 

2,856 

32 

2,888 

Total long-term debt 

$ 

39,646 

48,927 

24,402 

19,371 

10,405 

85,440 

228,191 

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, 2019, we were in compliance with all the 
covenants. 

186 

Wells Fargo & Company 

  
 
Note 16:  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 options, recourse 
obligations, and other types of similar arrangements. Table 16.1 
shows carrying value, maximum exposure to loss on our 
guarantees and the related non-investment grade amounts. 

Table 16.1:  Guarantees – Carrying Value and Maximum Exposure to Loss 

(in millions) 

December 31, 2019 

Standby letters of credit 

Direct pay letters of credit 

Written options (1) 

Loans and MLHFS sold with recourse (2) 

Exchange and clearing house guarantees 

Other guarantees and indemnifications (3) 

Total guarantees 

December 31, 2018 

Standby letters of credit (4) 

Direct pay letters of credit (4) 

Written options (1) 

Loans and MLHFS sold with recourse (2) 

Exchange and clearing house guarantees (4) 

Other guarantees and indemnifications (3), (4) 

$ 

$ 

$ 

Carrying 
value of 
obligation 
(asset) 

Expires in one 
year or less 

Expires after 
one year 
through three 
years 

Expires after 
three years 
through five 
years 

Expires after 
five years 

36 

— 

(345) 

52 

— 

1 

11,569 

1,861 

17,088 

114 

— 

785 

4,460 

3,815 

10,869 

576 

— 

1 

2,812 

824 

2,341 

1,356 

— 

3 

467 

105 

273 

10,050 

4,817 

809 

Maximum exposure to loss 

Non-
investment 
grade 

7,104 

1,184 

18,113 

9,835 

— 

698 

Total 

19,308 

6,605 

30,571 

12,096 

4,817 

1,598 

(256) 

31,417 

19,721 

7,336 

16,521 

74,995 

36,934 

40 

— 

(185) 

54 

— 

1 

10,947 

3,689 

17,243 

104 

— 

889 

4,649 

3,248 

10,502 

653 

— 

1 

2,872 

526 

3,066 

1,207 

— 

3 

461 

36 

400 

10,163 

2,922 

1,081 

18,929 

7,499 

31,211 

12,127 

2,922 

1,974 

7,017 

1,010 

21,732 

9,079 

— 

753 

Total guarantees 

$ 

(90) 

32,872 

19,053 

7,674 

15,063 

74,662 

39,591 

(1)  Written options, which are in the form of derivatives, are also included in the derivative disclosures in Note 18 (Derivatives). Carrying value net asset position is a result of certain deferred premium 

option trades. 
Represent recourse provided, predominantly to the GSEs, on loans sold under various programs and arrangements. 
Includes indemnifications provided to certain third-party clearing agents. Outstanding customer obligations under these arrangements were $80 million and $70 million with related collateral of 
$696 million and $974 million at December 31, 2019 and 2018, respectively.  
Prior period amounts have been revised to conform with the current period presentation. 

(2) 
(3) 

(4) 

“Maximum exposure to loss” and “Non-investment grade” 

are required disclosures under GAAP. 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 16.1 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, or the allowance for 
lending-related commitments, is more representative of our 
exposure to loss. 

Non-investment grade represents those guarantees on 
which we have a higher risk of performance 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). 

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. 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. Standby letters of credit are conditional lending 
commitments 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. Total maximum exposure to loss 
includes the portion of multipurpose lending facilities for which 
we have issued standby letters of credit under the commitments. 
We consider the credit risk in standby letters of credit and 
commercial and similar letters of credit in determining the ACL. 

DIRECT PAY LETTERS OF CREDIT  We issue direct pay letters of 
credit to serve as 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 consider the credit risk in direct pay letters of credit in 
determining the ACL. 

WRITTEN OPTIONS  We enter into certain derivative contracts 
that have the characteristics of a guarantee. These contracts 
include written put options that give the counterparty the right 
to sell to us an underlying instrument held by the counterparty at 

Wells Fargo & Company 

187 

  
 
 
 
 
Note 16:  Guarantees, Pledged Assets and Collateral, and Other Commitments (continued) 

OTHER GUARANTEES AND INDEMNIFICATIONS We 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. 

Under certain factoring arrangements, we may be required 

to purchase trade receivables from third parties, if receivable 
debtors default on their payment obligations. 

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. 

GUARANTEES OF SUBSIDIARIES In the normal course of business, 
the Parent may provide counterparties with guarantees related 
to its subsidiaries’ obligations. These obligations are included in 
the Company’s consolidated balance sheets or are reflected as 
off-balance sheet commitments, and therefore, the Parent has 
not recognized a separate liability for these guarantees. 
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 $1.6 billion and $5 million at December 31, 2019 and 2018, 
respectively. These guarantees rank on parity with all of the 
Parent’s other unsecured and unsubordinated indebtedness. 

a specified price by a specified date. They also include certain 
written options that require us to make a payment for increases 
in fair value of assets held by the counterparty. These written 
option contracts generally permit or require 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 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 
options is based on future market conditions and is only 
quantifiable at settlement. See Note 18 (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 16.1 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. 

EXCHANGE AND CLEARING HOUSE GUARANTEES  We are members 
of several securities and derivatives exchanges and clearing 
houses, both in the U.S. and in countries outside the U.S., 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 and of 
the organization. Our obligations under the guarantees are 
generally a pro-rata share based on either a fixed amount or a 
multiple of the guarantee fund we are required to maintain with 
these organizations. Some membership rules require members 
to assume a pro-rata share of losses resulting from another 
member’s default or from non-member default losses after 
applying the guarantee fund. We have not recorded a liability for 
these arrangements as of the dates presented in Table 16.1 
because we believe the likelihood of loss is remote. 

188 

Wells Fargo & Company 

 
 
Pledged Assets 
Table 16.2 provides the carrying amount of on-balance sheet 
pledged assets and the fair value of off-balance sheet pledged 
assets. 

TRADING RELATED ACTIVITY  Our trading businesses may pledge 
debt and equity securities in connection with securities sold 
under agreements to repurchase (repurchase agreements) and 
securities lending arrangements. Substantially all of the trading 
activity pledged collateral is eligible to be repledged or sold by 
the secured party. The collateral that we pledge related to our 
trading activities may include our own collateral as well as 
collateral that we have received from third parties and have the 
right to repledge. 

NON-TRADING RELATED ACTIVITY  As part of our liquidity 
management strategy, we may pledge loans, debt securities, and 
other assets to secure trust and public deposits, borrowings and 
letters of credit from the Federal Home Loan Bank (FHLB) and 
FRB and for other purposes as required or permitted by law or 

Table 16.2:  Pledged Assets 

(in millions) 

Related to trading activities: 

Debt securities 

Equity securities 

Total pledged assets related to trading activities (1) 

Related to non-trading activities: 

Debt securities and other 

Mortgage loans held for sale (2) 

Loans (2) 

Total pledged assets related to non-trading activities 

Total pledged assets 

• 

insurance statutory requirements. Substantially all of the non-
trading activity pledged collateral is not eligible to be repledged 
or sold by the secured party. 
Table 16.2 excludes: 
Pledged assets of consolidated VIEs of $14.4 billion and 
$14.6 billion at December 31, 2019 and 2018, respectively, 
which can only be used to settle the liabilities of those 
entities; 
Assets pledged in transactions with VIEs accounted for as 
secured borrowings of $80 million and $94 million at 
December 31, 2019 and 2018, respectively; and 
Pledged loans recorded on our balance sheet of $568 million 
and $1.2 billion at December 31, 2019 and 2018, 
respectively, representing certain delinquent loans that are 
eligible for repurchase from GNMA loan securitizations. 

• 

• 

See Note 10 (Securitizations and Variable Interest Entities) for 
additional information on consolidated VIE assets and secured 
borrowings. 

Dec 31, 

2019 

$ 

106,105 

6,204 

112,309 

65,047 

2,266 

406,106 

473,419 

585,728 

$ 

Dec 31, 

2018 

96,616 

9,695 

106,311 

62,438 

7,439 

446,455 

516,332 

622,643 

(1) 
(2) 

Includes securities collateral received from third parties that we have repledged of $60.1 billion and $60.8 billion as of December 31, 2019 and 2018, respectively. 
Prior period amounts have been revised to conform with the current period presentation. 

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 16.3 
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 16.3, we also 

have balance sheet netting related to derivatives that is 
disclosed in Note 18 (Derivatives). 

Wells Fargo & Company 

189 

  
  
 
 
Note 16:  Guarantees, Pledged Assets and Collateral, and Other Commitments (continued) 

Table 16.3:  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, 

2019 

Dec 31, 

2018 

$ 

$ 

$ 

$ 

140,773 

(19,180) 

121,593 

(120,786) 

807 

111,038 

(19,180) 

91,858 

(91,709) 

149 

112,662 

(15,258) 

97,404 

(96,734) 

670 

106,248 

(15,258) 

90,990 

(90,798) 

192 

(1) 
(2) 

(3) 

(4) 
(5) 
(6) 
(7) 

(8) 

Represents recognized amount of resale and repurchase agreements with counterparties subject to enforceable MRAs that have been offset in the consolidated balance sheet. 
Includes $102.1 billion and $80.1 billion, respectively, classified on our consolidated balance sheet in federal funds sold and securities purchased under resale agreements at December 31, 2019 and 
2018. Also includes securities purchased under long-term resale agreements (generally one year or more) classified in loans, which totaled $19.5 billion and $17.3 billion, at December 31, 2019 and 
2018, respectively. 
Represents the fair value of collateral we have received under enforceable MRAs or MSLAs, limited in the table above to the amount of the recognized asset due from each counterparty. At 
December 31, 2019 and 2018, we have received total collateral with a fair value of $150.9 billion and $123.1 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 $59.1 billion at December 31, 2019, and $60.8 billion at December 31, 2018. 
Represents the amount of our exposure that is not collateralized and/or is not subject to an enforceable MRA or MSLA. 
For additional information on underlying collateral and contractual maturities, see the “Repurchase and Securities Lending Agreements” section in this Note. 
Amount is classified in short-term borrowings on our consolidated balance sheet. 
Represents the fair value of collateral we have pledged, related to enforceable MRAs or MSLAs, limited in the table above to the amount of the recognized liability owed to each counterparty. At 
December 31, 2019 and 2018, we have pledged total collateral with a fair value of $113.3 billion and $108.8 billion, respectively, substantially all of which may be sold or repledged by the 
counterparty. 
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 in 
various ways. Most of our collateral consists of highly liquid 
securities. In addition, we underwrite and monitor the financial 
strength of our counterparties, monitor the fair value of 
collateral pledged relative to contractually required repurchase 
amounts, and monitor that our collateral is properly returned 
through the clearing and settlement process in advance of our 
cash repayment. Table 16.4 provides the gross amounts 
recognized on the balance sheet (before the effects of 
offsetting) of our liabilities for repurchase and securities lending 
agreements disaggregated by underlying collateral type. 

190 

Wells Fargo & Company 

  
 
 
Table 16.4:  Gross Obligations by Underlying Collateral Type 

(in millions) 

Repurchase agreements: 

Securities of U.S. Treasury and federal agencies 

Securities of U.S. States and political subdivisions 

Federal agency mortgage-backed securities 

Non-agency mortgage-backed securities 

Corporate debt securities 

Asset-backed securities 

Equity securities 

Other 

Total repurchases 

Securities lending arrangements: 

Securities of U.S. Treasury and federal agencies 

Federal agency mortgage-backed securities 

Corporate debt securities 

Equity securities (1) 

Other 

Total securities lending 

$ 

Dec 31, 

2019 

48,161 

104 

44,737 

1,818 

7,126 

1,844 

1,674 

705 

106,169 

163 

— 

223 

4,481 

2 

4,869 

Dec 31, 

2018 

38,408 

159 

47,241 

1,875 

6,191 

2,074 

992 

340 

97,280 

222 

2 

389 

8,349 

6 

8,968 

Total repurchases and securities lending 

$ 

111,038 

106,248 

(1) 

Equity securities are generally exchange traded and represent collateral received from third parties that has been repledged. We received the collateral through either margin lending agreements or 
contemporaneous securities borrowing transactions with other counterparties. 

Table 16.5 provides the contractual maturities of our gross 
obligations under repurchase and securities lending agreements. 

Table 16.5:  Contractual Maturities of Gross Obligations 

(in millions) 

December 31, 2019 

Repurchase agreements 

Securities lending arrangements 

Total repurchases and securities lending (1) 

December 31, 2018 

Repurchase agreements 

Securities lending arrangements 

Total repurchases and securities lending (1) 

Overnight/ 
continuous 

Up to 30 days 

30-90 days 

>90 days 

$ 

$ 

$ 

$ 

79,793 

4,724 

84,517 

86,574 

8,669 

95,243 

17,681 

— 

17,681 

3,244 

— 

3,244 

4,825 

145 

4,970 

2,153 

299 

2,452 

3,870 

— 

3,870 

5,309 

— 

5,309 

Total gross 
obligation 

106,169 

4,869 

111,038 

97,280 

8,968 

106,248 

(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, 2019 and 2018, we 
had commitments to purchase debt securities of $18 million and 
$335 million, respectively, and commitments to purchase equity 
securities of $2.7 billion and $2.5 billion, respectively. 

As part of maintaining our memberships in certain clearing 

organizations, we are required to stand ready to provide liquidity 
to sustain market clearing activity in the event unforeseen 
events occur or are deemed likely to occur. Certain of these 
obligations are guarantees of other members’ performance and 
accordingly are included in Table 16.1. 

Also, we have commitments to purchase loans and securities 

under resale agreements from certain counterparties, including 
central clearing organizations. The amount of our unfunded 
contractual commitments was $7.5 billion and $12.4 billion as of 
December 31, 2019 and 2018, respectively.

 Given the nature of these commitments, they are excluded 

from Table 6.4 (Unfunded Credit Commitments) in Note 6 
(Loans and Allowance for Credit Losses). 

Wells Fargo & Company 

191 

  
 
  
 
 
Note 17:  Legal Actions 

Wells Fargo and certain of our subsidiaries are involved in a 
number of judicial, regulatory, governmental, arbitration, and 
other proceedings or investigations concerning matters arising 
from the conduct of our business activities, and many of those 
proceedings and investigations expose Wells Fargo to potential 
financial loss. These proceedings and investigations 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 certain 
mortgage interest rate lock extensions. The consent orders 
192 

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. The 
Company has reached an agreement to resolve the multi-district 
litigation pursuant to which the Company has agreed to pay, 
consistent with its remediation obligations under the consent 
orders, approximately $547 million in remediation to customers 
with CPI policies placed between October 15, 2005, and 
September 30, 2016. The settlement amount is not incremental 
to the Company’s remediation obligations under the consent 
orders, but instead encompasses those obligations, including 
remediation payments to date. The settlement amount is 
subject to change as the Company finalizes its remediation 
activity under the consent orders. In addition, the Company has 
agreed to contribute $1 million to a common fund for the class. 
The district court granted final approval of the settlement on 
November 21, 2019. 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. In addition, the Company is subject to a class action 
lawsuit in the United States District Court for the Central District 
of California alleging that customers are entitled to refunds 
related to the unused portion of guaranteed automobile 
protection (GAP) waiver or insurance agreements between the 
customer and dealer and, by assignment, the lender. 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. The parties to the state court action have 
entered into an agreement to resolve the action pursuant to 
which the Company will pay plaintiffs’ attorneys’ fees and 
undertake certain business and governance practices. The state 
court granted final approval of the settlement on January 15, 
2020. These and other issues related to the origination, servicing, 
and 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 
historical practices associated with 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. 

FIDUCIARY AND CUSTODY ACCOUNT FEE CALCULATIONS  Federal 
government agencies are conducting formal or informal 

Wells Fargo & Company 

 
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 the Wealth and 
Investment Management (WIM) operating segment. 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 activities in the 
Company’s foreign exchange business, including whether 
customers may have received pricing inconsistent with 
commitments made to those customers. These matters are at 
varying stages. The Company has responded, and continues to 
respond, to requests from a number of the foregoing and has 
discussed the potential resolution of some of the matters. 

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 eight 
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 final approval of 
the settlement on December 13, 2019, which was appealed to 
the United States Court of Appeals for the Second Circuit by 
settlement objector merchants. Several of the opt-out and direct 
action litigations have been settled 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. 

MOBILE DEPOSIT PATENT LITIGATION  The Company is a defendant 
in two separate cases brought by United Services Automobile 
Association (USAA) in the United States District Court for the 
Eastern District of Texas alleging claims of patent infringement 
regarding mobile deposit capture technology patents held by 
USAA. Trial in the first case commenced on October 30, 2019, 
and resulted in a $200 million verdict against the Company. Trial 
in the second case commenced on January 6, 2020, and resulted 
in a $102.7 million verdict against the Company. The Company 
has filed post-trial motions to, among other things, vacate the 
verdicts, and USAA has filed post-trial motions seeking future 
royalty payments and damages for willful infringement. 

MORTGAGE LOAN MODIFICATION LITIGATION  Plaintiffs 
representing a putative class of mortgage borrowers have filed 
separate putative class actions, Hernandez v. Wells Fargo, et al., 
Coordes v. Wells Fargo, et al., Ryder v. Wells Fargo, Liguori v. 
Wells Fargo, and Dore v. Wells Fargo, against Wells Fargo Bank, 
N.A., in the United States District Court for the Northern District 
of California, the United States District Court for the District of 
Washington, the United States District Court for the Southern 
District of Ohio, the United States District Court for the 
Southern District of New York, and the United States District 
Court for the Western District of Pennsylvania, 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 

Wells Fargo & Company 

193 

  
  
  
 
Note 17:  Legal Actions (continued) 

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. On 
September 26, 2019, the district court entered an order granting 
Wells Fargo’s motion and dismissed the claims of unnamed class 
members in favor of arbitration. Plaintiffs appealed this decision 
to the United States Court of Appeals for the Eleventh Circuit. 

RETAIL SALES PRACTICES MATTERS  A number of bodies or 
entities, including (a) 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, (b) state attorneys 
general, including the New York Attorney General, and (c) 
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. 
On February 21, 2020, the Company entered into an 

agreement with the Department of Justice to resolve the 
Department of Justice’s criminal investigation into the 
Company’s retail sales practices, as well as a separate 
agreement to resolve the Department of Justice’s civil 
investigation. As part of the Department of Justice criminal 
settlement, no charges will be filed against the Company 
provided the Company abides by all the terms of the 
agreement. The Department of Justice criminal settlement 
also includes the Company’s agreement that the facts set 
forth in the settlement document constitute sufficient facts 
for the finding of criminal violations of statutes regarding 
bank records and personal information. On February 21, 2020, 
the Company also entered into an order to resolve the SEC’s 
investigation arising out of the Company’s retail sales 
practices. The SEC order contains a finding, to which the 
Company consented, that the facts set forth include 
violations of Section 10(b) of the Securities Exchange Act of 
1934 and Rule 10b-5 thereunder. As part of the resolution of 
the Department of Justice and SEC investigations, the 
Company has agreed to make payments totaling $3.0 billion. 
In addition, as part of the settlements and included in the 
$3.0 billion amount, the Company has agreed to the creation 
of a $500 million Fair Fund for the benefit of investors who 
were harmed by the conduct covered in the SEC settlement. 
In addition, a number of lawsuits have 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., pursuant to 
which the Company will pay $142 million to resolve claims 
regarding certain products or services provided without 
authorization or consent for the time period May 1, 2002 to April 
20, 2017. The district court issued an order 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 against, among others, current 
and former directors and officers for their alleged involvement 
with and failure to detect and prevent sales practices issues. 
These actions are currently pending in the United States District 
Court for the Northern District of California and California state 
court as coordinated proceedings. An additional lawsuit, which 
asserts similar claims and is pending in Delaware state court, has 
been stayed. The parties have entered into settlement 
agreements 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. The federal 
court granted preliminary approval of the settlement for its 
action and held a final approval hearing on August 1, 2019. The 

194 

Wells Fargo & Company 

 
state court granted final approval of the settlement for its action 
on January 15, 2020. Fourth, multiple employment litigation 
matters have been brought against Wells Fargo, including (a) a 
purported 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; this action has 
been dismissed and is now on appeal; (b) a purported 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; this action has been dismissed, and we 
have entered into a framework with plaintiffs’ counsel to address 
individual claims that have been asserted; (c) various wage and 
hour class actions brought in federal and state court in California, 
New Jersey, and Pennsylvania on behalf of non-exempt branch 
based team members alleging that sales pressure resulted in 
uncompensated overtime; these actions have been settled; and 
(d) 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 alleged that Wells Fargo 
Bank, N.A., as trustee, caused losses to investors and asserted 
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 sought money damages in an unspecified 
amount, reimbursement of expenses, and equitable relief. In 
December 2014 and December 2015, certain other investors 
filed additional complaints alleging similar claims against 
Wells Fargo Bank, N.A., in the Southern District of New York 
(Related Federal Cases). In January 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 subsequent 
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). 

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). A complaint raising similar allegations to those in 
the Federal Court Complaint was filed in May 2016 in New York 
state court by IKB International and IKB Deutsche Industriebank 
(IKB 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 sought, among other relief, declarations that the 
Company 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 May 2019, the New York state court approved a 
settlement agreement among the Institutional Investor 
Plaintiffs and the Company pursuant to which, among other 
terms, the Company paid $43 million to resolve the Federal 
Court Complaint and the State Court Action. The settlement 
also resolved the Third Party Claims and the Declaratory 
Judgment Action. The settlement did not affect the Related 
Federal Cases or the IKB Action, which remain pending. 

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 April 2020. 

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 $2.6 billion as of 
December 31, 2019. 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. 

Wells Fargo & Company 

195 

  
 
 
Note 18:  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 
qualifying hedge accounting relationships (fair value or cash flow 
hedges). Our remaining derivatives consist of economic hedges 
that do not qualify for hedge accounting and derivatives held for 
customer accommodation trading or other purposes. 

Risk management derivatives 
Our asset/liability management approach to interest rate, 
foreign currency and certain other risks includes the use of 
derivatives, which 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 significant 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 or foreign currency 
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. 

Customer accommodation trading 
We also use 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 
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. 

We mention derivative instruments within several other 
Notes in this Report. For more information on Derivatives, refer 
to the following areas: 
•  Note 1 – Summary of Significant Accounting Policies 
•  Note 4 – Trading Activities 
•  Note 8 – Equity Securities 
•  Note 10 – Securitizations and Variable Interest Entities 
•  Note 11 – Mortgage Banking Activities 
•  Note 15 – Long-Term Debt 
•  Note 16 – Guarantees, Pledged Assets and Collateral, and 

Other Commitments 

•  Note 19 – Fair Values of Assets and Liabilities 
•  Note 24 – Income Taxes 
•  Note 26 – Other Comprehensive Income 
•  Note 28 – Parent-Only Financial Statements 

196 

Wells Fargo & Company 

 
Table 18.1 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. 

Table 18.1:  Notional or Contractual Amounts and Fair Values of Derivatives 

(in millions) 

Derivatives designated as hedging instruments 

Interest rate contracts 

Foreign exchange contracts 

Total derivatives designated as qualifying hedging instruments 

Derivatives not designated as hedging instruments 

Economic hedges: 

Interest rate contracts 

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 

Total 

December 31, 2019 

December 31, 2018 

Notional or 

Fair value 

Notional or 

Fair value 

contractual 

Derivative 

Derivative 

contractual 

Derivative 

Derivative 

amount 

assets 

liabilities 

amount 

assets 

liabilities 

$ 

182,789 

32,386 

235,810 

19,263 

26,595 

1,400 

2,595 

341 

2,936 

207 

1,126 

118 

27 

1,478 

11,117,542 

21,245 

79,737 

272,145 

364,469 

12,215 

24,030 

1,421 

7,410 

4,755 

12 

69 

34,912 

36,390 

39,326 

1,237 

1,170 

2,407 

160 

224 

286 

— 

670 

17,969 

1,770 

10,240 

4,791 

65 

18 

34,853 

35,523 

37,930 

177,511 

34,176 

173,215 

13,920 

19,521 

100 

2,237 

573 

2,810 

849 

1,362 

225 

27 

2,463 

636 

1,376 

2,012 

369 

79 

80 

— 

528 

9,162,821 

15,349 

15,303 

66,173 

217,890 

364,982 

11,741 

20,880 

1,588 

6,183 

5,916 

76 

175 

29,287 

31,750 

34,560 

2,336 

5,931 

5,657 

182 

98 

29,507 

30,035 

32,047 

(25,123) 

(28,851) 

$ 

14,203 

9,079 

(23,790) 

(23,548) 

10,770 

8,499 

Wells Fargo & Company 

197 

  
 
 
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 18.2 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 OTC 
markets include bilateral contractual arrangements that are not 
cleared through a central clearing organization but are typically 
subject to enforceable master netting arrangements. Other 
derivative contracts that are settled through a central clearing 
organization whether OTC or exchange-traded, are excluded 
from that 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 16 (Guarantees, Pledged Assets and Collateral, and Other 
Commitments). 

Note 18:  Derivatives (continued) 

Table 18.2 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 $33.7 billion and 
$33.5 billion of gross derivative assets and liabilities, respectively, 
at December 31, 2019, and $30.9 billion and $28.4 billion, 
respectively, at December 31, 2018, with counterparties subject 
to enforceable master netting arrangements that are eligible for 
balance sheet netting adjustments. The majority of these 
amounts are interest rate contracts executed in over-the-
counter (OTC) markets. The remaining gross derivative assets 
and liabilities of $5.6 billion and $4.4 billion, respectively, at 
December 31, 2019, and $3.7 billion and $3.6 billion, 
respectively, at December 31, 2018, 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. Cash collateral receivables and payables 
that have not been offset against our derivatives were 
$6.3 billion and $1.4 billion, respectively, at December 31, 2019, 
and $4.8 billion and $1.4 billion, respectively, at December 31, 
2018. 

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. 

198 

Wells Fargo & Company 

 
Table 18.2:  Gross Fair Values of Derivative Assets and Liabilities 

(in millions) 

December 31, 2019 

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 

Total derivative liabilities 

December 31, 2018 

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 

Gross amounts 
recognized 

Gross amounts 
offset in 
consolidated 
balance sheet (1) 

Net amounts in 
consolidated 
balance sheet 

Gross amounts 
not offset in 
consolidated 
balance sheet 
(Disclosure-only 
netting) 

Net 
amounts 

Percent exchanged 
in over-the-
counter market 

$ 

24,047 

(14,878) 

1,421 

8,536 

5,214 

12 

96 

(888) 

(5,570) 

(3,722) 

(9) 

(56) 

9,169 

533 

2,966 

1,492 

3 

40 

(445) 

(2) 

(69) 

(22) 

— 

(1) 

8,724 

531 

2,897 

1,470 

3 

39 

$ 

$ 

$ 

$ 

$ 

$ 

39,326 

(25,123) 

14,203 

(539) 

13,664 

19,366 

1,770 

10,464 

6,247 

65 

18 

(16,595) 

(677) 

(6,647) 

(4,866) 

(60) 

(6) 

37,930 

(28,851) 

18,435 

(12,029) 

1,588 

7,545 

6,714 

76 

202 

(849) 

(5,318) 

(5,355) 

(73) 

(166) 

2,771 

1,093 

3,817 

1,381 

5 

12 

9,079 

6,406 

739 

2,227 

1,359 

3 

36 

(545) 

(2) 

(319) 

(169) 

(3) 

— 

2,226 

1,091 

3,498 

1,212 

2 

12 

(1,038) 

8,041 

(80) 

(4) 

(755) 

(35) 

— 

(1) 

6,326 

735 

1,472 

1,324 

3 

35 

34,560 

(23,790) 

10,770 

(875) 

9,895 

16,308 

(13,152) 

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) 

(8) 

(110) 

(188) 

(2) 

— 

2,589 

1,601 

2,023 

1,403 

— 

8 

95% 

80 

65 

100 

84 

97 

94% 

82 

81 

100 

98 

93 

90% 

57 

78 

100 

12 

78 

92% 

85 

75 

100 

67 

11 

Total derivative liabilities 

$ 

32,047 

(23,548) 

8,499 

(875) 

7,624 

(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 related to derivative assets were $231 million and $353 million and debit valuation adjustments related to derivative 
liabilities were $100 million and $152 million as of December 31, 2019 and 2018, respectively. Cash collateral totaled $2.9 billion and $6.8 billion, netted against derivative assets and liabilities, 
respectively, at December 31, 2019, and $3.7 billion and $3.6 billion, respectively, at December 31, 2018. 

Wells Fargo & Company 

199 

  
 
 
Note 18:  Derivatives (continued) 

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 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 26 (Other 
Comprehensive Income) for the amounts recognized in other 
comprehensive income. 

Table 18.3:  Gains (Losses) Recognized on Fair Value Hedging Relationships 

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 also 
use cross-currency swaps to hedge variability in interest 
payments on fixed-rate foreign currency-denominated long-
term debt due to changes in foreign exchange rates. 

We estimate $221 million pre-tax of deferred net losses 
related to cash flow hedges in OCI at December 31, 2019, will be 
reclassified into net interest income during the next twelve 
months. The deferred losses expected to be reclassified into net 
interest income are predominantly related to discontinued 
hedges of floating rate loans. For cash flow hedges as of 
December 31, 2019, we are hedging our foreign currency 
exposure to the variability of future cash flows for all forecasted 
transactions for a maximum of 11 years. 

Table 18.3 and Table 18.4 show the net gains (losses) related 

to derivatives in fair value and cash flow hedging relationships, 
respectively. 

(in millions) 

Year Ended December 31, 2019 

Net interest income 

Noninterest 
income 

Total 
recorded 
in net 
income 

Total 
recorded 
in OCI 

Debt 
securities 

Mortgage 
loans held 

for sale  Deposits 

Long-
term debt 

Derivative 
gains 
(losses) 

Derivative 
gains 
(losses) 

Other 

Total amounts presented in the consolidated statement of income and

other comprehensive income 

$  14,955 

813 

(8,635) 

(7,350) 

3,181 

N/A 

275 

Interest contracts 

Amounts related to interest settlements on derivatives 

Recognized on derivatives 

Recognized on hedged items 

Total gains (losses) (pre-tax) on interest rate contracts 

Foreign exchange contracts 

Amounts related to interest settlements on derivatives 

Recognized on derivatives 

Recognized on hedged items 

Total gains (losses) (pre-tax) on foreign exchange contracts 

Total gains (losses) (pre-tax) recognized on fair value hedges 

$ 

(continued on following page) 

— 

(2,082) 

2,096 

14 

35 

(5) 

6 

36 

50 

2 

1 

(7) 

(4) 

— 

— 

— 

— 

(4) 

58 

463 

169 

5,001 

(442) 

(4,910) 

79 

— 

— 

— 

— 

79 

260 

(483) 

308 

(289) 

(464) 

(204) 

— 

— 

— 

— 

— 

(358) 

350 

(8) 

(8) 

229 

3,383 

(3,263) 

349 

(448) 

(55) 

67 

(436) 

(87) 

— 

— 

(3) 

(3) 

(3) 

200 

Wells Fargo & Company 

 
  
 
(continued from previous page) 

(in millions) 

Year ended December 31, 2018 

Total amounts presented in the consolidated statement of income and other 

comprehensive income 

Interest contracts 

Amounts related to interest settlements on derivatives 

Recognized on derivatives 

Recognized on hedged items 

Total gains (losses) (pre-tax) on interest rate contracts 

Foreign exchange contracts 

Amounts related to interest settlements on derivatives 

Recognized on derivatives 

Recognized on hedged items 

Total gains (losses) (pre-tax) on foreign exchange contracts 

Net interest income 

Noninterest 
income 

Total 
recorded 
in net 
income 

Total 
recorded 
in OCI 

Debt 
securities 

Mortgage 
loans held 

for sale  Deposits 

Long-
term debt 

Derivative 
gains 
(losses) 

Derivative 
gains 
(losses) 

Other 

$  14,406 

777 

(5,622) 

(6,703) 

2,473 

N/A 

(238) 

(187) 

845 

(877) 

(219) 

33 

7 

(1) 

39 

(3) 

15 

(22) 

(10) 

— 

— 

— 

— 

(41) 

27 

(33) 

(47) 

— 

— 

— 

— 

292 

(1,923) 

1,843 

212 

(434) 

135 

(82) 

(381) 

(169) 

— 

— 

— 

— 

— 

61 

(1,035) 

910 

(64) 

(401) 

— 

— 

(1,204) 

(1,062) 

(254) 

1,114 

1,031 

(90) 

(90) 

(432) 

(496) 

(254) 

(254) 

Total gains (losses) (pre-tax) recognized on fair value hedges 

$ 

(180) 

(10) 

(47) 

Year ended December 31, 2017 

Total amounts presented in the consolidated statement of income and other 

comprehensive income 

Interest contracts 

$  12,946 

786 

(3,013) 

(5,157) 

1,603 

N/A 

(1,083) 

Amounts related to interest settlements on derivatives 

Recognized on derivatives 

Recognized on hedged items 

(469) 

(43) 

(52) 

(5) 

(5) 

(4) 

Total gains (losses) (pre-tax) on interest rate contracts 

(564) 

(14) 

Foreign exchange contracts 

Amounts related to interest settlements on derivatives 

Recognized on derivatives 

Recognized on hedged items 

Total gains (losses) (pre-tax) on foreign exchange contracts 

14 

13 

(10) 

17 

— 

— 

— 

— 

Total gains (losses) (pre-tax) recognized on fair value hedges 

$ 

(547) 

(14) 

36 

(20) 

36 

52 

— 

— 

— 

— 

52 

1,286 

(912) 

938 

1,312 

(210) 

(230) 

255 

(185) 

1,127 

— 

— 

— 

— 

— 

3,118 

847 

(979) 

917 

785 

(196) 

2,901 

(2,855) 

(2,610) 

263 

263 

95 

880 

— 

— 

(253) 

(253) 

(253) 

Wells Fargo & Company 

201 

 
Note 18:  Derivatives (continued) 

Table 18.4:  Gains (Losses) Recognized on Cash Flow Hedging Relationships 

(in millions) 

Year Ended December 31, 2019 

Net interest income 

Total 
recorded in 
net income 

Total 
recorded in 
OCI 

Loans 

Long-term 
debt 

Derivative 
gains (losses) 

Derivative 
gains (losses) 

Total amounts presented in the consolidated statement of income and other comprehensive income 

$ 

44,146 

(7,350) 

N/A 

Interest rate contracts: 

Realized gains (losses) (pre-tax) reclassified from OCI into net income 

Net unrealized gains (losses) (pre-tax) recognized in OCI 

Total gains (losses) (pre-tax) on interest rate contracts 

Foreign exchange contracts: 

Realized gains (losses) (pre-tax) reclassified from OCI into net income 

Net unrealized gains (losses) (pre-tax) recognized in OCI 

Total gains (losses) (pre-tax) on foreign exchange contracts 

Total gains (losses) (pre-tax) recognized on cash flow hedges 

Year ended December 31, 2018 

Total amounts presented in the consolidated statement of income and other comprehensive income 

Interest rate contracts: 

Realized gains (losses) (pre-tax) reclassified from OCI into net income 

Net unrealized gains (losses) (pre-tax) recognized in OCI 

Total gains (losses) (pre-tax) on interest rate contracts 

Foreign exchange contracts: 

Realized gains (losses) (pre-tax) reclassified from OCI into net income 

Net unrealized gains (losses) (pre-tax) recognized in OCI 

Total gains (losses) (pre-tax) on foreign exchange contracts 

$ 

$ 

(291) 

N/A 

(291) 

— 

N/A 

— 

(291) 

1 

N/A 

1 

(9) 

N/A 

(9) 

(8) 

(290) 

N/A 

(290) 

(9) 

N/A 

(9) 

(299) 

275 

290 

— 

290 

9 

(21) 

(12) 

278 

43,974 

(6,703) 

N/A 

(238) 

(292) 

N/A 

(292) 

— 

N/A 

— 

1 

N/A 

1 

(3) 

N/A 

(3) 

(2) 

(291) 

N/A 

(291) 

(3) 

N/A 

(3) 

(294) 

291 

(266) 

25 

3 

(12) 

(9) 

16 

Total gains (losses) (pre-tax) recognized on cash flow hedges 

$ 

(292) 

Year ended December 31, 2017 

Total amounts presented in the consolidated statement of income and other comprehensive income 

$ 

41,388 

(5,157) 

N/A 

(1,083) 

Interest rate contracts: 

Realized gains (losses) (pre-tax) reclassified from OCI into net income 

Net unrealized gains (losses) (pre-tax) recognized in OCI 

Total gains (losses) (pre-tax) on interest rate contracts 

Foreign exchange contracts: 

Realized gains (losses) (pre-tax) reclassified from OCI into net income 

Net unrealized gains (losses) (pre-tax) recognized in OCI 

Total gains (losses) (pre-tax) on foreign exchange contracts 

Total gains (losses) (pre-tax) recognized on cash flow hedges 

$ 

551 

N/A 

551 

— 

N/A 

— 

551 

(8) 

N/A 

(8) 

— 

N/A 

— 

(8) 

543 

N/A 

543 

— 

N/A 

— 

543 

(543) 

(287) 

(830) 

— 

— 

— 

(830) 

202 

Wells Fargo & Company 

  
 
 
Table 18.5 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 18.5:  Hedged Items in Fair Value Hedging Relationship 

(in millions) 

December 31, 2019 

Available-for-sale debt securities (5) 

Mortgage loans held for sale 

Deposits 

Long-term debt 

December 31, 2018 

Available-for-sale debt securities (5) 

Mortgage loans held for sale 

Deposits 

Long-term debt 

Hedged Items Currently Designated 

Hedged Items No Longer Designated (1) 

Carrying Amount of 
Assets/(Liabilities) (2)(4) 

Hedge Accounting 
Basis Adjustment 
Assets/(Liabilities) (3) 

Carrying Amount of 
Assets/(Liabilities) (4) 

Hedge Accounting 
Basis Adjustment 
Assets/(Liabilities) 

$ 

$ 

36,896 

961 

(43,716) 

(127,423) 

37,857 

448 

(56,535) 

(104,341) 

1,110 

(12) 

(324) 

(5,827) 

(157) 

7 

115 

(742) 

9,486 

— 

— 

(25,750) 

4,938 

— 

— 

(25,539) 

278 

— 

— 

173 

238 

— 

— 

366 

(1) 
(2) 

(3) 

(4) 

(5) 

Represents hedged items no longer designated in qualifying fair value hedging relationships for which an associated basis adjustment exists at the balance sheet date. 
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 $1.2 billion and for long-
term debt is $(5.2) billion as of December 31, 2019, and $1.6 billion for debt securities and $(6.3) billion for long-term debt as of December 31, 2018. 
The balance includes $790 million and $109 million of debt securities and long-term debt cumulative basis adjustments as of December 31, 2019, respectively, and $1.4 billion and $66 million of 
debt securities and long-term debt cumulative basis adjustments as of December 31, 2018, respectively, on terminated hedges whereby the hedged items have subsequently been re-designated 
into existing hedges. 
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. 
Carrying amount represents the amortized cost. 

Derivatives Not Designated as Hedging Instruments 
Derivatives not designated as hedging instruments include 
economic hedges and derivatives entered into for customer 
accommodation trading purposes. 

We use economic hedge derivatives to manage our exposure 

to interest rate risk, equity price risk, foreign currency risk, and 
credit risk. 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.  

Mortgage Banking Activities 
We use economic hedge derivatives in our mortgage banking 
business to hedge the risk of changes in the fair value of (1) 
certain residential MSRs measured at fair value, (2) residential 
MLHFS, (3) derivative loan commitments, and (4) other interests 
held. The types of derivatives used include swaps, swaptions, 
constant maturity mortgages, forwards, Eurodollar and Treasury 
futures and options contracts. Loan commitments for mortgage 
loans that we intend to sell are considered derivatives. 
Residential MSRs, derivative loan commitments, certain 
residential MLHFS, and our economic hedge derivatives are 
carried at fair value with changes in fair value included in 
mortgage banking noninterest income. See Note 11 (Mortgage 
Banking Activities) for additional information on this economic 
hedging activity and mortgage banking income. 

Customer Accommodation Trading and Other 
For customer accommodation trading purposes, we use swaps, 
futures, forwards, spots and options to assist our customers in 
managing their own risks, including interest rate, commodity, 
equity, foreign exchange, and credit contracts. 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 note is linked to an equity, 
commodity or 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. 

Wells Fargo & Company 

203 

  
 
 
 
Note 18:  Derivatives (continued) 

Table 18.6 shows the net gains (losses), recognized by 
income statement lines, related to derivatives not designated as 
hedging instruments. 

Table 18.6:  Gains (Losses) on Derivatives Not Designated as Hedging Instruments  

(in millions) 

Year ended December 31, 2019 

Net gains (losses) recognized on economic hedges

derivatives: 

Interest contracts (1) 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Subtotal 

Net gains (losses) recognized on customer

accommodation trading and other derivatives: 

Interest contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Subtotal 

Net gains (losses) recognized related to derivatives not

designated as hedging instruments 

$ 

(Continued on following page) 

Mortgage banking 

Net gains (losses)  Net gains (losses)
from trading
activities 

from equity 
securities 

Noninterest income 

Other 

Total 

$ 

2,177 

— 

— 

— 

— 

(2,120) 

— 

— 

2,177 

(2,120) 

— 

— 

— 

— 

— 

(95) 

164 

(4,863) 

47 

(120) 

(4,867) 

1 

(2) 

(77) 

(5) 

(83) 

— 

— 

(484) 

— 

— 

(484) 

(567) 

2,178 

(2,122) 

(77) 

(5) 

(26) 

323 

164 

(5,347) 

47 

(120) 

(4,933) 

(4,959) 

418 

— 

— 

— 

— 

418 

2,595 

— 

— 

— 

— 

— 

— 

(2,120) 

(4,867) 

204 

Wells Fargo & Company 

  
 
(continued from previous page) 

(in millions) 

Year ended December 31, 2018 

Net gains (losses) recognized on economic hedges 

derivatives: 

Interest contracts (1) 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Subtotal 

Net gains (losses) recognized on customer 

accommodation trading and other derivatives: 

Interest contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Subtotal 

$ 

$ 

Net gains (losses) recognized related to derivatives 

not designated as hedging instruments 

Year ended December 31, 2017 

Net gains (losses) recognized on economic hedges 

derivatives: 

Interest contracts (1) 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Subtotal 

Net gains (losses) recognized on customer 

accommodation trading and other derivatives: 

Interest contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Subtotal 

Net gains (losses) recognized related to derivatives 

not designated as hedging instruments 

$ 

Mortgage banking 

Net gains (losses) 
from equity 
securities 

Net gains (losses) 
from trading 
activities 

Noninterest income 

Other 

Total 

$ 

(215) 

— 

— 

— 

(215) 

(352) 

— 

— 

— 

— 

(352) 

(567) 

448 

— 

— 

— 

448 

614 

— 

— 

— 

— 

614 

1,062 

— 

(408) 

— 

— 

(408) 

— 

— 

— 

— 

— 

— 

(408) 

— 

(1,483) 

— 

— 

(1,483) 

— 

— 

— 

— 

— 

— 

(1,483) 

— 

— 

— 

— 

— 

446 

83 

4,499 

638 

1 

5,667 

5,667 

— 

— 

— 

— 

— 

160 

178 

(3,932) 

638 

(81) 

(3,037) 

(3,037) 

(15) 

4 

669 

— 

658 

— 

— 

(403) 

— 

— 

(403) 

255 

(75) 

17 

(866) 

5 

(919) 

— 

— 

1 

— 

— 

1 

(918) 

(230) 

(404) 

669 

— 

35 

94 

83 

4,096 

638 

1 

4,912 

4,947 

373 

(1,466) 

(866) 

5 

(1,954) 

774 

178 

(3,931) 

638 

(81) 

(2,422) 

(4,376) 

(1)  Mortgage banking amounts for the years ended December 31, 2019, 2018 and 2017, are comprised of gains (losses) of $2.3 billion, $(1.1) billion and $413 million, respectively, related to derivatives 
used as economic hedges of MSRs measured at fair value offset by gains (losses) of $(141) million, $857 million and $35 million, respectively, related to derivatives used as economic hedges of 
mortgage loans held for sale and derivative loan commitments. 

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 18.7 provides details of sold and purchased credit 

derivatives. 

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 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 

Wells Fargo & Company 

205 

 
 
Note 18:  Derivatives (continued) 

Table 18.7:  Sold and Purchased Credit Derivatives 

(in millions) 

December 31, 2019 

Credit default swaps on: 

Corporate bonds 

Structured products 

Credit protection on: 

Default swap index 

Commercial mortgage-backed securities index 

Asset-backed securities index 

Other 

Total credit derivatives 

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 

Total credit derivatives 

Fair value 
asset 

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 

$ 

$ 

$ 

$ 

8 

— 

1 

3 

— 

— 

12 

38 

— 

37 

1 

— 

— 

76 

1 

25 

— 

26 

8 

5 

65 

59 

62 

1 

49 

9 

2 

2,855 

74 

2,542 

322 

41 

6,381 

12,215 

2,037 

133 

3,618 

389 

42 

5,522 

182 

11,741 

707 

69 

120 

67 

41 

5,738 

6,742 

441 

128 

582 

109 

42 

5,327 

6,629 

1,885 

63 

550 

296 

41 

— 

2,835 

1,374 

121 

1,998 

363 

42 

— 

3,898 

970 

11 

2,447 

2020 - 2029 

111 

2022 - 2047 

1,992 

8,105 

2020 - 2029 

26 

— 

6,381 

9,380 

50 

1 

2047 - 2058 

2045 - 2046 

11,881 

2020 - 2049 

22,595 

663 

12 

1,460 

2019 - 2027 

113 

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 

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. Table 18.8 
illustrates our exposure to such derivatives with credit-risk 
contingent features, collateral we have posted, and the 
additional collateral we would be required to post if the credit 
rating of our debt was downgraded below investment grade. 

Table 18.8:  Credit-Risk Contingent Features 

(in billions) 

Dec 31, 

2019 

Dec 31, 

2018 

Net derivative liabilities with credit-risk 

contingent features 

$ 

Collateral posted 

Additional collateral to be posted upon a below 

investment grade credit rating (1) 

10.4 

9.1 

1.3 

7.4 

5.6 

1.8 

(1)  Any credit rating below investment grade requires us to post the maximum 

amount of collateral 

206 

Wells Fargo & Company 

  
 
 
 
  
 
 
Note 19:  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 19.2 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 
19.11 in this Note. Table 19.17 includes estimates of fair value 
for financial instruments that are not recorded at fair value. 

FAIR VALUE HIERARCHY  We classify our assets and liabilities 
measured at fair value as either Level 1, Level 2 or Level 3 in the 
fair value hierarchy. The highest priority (Level 1) is assigned to 
valuations based on unadjusted quoted prices in active markets 
and the lowest priority (Level 3) is assigned to valuations based 
on significant unobservable inputs. See Note 1 (Summary of 
Significant Accounting Policies) for a detailed description of 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.

 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. 

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 pricing services. These services 
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 pricing services 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 pricing 
service prices, considerations include the range and quality of 
pricing service prices. Pricing service 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 third party pricing 
service 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  AFS debt securities are recorded at fair value on a 
recurring basis and HTM debt securities are recorded at 
amortized cost. HTM debt securities are subject to impairment 
and written down to fair value if 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. Where available, we use quoted prices in active 
markets. When instruments are traded in secondary markets and 
quoted market prices do not exist for such securities, we 
predominantly use prices obtained from third-party pricing 
services and, to a lesser extent, may use prices obtained from 
independent broker-dealers (brokers), collectively vendor prices. 

When vendor prices are deemed inappropriate by a trader 

who has knowledge of a particular market, vendor prices may be 
adjusted by weighting them with values from internal models. 
We also use internal models when no vendor prices are available. 
Internal models typically use discounted cash flow techniques or 
pricing models that make adjustments to quoted market prices 
for similar securities. 

MORTGAGE LOANS HELD FOR SALE (MLHFS)  We carry most of our 
residential MLHFS portfolio at fair value on a recurring basis. We 
carry our commercial MLHFS and certain residential MLHFS at 
LOCOM which may be written down to fair value on a 
nonrecurring basis. Fair value for both residential and commercial 
mortgages is based on quoted market prices, where available, or 
the prices for other mortgage whole loans with similar 
characteristics. We may use securitization prices that are 
adjusted for typical securitization activities including servicing 
value, portfolio composition, market conditions and liquidity. 
Where market pricing data is not available, we use a discounted 
cash flow model to estimate fair value. 

LOANS HELD FOR SALE (LHFS)  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 carried at LOCOM, which are 
generally consumer loans, are subject to nonrecurring fair value 
adjustments. Fair value is determined based on pending 
transactions when available, or estimated using a discounted 
cash flow model. 

LOANS  Although most loans are recorded at amortized cost, 
reverse mortgages are recorded at fair value on a recurring basis 
and are valued using a discounted cash flow model. In addition, 

Wells Fargo & Company 

207 

 
 
 
 
Note 19:  Fair Values of Assets and Liabilities (continued) 

we record nonrecurring fair value adjustments to loans carried at 
amortized cost to reflect partial write-downs that are based on 
the observable market price of the loan or current appraised 
value of the collateral. 

We also provide fair value estimates 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 valuations include the use of available 
market prices for our exchange-traded derivatives, such as 
certain interest rate futures and option contracts. 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. The 
classification of derivatives between Level 2 and Level 3 of the 
fair value hierarchy can be particularly subjective. Examples of 
derivatives typically classified as Level 2 include generic interest 
rate swaps, foreign currency swaps, commodity swaps, and 
certain option and forward contracts. Examples of derivatives 
classified as Level 3 may include derivative loan commitments 
written for our mortgage loans that we intend to sell, long-dated 
equity options where volatility is not observable, credit risk 
participation swaps, and complex and highly structured 
derivatives. 

MORTGAGE SERVICING RIGHTS (MSRs)  Residential MSRs are 
carried at fair value on a recurring basis, and commercial MSRs, 
which are carried at LOCOM, will be written down to fair value if 
impaired. MSRs do not trade in an active market with readily 
observable prices. We determine the fair value of MSRs using a 
valuation model that estimates the present value of expected 
future net servicing income. 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 for 
residential MSRs), discount rates, default rates, cost to service 
(including delinquency and foreclosure costs), escrow account 
earnings, contractual servicing fee income, ancillary income and 
late fees. Our valuation approach is validated by our internal 
valuation model validation group. Changes in the fair value of 
MSRs reflect the collection/realization of expected cash flows as 
well as changes in valuation inputs and assumptions. Fair value 
measurements of our MSRs use significant unobservable inputs 
and, accordingly, we classify them as Level 3. 

EQUITY SECURITIES  Marketable equity securities and certain 
nonmarketable equity securities 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 and can be subject to 
nonrecurring fair value adjustments to record impairment. The 
carrying value of equity securities accounted for under the 
measurement alternative are also remeasured to fair value upon 

the occurrence of orderly observable transactions of the same or 
similar securities of the same issuer. 

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, generally 
market comparable pricing, to determine fair value for such 
securities. We use all available information in making this 
determination, which includes observable transaction prices for 
the same or similar security, third-party pricing service 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 are Federal Reserve Bank 
stock and Federal Home Loan Bank stock, for which carrying 
values approximate 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. 

Liabilities 
DEPOSIT AND SHORT-TERM FINANCIAL LIABILITIES  Deposit and 
short-term financial liabilities including federal funds purchased, 
securities sold under repurchase agreements, commercial paper 
and other short-term borrowings, are recorded at historical cost. 
Carrying value is a reasonable estimate of fair value for short-
term financial liabilities because of the relatively short time 
between their origination and expected realization. Fair values 
for deposits with contractual or defined maturities are estimated 
using discounted cash flow models. We are not required to 
estimate fair values for deposits with indeterminate maturities. 

OTHER LIABILITIES  Other liabilities recorded at fair value on a 
recurring basis predominantly include short sale liabilities. We 
value these instruments using quoted prices in active markets, 
where available. When quoted prices for the same instruments 
are not available or markets are not active, fair values are 
estimated using recent trades of similar securities. 

LONG-TERM DEBT  Our long-term debt is largely denominated in 
U.S. dollars and issued with a fixed or floating rate at varying 
levels of seniority and maturity. The long-term debt is recorded 
at amortized cost. We utilize third-party pricing service prices, 
discounted cash flow models, or a combination of the two when 
estimating fair value of our long-term debt. 

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 vendor pricing services. Our valuation 
processes vary depending on which approach is utilized. 

INTERNAL MODEL VALUATIONS  Many of our Level 3 fair value 
estimates are based on internally-developed models, which 
typically involve use of discounted cash flow or market 
comparable pricing techniques. Some of the inputs used in these 
valuations are unobservable. Unobservable inputs are generally 

208 

Wells Fargo & Company 

 
derived from historic performance of similar assets or 
determined from previous market trades in similar instruments. 
Unobservable inputs usually include discount rates, default rates, 
loss severity upon default, volatilities, correlations and 
prepayment rates. Such unobservable inputs can be correlated to 
similar portfolios with known historical experience or recent 
trades where particular unobservable inputs may be implied. We 
attempt to correlate each unobservable input to historical 
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. Model validation helps ensure 
our models are appropriate for intended use and appropriate 
controls exist to help mitigate risk of invalid valuations. Model 
validation assesses the adequacy and appropriateness of our 
models, 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. 

We also have ongoing monitoring procedures in place for our 

Level 3 assets and liabilities that use internal valuation models. 
These procedures, which are designed to provide reasonable 
assurance that models continue to perform as expected, 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 fluctuations in 
value. 

• 

• 

VENDOR-DEVELOPED VALUATIONS  We routinely obtain pricing 
from third-party vendors to value our assets or liabilities. In 
certain limited circumstances, this includes our Level 3 assets or 
liabilities. We have processes in place to approve and periodically 
review third-party vendors to ensure information obtained and 
valuation techniques used are appropriate. This review may 
consist of, among other things, obtaining and evaluating control 
reports issued and pricing methodology materials distributed. 
We monitor and review vendor prices on an ongoing basis to 
ensure the fair values are reasonable and in line with market 
experience in similar asset classes. While the inputs used to 
determine fair value are not provided by the pricing vendors, and 
therefore unavailable for our review, we perform one or more of 
the following procedures to validate the pricing information and 
determine appropriate classification within the fair value 
hierarchy: 
• 
• 
• 

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; 
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. 

• 

• 

We update model inputs and methodologies periodically to 

reflect these monitoring procedures. Additionally, 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 subject to additional 
oversight by corporate-level risk management. 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. 

Wells Fargo & Company 

209 

 
Note 19:  Fair Values of Assets and Liabilities (continued) 

Fair Value Measurements from Vendors 
For certain assets and liabilities, we obtain fair value 
measurements from vendors and we 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 the same procedures and controls as stated in the 
“Vendor-Developed Valuations” section. 

Table 19.1 presents unadjusted fair value measurements 

obtained from third-party pricing services classified within the 
fair value hierarchy. Unadjusted fair value measurements 

obtained from brokers and fair value measurements obtained 
from brokers or third-party pricing services that we have 
adjusted to determine the fair value are excluded from Table 
19.1. 

The unadjusted fair value measurements obtained from 
brokers for AFS debt securities were $45 million in Level 2 assets 
and $126 million in Level 3 assets at December 31, 2019, and 
$45 million and $129 million at December 31, 2018, respectively. 

Table 19.1:  Fair Value Measurements obtained from Third-Party Pricing Services 

(in millions) 

Level 1 

Level 2 

Level 3 

Level 1 

Level 2 

Level 3 

December 31, 2019 

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 

$ 

634 

329 

13,460 

— 

— 

— 

13,460 

— 

—

— 

12 

(11) 

1,500 

39,868 

167,172 

38,067 

246,607 

110 

—

110 

1

(3) 

— 

— 

34 

42 

650 

726 

— 

— 

— 

— 

— 

899 

256 

10,399 

— 

— 

— 

10,399 

— 

— 

— 

17 

(12) 

2,949 

48,377 

160,162 

44,292 

255,780 

158 

1

159 

— 

— 

— 

— 

43 

41 

758 

842 

— 

— 

— 

— 

— 

(1) 

Includes corporate debt securities, collateralized loan and other debt obligations, asset-backed securities, and other debt securities. 

210 

Wells Fargo & Company 

  
 
Assets and Liabilities Recorded at Fair Value on a 
Recurring Basis 
Table 19.2 presents the balances of assets and liabilities recorded 
at fair value on a recurring basis. 

Table 19.2:  Fair Value on a Recurring Basis 

(in millions) 

December 31, 2019 
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 
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 (3) 

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 (1) 

Total 

$ 

$ 

$ 

32,335 
— 
— 
— 
— 
— 
— 
32,335 

13,460 

— 

— 
— 
— 

— 

37 
— 

— 
— 
— 

— 
— 

13,497 

— 
— 
— 
— 

26 
— 
2,946 
12 
— 
— 

2,984 

33,702 

— 

33,702 

82,518 

(23) 
— 
(2,011) 
(11) 
— 
— 

(2,045) 

(9,035) 
— 
— 
(2,447) 
— 

(11,482) 

— 

4,382 
2,434 
555 
11,006 
27,712 
1,081 
5 
47,175 

1,500 

39,924 

162,453 
827 
3,892 

167,172 

6,159 
29,055 

951 
— 
3,635 

4,586 
1 

248,397 

15,408 
956 
— 
— 

23,792 
1,413 
4,135 
5,197 
49 
— 

34,586 

216 

22 

238 

346,760 

(19,328) 
(1,746) 
(6,729) 
(6,213) 
(53) 
— 

(34,069) 

(31) 
(2) 
(5,915) 
— 
— 

(5,948) 

— 

— 
— 
183 
38 
— 
— 
2 
223 

— 

413 

— 
— 
42 

42 

367 
640 

— 
— 
103 

103 
— 

1,565  (2) 

1,198 
16 
171 
11,517 

229 
8 
1,455 
5 
59 
— 

1,756 

3 

7,847 

7,850 

24,296 

(15) 
(24) 
(1,724) 
(23) 
(30) 
— 

(1,816) 

— 
— 
— 
— 
— 

— 

(2) 

(1,818) 

— 
— 
— 
— 
— 
— 
— 
— 

— 

— 

— 
— 
— 

— 

— 
— 

— 
— 
— 

— 
— 

— 

— 
— 
— 
— 

— 
— 
— 
— 
— 
(25,123) 

(25,123) 

— 

— 

— 

(25,123) 

— 
— 
— 
— 
— 
28,851 

28,851 

— 
— 
— 
— 
— 

— 

— 

28,851 

36,717 
2,434 
738 
11,044 
27,712 
1,081 
7 
79,733 

14,960 

40,337 

162,453 
827 
3,934 

167,214 

6,563 
29,695 

951 
— 
3,738 
4,689 

1 

263,459 

16,606 
972 
171 
11,517 

24,047 
1,421 
8,536 
5,214 
108 
(25,123) 

14,203 

33,921 

7,869 

41,790

428,451 

146 

428,597 

(19,366) 
(1,770) 
(10,464) 
(6,247) 
(83) 
28,851 

(9,079) 

(9,066) 
(2) 
(5,915) 
(2,447) 
— 

(17,430) 

(2) 

(26,511) 

Total liabilities recorded at fair value 

$ 

(13,527) 

(40,017) 

(1) 

(2) 

(3) 

Represents balance sheet netting of derivative asset and liability balances, related cash collateral and portfolio level counterparty valuation adjustments. See Note 18 (Derivatives) for additional 
information. 
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. 
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) 

Wells Fargo & Company 

211 

  
  
 
Note 19:  Fair Values of Assets and Liabilities (continued) 

(continued from previous page) 

(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 
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 (3) 

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 (1) 

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) 

(23,790) 

— 

— 

— 

(23,790) 

— 
— 
— 
— 
— 
23,548 

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 

(1) 

(2) 

(3) 

Represents balance sheet netting of derivative asset and liability balances, related cash collateral and portfolio level counterparty valuation adjustments. See Note 18 (Derivatives) for additional 
information. 
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. 
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. 

212 

Wells Fargo & Company 

 
 
The changes in Level 3 assets and liabilities measured at fair value on a recurring basis for the year ended December 31, 2019, 

are presented in Table 19.3. 

Table 19.3:  Changes in Level 3 Fair Value Assets and Liabilities on a Recurring Basis – 2019 

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, 2019 

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 

3 

237 

34 
16 

290 

444 

—

41 

41 

370 

800 

389 

389 

2,044 

997 

60 

244 

— 

(30) 

3 
(4) 

(31) 

2 

—

— 

— 

3 

29 

— 

— 

34 

58 

(2) 

— 

Mortgage servicing rights (residential) (8) 

14,649 

(4,779) 

Net derivative assets and liabilities: 

Interest rate contracts 

Commodity contracts 

Equity contracts 

Foreign exchange contracts 

Credit contracts 

Total derivative contracts 

Equity securities: 

Marketable 

Nonmarketable 

Total equity securities 

Other liabilities 

25 

4 

(17) 

(26) 

35 

21 

—

5,468 

5,468 

(2) 

585 

(203) 

(571) 

34 

(7) 

(162) 

—

2,383 

2,383 

— 

— 

— 

— 
— 

— 

2 

— 

— 

— 

(5) 

(37) 

— 

— 

(40) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

(2) 

(22) 

6 
(10) 

(28) 

14 

— 

(5) 

(5) 

(1) 

(152) 

(133) 

(133) 

(277) 

(140) 

(4) 

(73) 

1,647 

(396) 

158 

292 

(26) 

1 

29 

— 

(1) 

(1) 

— 

— 

— 

1 
— 

1 

— 

— 

6 

6 

— 

— 

— 

— 

6 

299 

55 

— 

— 

— 

2 

6 

— 

— 

8 

3 

9 

12 

— 

(1) 

(2) 

(6) 
— 

(9) 

— 

183 

38 
2 

223 

(49) 

413 

—

— 

— 

— 

— 

(153) 

(153) 

(202) 

(16) 

(93) 

— 

— 

— 

23 

21 

— 

— 

44 

— 

(12) 

(12) 

— 

— 

42 

42 

367 

640 

103 

103 

1,565 

1,198 

16 

171 

11,517 

214 

(16) 

(269) 

(18) 

29 

(60) 

3 

7,847 

7,850 

(2) 

— 

(35) 

5 
(1) 

(31)  (5) 

— 

— 

— 

— 

(4) 

— 

— 

— 

(4)  (6) 

54  (7) 

(3) 

(8)  (7) 

(2,569)  (7) 

249 

9 

(186) 

9 

(6) 

75  (9) 

— 

2,386 

2,386  (10) 

—  (7) 

(1) 
(2) 
(3) 
(4) 

(5) 
(6) 
(7) 
(8) 
(9) 
(10) 

See Table 19.4 for detail. 
All assets and liabilities transferred into level 3 were previously classified within level 2. 
All assets and liabilities transferred out of level 3 are classified as level 2, except for $153 million of asset-backed securities that were transferred to loans during third quarter 2019. 
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. 
For more information on the changes in mortgage servicing rights, see Note 11 (Mortgage Banking Activities). 
Included in mortgage banking income, net gains from trading activities and from equity securities, and other noninterest income. 
Included in net gains (losses) from equity securities in the income statement. 

Wells Fargo & Company 

213 

  
 
Note 19:  Fair Values of Assets and Liabilities (continued) 

Table 19.4 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, 2019. 

Table 19.4:  Gross Purchases, Sales, Issuances and Settlements – Level 3 – 2019 

Purchases 

Sales 

Issuances 

Settlements 

Net 

— 

(372) 

(13) 

— 

(385) 

— 

— 

— 

— 

— 

— 

(9) 

(9) 

(9) 

(235) 

(2) 

— 

— 

— 

— 

— 

— 

133 

133 

302 

248 

— 

10 

(286) 

1,933 

— 

— 

— 

— 

(12) 

(12) 

(1) 

(1) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

(2) 

(22) 

— 

(10) 

(34) 

(2) 

(22) 

6 

(10) 

(28) 

169 

(155) 

14 

— 

(5) 

(5) 

(19) 

(307) 

(257) 

(257) 

(743) 

(249) 

(14) 

(86) 

— 

(396) 

158 

292 

(26) 

— 

28 

— 

— 

— 

— 

(5) 

(5) 

(1) 

(152) 

(133) 

(133) 

(277) 

(140) 

(4) 

(73) 

1,647 

(396) 

158 

292 

(26) 

1 

29 

(1) 

(1) 

— 

(in millions) 

Year ended December 31, 2019 

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 

Total derivative contracts 

Equity securities: 

Nonmarketable 

Total equity securities 

Other liabilities 

— 

372 

19 

— 

391 

— 

— 

— 

— 

18 

155 

— 

— 

173 

96 

12 

3 

— 

— 

— 

— 

— 

13 

13 

— 

— 

— 

(1) 

For more information on the changes in mortgage servicing rights, see Note 11 (Mortgage Banking Activities). 

214 

Wells Fargo & Company 

  
 
 
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 19.5. 

Table 19.5:  Changes in Level 3 Fair Value Assets and Liabilities on a Recurring Basis – 2018 

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, 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: 

Other asset-backed securities 

Total asset-backed securities 

Total available-for-sale debt securities 

Mortgage loans held for sale 

Loans held for sale 

Loans 

3 

354 
31 

19 

407 

925 

1 

75 

76 

407 

1,020 

566 

566 

2,994 

998 

14 

376 

— 

(12) 
(1) 

(3) 

(16) 

8 

— 

— 

— 

4 

72 

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 

Total derivative contracts 

Equity securities: 

Marketable 

Nonmarketable (10) 

Total equity securities 

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) 

(344) 

— 

— 

— 

— 

— 

— 

— 

(344) 

(10) 

— 

— 

— 

— 

— 

81 

— 

— 

81 

—

(4) 

(4) 

— 

3 

237 
34 

16 

290 

444 

— 

41 

41 

370 

800 

389 

389 

2,044 

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) 

— 

(7) 

(1) 
(2) 
(3) 
(4) 

See Table 19.6 for detail. 
All assets and liabilities transferred into level 3 were previously classified within level 2. 
All assets and liabilities transferred out of level 3 are classified as level 2. 
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. 
For more information on the changes in mortgage servicing rights, see Note 11 (Mortgage Banking Activities) 
Included in mortgage banking income, net gains from trading activities and from equity securities, and other noninterest income. 

(5) 
(6) 
(7) 
(8) 
(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 ASU 2016-01 in first quarter 

2018. 
Included in net gains (losses) from equity securities in the income statement. 

(11) 

Wells Fargo & Company 

215 

  
 
Note 19:  Fair Values of Assets and Liabilities (continued) 

Table 19.6 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, 2018. 

Table 19.6:  Gross Purchases, Sales, Issuances and Settlements – Level 3 – 2018 

(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: 

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 

Total derivative contracts 

Equity securities: 

Marketable 

Nonmarketable 

Total equity securities 

Other liabilities 

Purchases 

Sales 

Issuances 

Settlements 

Net 

— 

408 

20 

— 

428 

— 

— 

— 

— 

33 

61 

25 

25 

119 

87 

4 

8 

— 

— 

— 

3 

— 

12 

15 

— 

— 

— 

— 

— 

(348) 

(4) 

— 

(352) 

(6) 

— 

— 

— 

— 

(149) 

(12) 

(12) 

(167) 

(320) 

(40) 

— 

(71) 

— 

— 

(37) 

— 

(7) 

(44) 

— 

(51) 

(51) 

— 

— 

— 

— 

— 

— 

79 

— 

— 

— 

— 

— 

166 

166 

245 

353 

— 

17 

2,010 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

(161) 

— 

— 

(161) 

(210) 

(1) 

(33) 

(34) 

(71) 

(209) 

(350) 

(350) 

(874) 

(156) 

— 

(156) 

— 

351 

(11) 

556 

9 

(11) 

894 

— 

(399) 

(399) 

— 

— 

(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) 

— 

(1) 

For more information on the changes in mortgage servicing rights, see Note 11 (Mortgage Banking Activities). 

216 

Wells Fargo & Company 

  
 
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 19.7. 

Table 19.7:  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: 

3 

309 

34 

28 

374 

Securities of U.S. states and political subdivisions 

1,140 

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 

1 

91 

92 

432 

879 

962 

962 

3,505 

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 

(267) 

12 

77 

(47) 

(81) 

—

3,259 

3,259 

— 

(4) 

604 

(17) 

(199) 

(5) 

24 

27 

434 

— 

1,563 

1,563 

— 

1 

— 

3 

2 

(9) 

(4) 

4 

— 

(4) 

(4) 

(1) 

— 

— 

— 

— 

— 

5 

— 

— 

— 

23 

22 

103 

1 

1 

22 

(36) 

1 

(6) 

3 

3 

134 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

42 

(7) 

— 

35 

1,105 

— 

(12) 

(12) 

(47) 

16 

(400) 

(400) 

662 

(75) 

(3) 

(376) 

2,781 

(654) 

13 

(37) 

— 

(65) 

20 

— 

— 

6 

— 

6 

5 

— 

— 

— 

— 

— 

— 

— 

5 

134 

34 

— 

— 

— 

2 

(53) 

— 

— 

— 

(723) 

(51) 

— 

(2) 

(2) 

— 

— 

—

1 

1 

— 

— 

— 

— 

(4) 

— 

(4) 

3 

354 

31 

19 

407 

(1,334) 

925 

— 

— 

— 

— 

— 

— 

— 

1 

75 

76 

407 

1,020 

566 

566 

(1,334) 

2,994 

(10) 

(18) 

— 

— 

— 

(2) 

45 

— 

— 

— 

43 

— 

— 

— 

— 
— 

998 

14 

376 

13,625 

71 

19 

(511) 

7 

36 

— 

(378) 

— 

4,821 

4,821 

— 

(3) 

— 

(13) 

2 

(4) 

(15)  (5) 

— 

— 

(11) 

(11) 

— 

— 

— 

— 

(11)  (6) 

(34)  (7) 

— 

(12)  (7) 

(126)  (7) 

(52) 

15 

(259) 

6 

(62) 

— 

(352)  (9) 

— 

1,569 

1,569 

(10) 

— 

— 

(5) 

(7) 

(1) 
(2) 
(3) 
(4) 

(5) 
(6) 
(7) 
(8) 
(9) 
(10) 

See Table 19.8 for detail. 
All assets and liabilities transferred into level 3 were previously classified within level 2. 
All assets and liabilities transferred out of level 3 are classified as level 2. 
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. 
For more information on the changes in mortgage servicing rights, see Note 11 (Mortgage Banking Activities). 
Included in mortgage banking income, net gains from trading activities and from equity securities, and other noninterest income. 
Included in net gains (losses) from equity securities in the income statement. 

Wells Fargo & Company 

217 

  
 
Note 19:  Fair Values of Assets and Liabilities (continued) 

Table 19.8 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, 2017. 

Table 19.8:  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 

(654) 

13 

81 

— 

(68) 

20 

(608) 

— 

— 

— 

— 

— 

— 

(12) 

(12) 

(47) 

16 

(400) 

(400) 

662 

(75) 

(3) 

(376) 

2,781 

(654) 

13 

(37) 

— 

(65) 

20 

(723) 

— 

(2) 

(2) 

— 

— 

(1) 

For more information on the changes in mortgage servicing rights, see Note 11 (Mortgage Banking Activities). 

Table 19.9 and Table 19.10 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 inherent in the 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 in the 
“Level 3 Asset and Liability Valuation Processes” section within 
this Note regarding vendor-developed valuations). 

significant unobservable inputs for certain classes of Level 3 
assets and liabilities measured using internal models 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. 

Weighted averages of inputs are calculated using 

outstanding unpaid principal balance for cash instruments, such 
as loans and securities, and notional amounts for derivative 
instruments. 

218 

Wells Fargo & Company 

  
 
Table 19.9:  Valuation Techniques – Recurring Basis – December 31, 2019 

($ in millions, except cost to service amounts) 

December 31, 2019 

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 

Corporate debt securities 

Asset-backed securities: 

Diversified payment rights (1) 

Other commercial and consumer 

Mortgage loans held for sale (residential) 

Loans (2) 

Fair Value 
Level 3 

Valuation Technique(s) 

Significant Unobservable
Input 

Range of Inputs 

Weighted 
Average 

$ 

379 

Discounted cash flow 

Discount rate 

1.3 

-

5.4 

% 

2.4 

Vendor priced 

Market comparable pricing 

Comparability adjustment 

(15.0)  -

19.2 

34 

183 

640 

220 

60 

125 

92 

11 

1,183 

15 

171 

Vendor priced 

Discounted cash flow 

Discount rate 

3.2 

Market comparable pricing 

Comparability adjustment 

(19.7) 

Vendor priced 

Discounted cash flow 

Discount rate 

Vendor priced 

Discounted cash flow 

Default rate 

Discount rate 

Loss severity 

Prepayment rate 

2.3 

0.0 

3.0 

0.0 

5.7 

-

-

-

-

-

Market comparable pricing 

Comparability adjustment 

(56.3)  -

Discounted cash flow 

Discount rate 

Prepayment rate 

Loss severity 

Mortgage servicing rights (residential) 

11,517 

Discounted cash flow 

Cost to service per loan (3) 

$ 

Net derivative assets and (liabilities): 

Interest rate contracts 

146 

Discounted cash flow 

Discount rate 

Prepayment rate (4) 

Default rate 

Loss severity 

Prepayment rate 

Interest rate contracts: derivative loan 

commitments 

68 

Discounted cash flow 

Fall-out factor 

Equity contracts 

Credit contracts 

147 

(416) 

2 

27 

Initial-value servicing 

(32.2)  -

149.0  bps 

Discounted cash flow 

Conversion factor 

Weighted average life 

(8.8)  -

0.5 

-

0.0 

% 

3.0 

yrs 

Option model 

Correlation factor 

(77.0)  -

99.0 

% 

Volatility factor 

6.8 

-

100.0 

Market comparable pricing 

Comparability adjustment 

(56.1)  -

Option model 

Credit spread 

Loss severity 

0.0 

12.0 

-

-

10.8 

17.8 

60.0 

Nonmarketable equity securities 

7,847 

Market comparable pricing 

Comparability adjustment 

(20.2)  -

(4.2) 

Insignificant Level 3 assets, net of liabilities 

27 

Total level 3 assets, net of liabilities 

$ 

22,478  (5) 

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

Securities backed by specified sources of current and future receivables generated from non-U.S. originators. 
Consists of reverse mortgage loans. 
The high end of the range of inputs is for servicing modified loans. For non-modified loans the range is $61 - $231. 
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. 
Consists of total Level 3 assets of $24.3 billion and total Level 3 liabilities of $1.8 billion, before netting of derivative balances. 

14.9 

14 

3.1 

15.5 

5.6 

43.5 

15.4 

(6.3) 

4.3 

100.0 

36.5 

495 

13.6 

24.4 

5.0 

50.0 

25.0 

99.0 

% 

3.9 

6.0 

0.0 

61 

6.0 

9.6 

0.0 

50.0 

2.8 

1.0 

-

-

-

-

-

-

-

-

-

-

1.3 

9.2 

(4.4) 

2.8 

0.7 

4.5 

21.7 

7.8 

(40.3) 

4.1 

85.6 

14.1 

102 

7.2 

11.9 

1.7 

50.0 

15.0 

16.7 

36.4 

(7.7) 

1.5 

23.8 

18.7 

(16.0) 

0.8 

45.6 

(14.6) 

Wells Fargo & Company 

219 

  
 
Note 19:  Fair Values of Assets and Liabilities (continued) 

Table 19.10:  Valuation Techniques – Recurring Basis – December 31, 2018 

($ in millions, except cost to service amounts) 

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 

Corporate debt securities 

Asset-backed securities: 

Diversified payment rights (1) 

Other commercial and consumer 

Mortgage loans held for sale (residential) 

Loans (3) 

Fair Value 
Level 3 

Valuation Technique(s) 

Significant 
Unobservable Input 

Range of Inputs 

Weighted   
Average 

$ 

404 

Discounted cash flow 

Discount rate 

2.1  -

6.4 

% 

3.4 

Vendor priced 

Market comparable pricing 

Comparability adjustment 

(13.5)  -

22.1 

% 

3.2 

Vendor priced 

Discounted cash flow 

Discount rate 

4.0 

Market comparable pricing 

Comparability adjustment 

(11.3) 

11.7 

16.6 

Vendor priced 

171 

198 

(2) 

Discounted cash flow 

Discounted cash flow 

Vendor priced 

Discounted cash flow 

Discount rate 

Discount rate 

Weighted average life 

Default rate 

Discount rate 

Loss severity 

Prepayment rate 

3.4  -

4.6 

1.1 

-

-

0.0  -

1.1  -

0.0 

3.2 

-

-

43 

298 

739 

220 

56 

128 

20 

982 

15 

244 

Market comparable pricing 

Comparability adjustment 

(56.3)  -

Discounted cash flow 

Discount rate 

Mortgage servicing rights (residential) 

14,649 

Discounted cash flow 

Net derivative assets and (liabilities): 

Interest rate contracts 

(35) 

Discounted cash flow 

Prepayment rate 

Loss severity 

Cost to service per 
loan (4) 

Discount rate 

Prepayment rate (5) 

Default rate 

Loss severity 

Prepayment rate 

3.4  -

2.9 

0.0 

-

-

$ 

62  -

7.1  -

9.0  -

0.0  -

50.0  -

2.8  -

Interest rate contracts: derivative loan 

commitments 

Equity contracts 

Credit contracts 

60 

104 

(121) 

3 

32 

Discounted cash flow 

Fall-out factor 

1.0  -

99.0 

Initial-value servicing 

(36.6)  -

91.7  bps 

Discounted cash flow 

Conversion factor 

Weighted average life 

(9.3)  -

1.0 

-

0.0 

% 

3.0 

yrs 

Option model 

Correlation factor 

(77.0)  -

99.0 

% 

Volatility factor 

6.5  -

100.0 

Market comparable pricing 

Comparability adjustment 

(15.5)  -

Option model 

Credit spread 

Loss severity 

0.9  -

13.0  -

40.0 

21.5 

60.0 

6.2 

5.2 

1.5 

yrs 

15.6 

% 

6.6 

43.3 

13.4 

(6.3) 

6.4 

100.0 

34.8 

507 

15.3 

23.5 

5.0 

50.0 

25.0 

% 

8.5 

(1.4) 

4.4 

4.7 

1.1 

0.8 

5.5 

23.4 

4.6 

(36.3) 

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 

Nonmarketable equity securities 

5,468 

Market comparable pricing 

Comparability adjustment 

(20.6)  -

(4.3) 

(15.8) 

Insignificant Level 3 assets, net of liabilities 

93 

Total level 3 assets, net of liabilities 

$ 

23,771  (6) 

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

Securities backed by specified sources of current and future receivables generated from non-U.S. originators. 
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. 
Consists of reverse mortgage loans. 
The high end of the range of inputs is for servicing modified loans. For non-modified loans the range is $62 - $204. 
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. 
Consists of total Level 3 assets of $25.3 billion and total Level 3 liabilities of $1.6 billion, before netting of derivative balances. 

220 

Wells Fargo & Company 

  
  
 
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. 

Wells Fargo & Company 

221 

 
Note 19:  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, MLHFS, loans, other 
nonmarketable equity investments, and AFS 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 MSRs. 
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 MSRs and alternatively, a decrease in any one of 
these inputs would result in the MSRs 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 10 (Securitizations 
and Variable Interest Entities). 

222 

Wells Fargo & Company 

 
 
 
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 use of the measurement alternative for nonmarketable 
equity securities. 

Table 19.11 provides the fair value hierarchy and fair value at 

the date of the nonrecurring fair value adjustment for all assets 

Table 19.11:  Fair Value on a Nonrecurring Basis 

that were still held as of December 31, 2019 and 2018, and for 
which a nonrecurring fair value adjustment was recorded during 
the years then ended. 

Table 19.12 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. 

December 31, 2019 

December 31, 2018 

Level 1 

Level 2 

Level 3 

1,213 

313 

339 

346 

685 

774 

149 

1,233 

— 

— 

1 

1 

157 

6 

Total 

2,446 

313 

339 

347 

686 

931 

155 

3,134 

1,397 

4,531 

— 

— 

— 

— 

— 

— 

— 

— 

(in millions) 

Level 1 

Level 2 

Level 3 

Mortgage loans held for sale (1) 

$ 

Loans held for sale 

Loans: 

Commercial 

Consumer 

Total loans 

Nonmarketable equity securities 

Other assets 

Total assets at fair value on a nonrecurring basis 

$ 

— 

— 

— 

— 

— 

— 

— 

— 

2,034 

3,803 

5 

280 

213 

493 

1,308 

359 

4,199 

— 

— 

1 

1 

173 

27 

4,004 

Total 

5,837 

5 

280 

214 

494 

1,481 

386 

8,203 

(1) 

Consists of commercial mortgages and residential real estate 1-4 family first mortgage loans. 

Premises and equipment includes the full impairment of 

certain capitalized software projects. Other assets includes 
impairments of operating lease ROU assets, as well as valuation 
losses on foreclosed real estate and other collateral owned. 

Table 19.12:  Change in Value of Assets with Nonrecurring Fair Value 
Adjustment 

Year ended December 31, 

(in millions) 

Mortgage loans held for sale 

$ 

Loans held for sale 

Loans: 

Commercial 

Consumer 

Total loans 

Nonmarketable equity securities 

Premises and equipment 

Other assets 

Total 

$ 

2019 

11 

— 

(291) 

(207) 

(498) 

322 

(170) 

(84) 

(419) 

2018 

21 

(39) 

(221) 

(284) 

(505) 

265 

— 

(40) 

(298) 

Wells Fargo & Company 

223 

  
 
  
 
 
Note 19:  Fair Values of Assets and Liabilities (continued) 

Table 19.13 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 19.13:  Valuation Techniques – Nonrecurring Basis 

assets 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. 

($ in millions) 

December 31, 2019 

Fair Value 
Level 3 

Valuation Technique(s) (1) 

Significant 
Unobservable 
Inputs (1) 

Range of inputs 

Weighted 
Average (2) 

Residential mortgage loans held for sale 

$ 

3,803  (3) 

Discounted cash flow 

Default rate  (4) 

Discount rate 

0.3  – 

1.5  – 

48.3% 

9.4 

Loss severity 

0.4  – 

100.0 

Prepayment rate  (5) 

4.8  – 

100.0 

4.6% 

4.3 

23.4 

23.2 

Insignificant Level 3 assets 

Total 

December 31, 2018 

Residential mortgage loans held for sale 

$ 

$ 

201 

4,004 

1,233  (3) 

Discounted cash flow 

Default rate  (4) 

Discount rate 

Loss severity 

Prepayment rate  (5) 

0.2  – 

1.5  – 

0.5  – 

3.5  – 

2.3% 

1.4% 

8.5 

66.0 

100.0 

4.0 

1.7 

46.5 

Insignificant Level 3 assets 

Total 

164 

$ 

1,397 

(1) 
(2) 
(3) 

(4) 
(5) 

Refer to the narrative following Table 19.10 for a definition of the valuation technique(s) and significant unobservable inputs. 
For residential MLHFS, weighted averages are calculated using the outstanding unpaid principal balance of the loans. 
Consists of approximately $1.3 billion and $1.2 billion of government insured/guaranteed loans purchased from GNMA-guaranteed mortgage securitizations at December 31, 2019 and 2018, 
respectively, and $2.5 billion and $27 million, respectively, of other mortgage loans that are not government insured/guaranteed. 
Applies only to non-government insured/guaranteed loans. 
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)  MLHFS measured at 
fair value include residential mortgage loan originations for 
which an active secondary market and readily available market 
prices exist to reliably support our valuations. Loan origination 
fees on these loans are recorded when earned, and related direct 
loan origination costs are recognized when incurred. We believe 
fair value measurement for MLHFS, which we economically 
hedge with 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 purchase 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. Fair value measurement 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 measured at fair value consist 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, continue to be subject to the fair value 
option. 

224 

Wells Fargo & Company 

  
 
 
Table 19.14 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 19.14:  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 

December 31, 2019 

December 31, 2018 

Fair value 
carrying 
amount 

Aggregate 
unpaid 
principal 

$ 

16,606 

16,279 

133 

8 

972 

21 

171 

129 

157 

10 

1,020 

29 

201 

159 

Fair value 
carrying 
amount less 
aggregate 
unpaid 
principal 

Fair value 
carrying 
amount 

Aggregate 
unpaid 
principal 

Fair value 
carrying 
amount less 
aggregate 
unpaid principal 

327 

(24) 

(2) 

(48) 

(8) 

(30) 

(30) 

11,771 

11,573 

127 

7 

1,469 

21 

244 

179 

158 

9 

1,536 

32 

274 

208 

198 

(31) 

(2) 

(67) 

(11) 

(30) 

(29) 

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 19.15 by income 

statement line item. Amounts recorded as interest income are 
excluded from Table 19.15. 

Table 19.15:  Fair Value Option – Changes in Fair Value Included in Earnings 

(in millions) 

Mortgage
banking
noninterest 
income 

Net gains
(losses) from
trading
activities 

Mortgage loans held for sale 

$ 

1,064 

Loans held for sale 

Loans 

— 

— 

— 

11 

— 

2019 

Other 
noninterest 
income 

— 

2 

— 

Mortgage 
banking 
noninterest 
income 

Net gains 
(losses) from 
trading 
activities 

2018 

Other 
noninterest 
income 

Mortgage 
banking 
noninterest 
income 

Net gains 
(losses) from 
trading 
activities 

462 

— 

— 

— 

(1) 

— 

— 

1 

(1) 

1,229 

— 

— 

— 

45 

— 

2017 

Other 
noninterest 
income 

— 

2 

— 

Year ended December 31, 

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 19.16 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 19.16:  Fair Value Option – Gains/Losses Attributable to 
Instrument-Specific Credit Risk 

(in millions) 

Gains (losses) attributable to 

instrument-specific credit risk: 

Mortgage loans held for sale 

Loans held for sale 

Total 

Year ended December 31, 

2019 

2018 

2017 

$ 

$ 

2 

13 

15 

(16) 

— 

(16) 

(12) 

45 

33 

Wells Fargo & Company 

225 

 
  
 
  
  
 
Note 19:  Fair Values of Assets and Liabilities (continued) 

Disclosures about Fair Value of Financial Instruments 
Table 19.17 presents a summary of fair value estimates for 
financial instruments that are not carried at fair value on a 
recurring basis. Some financial instruments are excluded from 
the scope of this table, such as certain insurance contracts and 
leases. This table also excludes assets and liabilities that are not 
financial instruments such as the value of the long-term 
relationships with our deposit, credit card and trust customers, 
MSRs, premises and equipment, goodwill and deferred taxes. 

Loan commitments, standby letters of credit and 
commercial and similar letters of credit are not included in    
Table 19.17. 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, 2019 and 2018.

 The total of the fair value calculations presented does not 

represent, and should not be construed to represent, the 
underlying fair value of the Company. 

Table 19.17:  Fair Value Estimates for Financial Instruments 

(in millions) 

December 31, 2019 

Financial assets 

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) 

Nonmarketable equity securities (cost method) 

$ 

21,757 

119,493 

102,140 

153,933 

6,736 

5 

933,042 

4,790 

21,757 

119,257 

— 

46,138 

— 

— 

— 

— 

— 

236 

102,140 

109,933 

2,939 

5 

— 

— 

— 

789 

4,721 

— 

21,757 

119,493 

102,140 

156,860 

7,660 

5 

54,125 

891,714 

945,839 

— 

4,823 

4,823 

Total financial assets 

$ 

1,341,896 

187,152 

269,378 

902,047 

1,358,577 

Financial liabilities 

Deposits (3) 

Short-term borrowings 

Long-term debt (4) 

Total financial liabilities 

December 31, 2018 

Financial assets 

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) 

Nonmarketable equity securities (cost method) 

$ 

118,849 

104,512 

228,159 

$ 

451,520 

$ 

23,551 

149,736 

80,207 

144,788 

3,355 

572 

923,703 

5,643 

— 

— 

— 

— 

87,279 

104,513 

231,332 

423,124 

— 

194 

80,207 

97,275 

2,129 

572 

23,551 

149,542 

— 

44,339 

— 

— 

— 

— 

31,858 

— 

1,720 

33,578 

— 

— 

— 

501 

1,233 

— 

119,137 

104,513 

233,052 

456,702 

23,551 

149,736 

80,207 

142,115 

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) 

Short-term borrowings 

Long-term debt (4) 

Total financial liabilities 

$ 

130,645 

105,787 

229,008 

$ 

465,440 

— 

— 

— 

— 

107,448 

105,789 

225,904 

439,141 

22,641 

— 

2,230 

24,871 

130,089 

105,789 

228,134 

464,012 

(1) 
(2) 
(3) 
(4) 

Amounts consist of financial instruments for which carrying value approximates fair value. 
Excludes lease financing with a carrying amount of $19.5 billion and $19.7 billion at December 31, 2019 and 2018, respectively. 
Excludes deposit liabilities with no defined or contractual maturity of $1.2 trillion at both December 31, 2019 and 2018. 
Excludes capital lease obligations under capital leases of $32 million and $36 million at December 31, 2019 and 2018, respectively. 

226 

Wells Fargo & Company 

  
 
 
Note 20:  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. 

In January 2020, we issued $2.0 billion of our Preferred 
Stock, Series Z. On February 12, 2020, the Company announced 
a redemption of the remaining outstanding shares of our 
Preferred Stock, Series K, and a partial redemption of 26,720 
outstanding shares of our Preferred Stock, Series T. The 
redemptions will occur on March 16, 2020. 

Table 20.1:  Preferred Stock Shares 

DEP Shares 

Dividend Equalization Preferred Shares (DEP) 

Series I 

Floating Class A Preferred Stock (1) 

Series K 

December 31, 2019 

December 31, 2018 

Liquidation 
preference 
per share 

Shares 
authorized 
and designated 

Liquidation 
 preference 
 per share 

Shares 
authorized 
and designated 

$ 

10 

97,000 

$ 

10 

97,000 

100,000 

25,010 

100,000 

25,010 

Floating Non-Cumulative Perpetual Class A Preferred Stock (2)(3) 

1,000 

3,500,000 

1,000 

3,500,000 

Series L 

7.50% Non-Cumulative Perpetual Convertible Class A Preferred Stock (4) 

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 (5) 

Total 

— 

1,071,418 

9,251,728 

— 

1,406,460 

9,586,770 

(1) 

(2) 
(3) 
(4) 

(5) 

Series I preferred stock issuance relates to trust preferred securities. See Note 10 (Securitizations and Variable Interest Entities) for additional information. This issuance has a floating interest rate 
that is the greater of three-month LIBOR plus 0.93% and 5.56975%. 
Floating rate for Preferred Stock, Series K, is three-month LIBOR plus 3.77%. 
In third quarter 2019, 1,550,000 shares of Preferred Stock, Series K, were redeemed. 
Preferred Stock, Series L, may be converted at any time, at the option of the holder, into 6.3814 shares of our common stock, plus cash in lieu of fractional shares, subject to anti-dilution 
adjustments. 
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. 

Wells Fargo & Company 

227 

  
 
 
Note 20:  Preferred Stock (continued) 

Table 20.2:  Preferred Stock – Shares Issued and Carrying Value 

(in millions, except shares) 

DEP Shares 

December 31, 2019 

December 31, 2018 

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 

Series K (1)(3)(4) 

25,010 

2,501 

2,501 

— 

— 

96,546

$ 

— 

— 

25,010 

2,501 

2,501 

— 

— 

Floating Non-Cumulative Perpetual Class A Preferred Stock 

1,802,000 

1,802 

1,546 

256 

3,352,000 

3,352 

2,876 

476 

Series L (1)(5) 

7.50% Non-Cumulative Perpetual Convertible Class A Preferred Stock 

3,967,995 

3,968 

3,200 

768 

3,968,000 

3,968 

3,200 

768 

Series N (1) 

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 

69,000 

1,725 

1,725 

Series R (1) 

6.625% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock 

33,600 

840 

840 

Series S (1) 

5.90% Fixed-to-Floating Non-Cumulative Perpetual Class A Preferred Stock 

80,000 

2,000 

2,000 

Series T (1) 

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 

80,000 

2,000 

2,000 

Series V (1) 

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 

1,071,418 

1,072 

1,072 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

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 

1,406,460 

1,407 

1,407 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

Total 

7,492,169 

$ 

22,573 

21,549 

1,024 

9,377,216 

$ 

24,458 

23,214 

1,244 

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

Preferred shares qualify as Tier 1 capital. 
Floating rate for Preferred Stock, Series I, is the greater of three-month LIBOR plus 0.93% and 5.56975%. 
Floating rate for Preferred Stock, Series K, is three-month LIBOR plus 3.77%. 
In third quarter 2019, 1,550,000 shares of Preferred Stock, Series K, were redeemed. 
Preferred Stock, Series L, may be converted at any time, at the option of the holder, into 6.3814 shares of our common stock, plus cash in lieu of fractional shares, subject to anti-dilution 
adjustments. 

228 

Wells Fargo & Company 

  
 
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 
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. 

Table 20.3:  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 (1) 

Total ESOP Preferred Stock (2) 

Unearned ESOP shares (3) 

Shares issued and outstanding 

Carrying value 

Adjustable dividend rate 

Dec 31, 

2019 

Dec 31, 

2018 

Dec 31, 

2019 

Dec 31, 

2018 

Minimum 

Maximum 

254,945 

192,210 

197,450 

116,784 

136,151 

97,948 

49,134 

26,796 

— 

336,945  $ 

222,210 

233,835 

144,338 

174,151 

133,948 

77,634 

61,796 

21,603 

255 

192 

198 

117 

136 

98 

49 

27 

— 

1,071,418 

1,406,460  $ 

1,072 

$ 

(1,143) 

337 

222 

234 

144 

174 

134 

78 

62 

22 

1,407 

(1,502) 

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 

In April 2019, all of the 2010 ESOP Preferred Stock was converted into common stock. 
At December 31, 2019 and 2018, additional paid-in capital included $71 million and $95 million, respectively, related to ESOP preferred stock.  

(1) 
(2) 
(3)  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. 

Wells Fargo & Company 

229 

  
 
 
Note 21:  Common Stock and Stock Plans 

Common Stock 
Table 21.1 presents our reserved, issued and authorized shares of 
common stock at December 31, 2019. 

Table 21.1:  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 

6,774,855 

375,293 

488,214,122 

65,835,437 

561,199,707 

5,481,811,474 

2,956,988,819 

9,000,000,000 

(1) 

Includes employee restricted share rights, performance share awards, 401(k), and deferred 
compensation 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 no 
warrants and 23,217,208 warrants to purchase shares of our 
common stock in 2019 and 2018, 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  Since 2010, we 
have granted restricted share rights (RSRs) and performance 
share awards (PSAs) as our primary long-term incentive awards 
using our Long-Term Incentive Compensation Plan (LTICP). 

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. 

Table 21.2 summarizes the major components of stock 
incentive compensation expense and the related recognized tax 
benefit. 

Table 21.2:  Stock Incentive Compensation Expense 

(in millions) 

RSRs (1) 

Performance shares 

Stock options 

Total stock incentive 

compensation expense 

Related recognized tax benefit 

Year ended December 31, 

2019 

$ 

1,109 

108 

— 

$ 

$ 

1,217 

301 

2018 

1,013 

9 

— 

1,022 

252 

2017 

743 

112 

(6) 

849 

320 

(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. 

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, 2019, was 246 million. 

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 
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 are granted. A summary of the status of our RSRs at 
December 31, 2019, and changes during 2019 is presented in 
Table 21.3. 

Table 21.3:  Restricted Share Rights 

Weighted- 
 average 
 grant-date 
fair value 

Number 

Nonvested at January 1, 2019 

45,572,498  $ 

Granted 

Vested 

Canceled or forfeited 

Nonvested at December 31, 2019 

22,743,879 

(15,281,949) 

(2,118,967) 

50,915,461 

54.85 

49.32 

55.03 

55.37 

52.30 

The weighted-average grant date fair value of RSRs granted 

during 2018 and 2017 was $58.47 and $57.54, respectively. 

At December 31, 2019, there was $1.0 billion of total 

unrecognized compensation cost related to nonvested RSRs. The 
cost is expected to be recognized over a weighted-average 
period of 2.4 years. The total fair value of RSRs that vested 
during 2019, 2018 and 2017 was $773 million, $824 million and 
$865 million, respectively. 

230 

Wells Fargo & Company 

  
 
 
  
 
 
 
  
 
 
The weighted-average grant date fair value of performance 
awards granted during 2018 and 2017 was $58.62 and $57.14, 
respectively. 

At December 31, 2019, there was $29 million of total 

unrecognized compensation cost related to nonvested 
performance awards. The cost is expected to be recognized over 
a weighted-average period of 1.6 years. The total fair value of 
PSAs that vested during 2019, 2018 and 2017 was $82 million, 
$107 million and $117 million, respectively. 

Stock Options 
Table 21.5 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. 

Number 

Weighted- 
 average 
 exercise price 

Weighted- 
 average 
 remaining 
contractual term 
(in yrs.) 

Aggregate 
intrinsic 
value 
 (in millions) 

8,343,157  $ 

(170,141) 

(8,112,456) 

60,560 

13.46 

13.05 

13.34 

30.69 

0.3 

$ 

1 

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, 2019, the determination of the number of 
performance shares that will vest will occur in first quarter of 
2020 after review of the Company’s performance by the Human 
Resources Committee of the Board. 

A summary of the status of our PSAs at December 31, 2019, 

and changes during 2019 is in Table 21.4, based on the 
performance adjustments recognized as of December 2019. 

Table 21.4:  Performance Share Awards 

Number 

Weighted- average 
 grant-date fair value (1) 

Nonvested at January 1, 2019 

5,984,686  $ 

Granted 

Vested 

Canceled or forfeited 

2,320,530 

(1,610,502) 

(190,501) 

Nonvested at December 31, 2019 

6,504,213 

49.91 

49.26 

48.59 

56.48 

49.81 

(1) 

Reflects approval date fair value for grants subject to variable accounting. 

Table 21.5:  Stock Option Activity 

Incentive compensation plans 

Options outstanding as of December 31, 2018 

Canceled or forfeited 

Exercised 

Options exercisable and outstanding as of December 31, 2019 

The total intrinsic value to option holders, which is the stock 

market value in excess of the option exercise price, of options 
exercised during 2019, 2018 and 2017 was $291 million, 
$375 million and $623 million, respectively. 

Cash received from the exercise of stock options for 2019, 

2018 and 2017 was $108 million, $227 million and $602 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. 

Wells Fargo & Company 

231 

  
 
  
 
 
Note 21:  Common Stock and Stock Plans (continued) 

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 2019, 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 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. 

Table 21.6 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 21.6:  Common Stock and Unreleased Preferred Stock in the Wells Fargo ESOP Fund 

(in millions, except shares) 

Allocated shares (common) 

Unreleased shares (preferred) 

Shares outstanding 

December 31, 

2019 

2018 

2017 

138,978,383 

1,071,418 

138,182,911 

124,670,717 

1,406,460 

1,556,104 

Fair value of unreleased ESOP preferred shares 

$ 

1,072 

1,407 

1,556 

Allocated shares (common) 

Unreleased shares (preferred) 

$ 

2019 

233 

101 

Dividends paid 

Year ended December 31, 

2018 

213 

159 

2017 

195 

166 

232 

Wells Fargo & Company 

  
 
 
Note 22:  Revenue from Contracts with Customers 

Our revenue includes net interest income on financial 
instruments and noninterest income. Table 22.1 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, substantially all 
of which represents products and services for WIM customers 
served through Community Banking distribution channels. For 
additional description of our operating segments, including 

Table 22.1:  Revenue by Operating Segment 

additional financial information and the underlying management 
accounting process, see Note 27 (Operating Segments). 

We adopted ASU 2014-09 – Revenue from Contracts with 

Customers on a modified retrospective basis as of January 1, 
2018. For details on the impact of the adoption of this ASU, see 
Note 1 (Summary of Significant Accounting Policies) in our 2018 
Form 10-K. 

(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 (losses) from trading activities (1) 

Net gains (losses) on debt securities (1) 

Net gains (losses) from equity securities (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 (losses) from trading activities (1) 

Net gains (losses) on debt securities (1) 

Net gains (losses) from equity securities (1) 

Lease income (1) 

Other income of the segment (1) 

Total noninterest income 

Revenue 

(continued on following page) 

Community 
Banking 

$ 

27,610 

Wholesale 
Banking 

17,699 

2,823 

1,931 

805 

(93) 

2,643 

3,655 

239 

452 

— 

274 

313 

1,278 

2,307 

44 

24 

51 

2,155 

— 

2,726 

17,706 

45,316 

1,974 

292 

486 

1,889 

2,667 

359 

1,139 

— 

358 

196 

108 

1,801 

412 

303 

915 

89 

416 

1,612 

(570) 

9,978 

27,677 

Wealth and 
Investment 
Management 

4,037 

16 

8,946 

2,587 

6 

11,539 

6 

8 

— 

— 

8 

1 

17 

(12) 

72 

53 

— 

272 

— 

Year ended December 31, 2019 

Other 

(2,115) 

Consolidated 
Company 

47,231 

(15) 

4,798 

(1,932) 

(840) 

(5) 

(2,777) 

(4) 

(7) 

— 

— 

(4) 

(1) 

(12) 

8 

(41) 

1 

— 

— 

— 

9,237 

3,038 

1,797 

14,072 

4,016 

1,379 

452 

358 

474 

421 

3,084 

2,715 

378 

993 

140 

2,843 

1,612 

3,181 

37,832 

85,063 

1,341 

13,304 

17,341 

(316) 

(3,156) 

(5,271) 

29,219 

18,690 

4,441 

(2,355) 

49,995 

Year ended December 31, 2018 

2,641 

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 

2,074 

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 

16 

(15) 

4,716 

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 

$ 

$ 

$ 

Wells Fargo & Company 

233 

 
Note 22:  Revenue from Contracts with Customers (continued) 

(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 (losses) from trading activities (1) 

Net gains (losses) on debt securities (1) 

Net gains (losses) from equity securities (1) 

Lease income (1) 

Other income of the segment (1) 

Total noninterest income 

Revenue 

Community 
Banking 

$ 

28,658 

Wholesale 
Banking 

18,810 

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 

$ 

Wealth and 
Investment 
Management 

4,641 

17 

9,072 
2,877 

(2) 
11,947 

6 

8 
— 

— 
9 

1 
18 

(10) 

88 

92 

2 

208 

— 

63 

12,431 

17,072 

Year ended December 31, 2017 

Other 

(2,552) 

Consolidated 
Company 

49,557 

(16) 

5,111 

(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 

(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 notes 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. 
Represents combined amount of previously reported “Charges and fees on loans” and “Letters of credit fees.” 

(2) 

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. 

and include fees for account and overdraft services. Account 
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 22.2 presents our service charges on deposit accounts 

SERVICE CHARGES ON DEPOSIT ACCOUNTS are earned on 
depository accounts for commercial and consumer customers 

by operating segment. 

Table 22.2:  Service Charges on Deposit Accounts by Operating Segment 

Community 
Banking 

Wholesale 
Banking 

Wealth and 
Investment 
Management 

Year ended December 31, 

Other 

Consolidated 
Company 

(in millions) 

Overdraft fees 

Account charges 

Service charges on deposit accounts 

2019 

2018 

2017 

2019 

2018 

2017 

2019 

2018 

2017 

2019 

2018 

2017 

2019 

2018 

2017 

$ 1,965 

1,776 

1,941 

858 

865 

968 

$ 2,823 

2,641 

2,909 

5 

1,969 

1,974 

5 

2,069 

2,074 

6 

2,195 

2,201 

1 

15 

16 

1 

15 

16 

1 

16 

17 

— 

(15) 

(15) 

— 

(15) 

(15) 

— 
1,971 
(16)  2,827 
(16)  4,798 

1,782 

2,934 

4,716 

1,948 

3,163 

5,111 

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. 

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. 

Other revenues earned from other brokerage advisory 

services include omnibus and networking fees received from 
mutual fund companies in return for providing record keeping 
and other administrative services, and annual account 
maintenance fees charged to customers. 

234 

Wells Fargo & Company 

 
Table 22.3 presents our brokerage advisory, commissions 

and other fees by operating segment. 

Table 22.3:  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) 

Asset-based revenue (1) 

Transactional revenue 
Other revenue 

Brokerage advisory, commissions and 

other fees 

2019 

2018 

2017 

2019 

2018 

2017 

$  1,478 

1,482 

1,372 

383 
70 

340 
65 

382 
76 

$  1,931 

1,887 

1,830 

— 

26 
266 

292 

1 

70 
246 

317 

1 

40 
263 

304 

2019 

6,777 

1,534 
635 

2018 

2017 

2019 

2018 

2017 

2019 

2018 

2017 

6,899 

1,618 
644 

6,630 

(1,480) 

(1,484) 

(1,371) 

6,775 

6,898 

6,632 

1,802 
640 

(383) 
(69) 

(380) 
(65) 

(400) 
(77) 

1,560 
902 

1,648 
890 

1,824 
902 

8,946 

9,161 

9,072 

(1,932) 

(1,929) 

(1,848) 

9,237 

9,436 

9,358 

(1)  We earned trailing commissions of $1.2 billion for the year ended December 31, 2019 and $1.3 billion for both of the years ended December 31, 2018 and 2017, respectively. 

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 22.4 presents our trust and investment management 

fees by operating segment. 

Table 22.4:  Trust and Investment Management Fees by Operating Segment 

(in millions) 

Investment management fees 

Trust fees 

Other revenue 

Trust and investment management fees 

$  805 

Community 
Banking 

Wholesale 
Banking 

Wealth and 
Investment 
Management 

Year ended December 31, 

Other 

Consolidated 
Company 

2019 

2018 

2017 

2019 

2018 

2017 

2019 

2018 

2017 

2019 

2018 

2017 

2019 

2018 

2017 

$  — 

804 

1 

— 

908 

2 

910 

1 

887 

1 

889 

— 

338 

148 

486 

— 

329 

116 

445 

— 

1,990 

2,087 

2,053 

— 

— 

— 

1,990 

2,087 

2,054 

421 

102 

523 

557 

40 

728 

78 

757 

67 

(840) 

(932) 

(916) 

— 

— 

(1) 

859 

189 

1,033 

1,149 

196 

169 

2,587 

2,893 

2,877 

(840) 

(932) 

(917) 

3,038 

3,316 

3,372 

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 FEES include credit and debit card interchange and network 
revenues and various card-related fees. Credit and debit card 

Table 22.5:  Card Fees by Operating Segment 

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 22.5 presents our card fees by operating segment. 

Community 
Banking 

Wholesale 
Banking 

Wealth and 
Investment 
Management 

Year ended December 31, 

Other 

Consolidated 
Company 

(in millions) 

2019 

2018 

2017 

Credit card interchange and network revenues (1) 

$  809 

792 

944 

Debit card interchange and network revenues 

2,148 

2,053 

1,964 

Late fees, cash advance fees, balance transfer fees, 

and annual fees 

Card fees 

698 

698 

705 

2019 

359 

— 

— 

361 

345 

—

1

— 

— 

$  3,655 

3,543 

3,613 

359 

362 

345 

6 

— 

— 

6 

6

—

—

6

6 

— 

— 

6 

(4) 

— 

— 

(4) 

(4) 

—

—

(4) 

(4) 

1,170 

1,155 

1,291 

— 

— 

2,148 

2,053 

1,964 

698 

699 

705

(4) 

4,016 

3,907 

3,960 

2018 

2017 

2019 

2018 

2017 

2019 

2018 

2017 

2019 

2018 

2017 

(1) 

The cost of credit card rewards and rebates of $1.5 billion, $1.4 billion and $1.2 billion for the years ended December 31, 2019, 2018 and 2017, respectively, are presented net against the related 
revenues. 

Wells Fargo & Company 

235 

 
Note 22:  Revenue from Contracts with Customers (continued) 

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. In October 2019, we sold our commercial real estate 
brokerage business (Eastdil). 

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 for products or 
services such as merchant payment services, safe deposit boxes, 
and loan syndication agency services. These fees are generally 
recognized over time as we perform the services. Most of these 
fees are in the Community Banking operating segment. 

Note 23:  Employee Benefits and Other Expenses 

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.

 Although not required, we made a $192 million contribution 

to our Cash Balance Plan in 2019. We do not expect that we will 
be required to make a contribution to the Cash Balance Plan in 
2020; however, this is dependent on the finalization of the 
actuarial valuation in 2020. Our decision of whether to make a 
contribution in 2020 will be based on various factors including 
the actual investment performance of plan assets during 2020. 
Given these uncertainties, we cannot estimate at this time the 
amount, if any, that we will contribute in 2020 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 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). Lump sum payments (included in the 
“Benefits paid” line in Table 23.1) did not exceed this threshold in 
2019. 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. 
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 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. 

236 

Wells Fargo & Company 

 
Table 23.1 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. The increases in the 
benefit obligation of the qualified plans and nonqualified plans 
were primarily due to actuarial losses, reflecting a decrease in the 
discount rates, partially offset by benefits paid. The decrease in 

Table 23.1:  Changes in Benefit Obligation and Fair Value of Plan Assets 

the benefit obligation for the other benefit plans was primarily 
due to benefits paid (net of participant contributions) and net 
actuarial gains, partially offset by interest cost. Net actuarial 
gains were primarily due to actual benefit claims being less than 
projected, partially offset by a decrease in the discount rate. 

(in millions) 

Change in benefit obligation: 

Benefit obligation at beginning of year 

Service cost 

Interest cost 

Plan participants’ contributions 

Actuarial loss (gain) 

Benefits paid 

Medicare Part D subsidy 

Settlements, Curtailments, and Amendments 

Other 

Foreign exchange impact 

December 31, 2019 

December 31, 2018 

Pension benefits 

Pension benefits 

Qualified 

Non-
qualified 

Other 
benefits 

Qualified 

Non-
qualified 

Other 
benefits 

$ 

10,129 

11 

419 

— 

1,229 

(672) 

— 

(2) 

— 

2 

557 

— 

22 

— 

49 

(57) 

— 

— 

— 

1 

555 

— 

23 

44 

(11) 

(86) 

— 

— 

— 

— 

11,110 

11 

392 

— 

(674) 

(719) 

— 

1 

13 

(5) 

621 

— 

21 

— 

(27) 

(57) 

— 

— 

— 

(1) 

611 

— 

21 

48 

(33) 

(92) 

2 

— 

— 

(2) 

Benefit obligation at end of year 

11,116 

572 

525 

10,129 

557 

555 

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 

Fair value of plan assets at end of year 

Funded status at end of year 

Amounts recognized on the balance sheet at end of year: 

Assets 

Liabilities 

9,477 

1,758 

199 

— 

(672) 

— 

(1) 

— 

2 

10,763 

(353) 

1 

(354) 

$ 

$ 

— 

— 

57 

— 

(57) 

— 

— 

— 

— 

— 

(572) 

— 

(572) 

511 

64 

7 

44 

(86) 

— 

— 

— 

— 

540 

15 

44 

(29) 

10,667 

(478) 

10 

— 

(719) 

— 

— 

1 

(4) 

9,477 

(652) 

1 

(653) 

— 

— 

57 

— 

(57) 

— 

— 

— 

— 

— 

(557) 

— 

(557) 

565 

(17) 

5 

48 

(92) 

2 

— 

— 

— 

511 

(44) 

— 

(44) 

Table 23.2 provides information for pension and post 

retirement plans with benefit obligations in excess of plan assets. 

Table 23.2:  Plans with Benefit Obligations in Excess of Plan Assets 

(in millions) 

Projected benefit obligation 

Accumulated benefit obligation 

Fair value of plan assets 

December 31, 2019 

December 31, 2018 

Pension Benefits 

Other Benefits 

Pension Benefits 

Other Benefits 

$ 

11,653 

11,634 

10,727 

N/A 

29 

— 

10,640 

10,627 

9,429 

N/A 

555 

511 

Wells Fargo & Company 

237 

  
 
  
 
Note 23:  Employee Benefits and Other Expenses (continued) 

Table 23.3 presents the components of net periodic benefit 

cost and other comprehensive income (OCI). 

Table 23.3:  Net Periodic Benefit Cost and Other Comprehensive Income 

December 31, 2019 

December 31, 2018 

December 31, 2017 

Pension benefits 

Pension benefits 

Pension benefits 

Qualified 

Non-
qualified 

Other 
benefits 

Qualified 

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 

Amortization of prior service credit 

Settlement 

$ 

11 

419 

(567) 

148 

— 

— 

11 

38 

(148) 

— 

— 

— 

Total recognized in other comprehensive income 

(110) 

Total recognized in net periodic benefit cost and 

other comprehensive income 

$ 

(99) 

— 

22 

— 

10 

— 

2 

34 

49 

(10) 

— 

— 

(2) 

37 

71 

— 

23 

(28) 

(17) 

(10) 

— 

(32) 

(47) 

17 

— 

10 

— 

(20) 

(52) 

11 

392 

(641) 

131 

— 

134 

27 

445 

(131) 

1 

— 

(134) 

181 

208 

— 

21 

— 

14 

— 

2 

37 

(27) 

(14) 

— 

— 

(2) 

(43) 

(6) 

— 

21 

(31) 

(18) 

(10) 

— 

(38) 

15 

18 

— 

10 

— 

43 

5 

5 

412 

(652) 

148 

— 

7 

(80) 

33 

(148) 

1 

— 

(8) 

(122) 

(202) 

— 

24 

— 

11 

— 

6 

41 

46 

(11) 

— 

— 

(6) 

29 

70 

— 

28 

(30) 

(9) 

(10) 

— 

(21) 

(128) 

9 

— 

10 

— 

(109) 

(130) 

(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, 2019 and 2018 balances are 
reported in other noninterest expense on the consolidated statement of income. For 2017, these balances were reported in employee benefits. 

Table 23.4 provides the amounts recognized in cumulative 

OCI (pre-tax). 

Table 23.4:  Benefits Recognized in Cumulative OCI 

(in millions) 

Net actuarial loss (gain) 

Net prior service cost (credit) 

Total 

December 31, 2019 

December 31, 2018 

Pension benefits 

Pension benefits 

Qualified 

3,226 

1 

3,227 

$ 

$ 

Non-
qualified 

Other 
benefits 

186 

— 

186 

(357) 

(146) 

(503) 

Qualified 

3,336 

1 

3,337 

Non-
qualified 

Other 
benefits 

149 

— 

149 

(327) 

(156) 

(483) 

238 

Wells Fargo & Company 

  
  
 
 
Plan Assumptions 
For additional information on our pension accounting 
assumptions, see Note 1 (Summary of Significant Accounting 
Policies). Table 23.5 presents the weighted-average assumptions 
used to estimate the projected benefit obligation. 

Table 23.5:  Weighted-Average Assumptions Used to Estimate Projected Benefit Obligation 

Discount rate 

Interest crediting rate 

December 31, 2019 

December 31, 2018 

Pension benefits 

Pension benefits 

Qualified 

3.21% 

2.70 

Non-
qualified 

Other 
benefits 

3.03 

1.35 

3.10 

N/A 

Qualified 

4.30 

3.22 

Non-
qualified 

Other 
benefits 

4.20 

2.18 

4.24 

N/A 

Table 23.6 presents the weighted-average assumptions 

used to determine the net periodic benefit cost. 

Table 23.6:  Weighted-Average Assumptions Used to Determine Net Periodic Benefit Cost 

December 31, 2019 

December 31, 2018 

December 31, 2017 

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 

4.30% 

3.22 

6.24 

4.10 

2.05 

N/A 

4.24 

N/A 

5.75 

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 

(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 8.30% for health care costs in 2020. This rate is 
assumed to trend down 0.40%-0.50% per year until the trend 
rate reaches an ultimate rate of 4.50% in 2028. The 2019 
periodic benefit cost was determined using an initial annual trend 
rate of 8.40%. This rate was assumed to decrease 0.50%-0.60% 
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 a moderate 
amount of long-term growth opportunities while ensuring that 
risk is mitigated through diversification across numerous asset 
classes and various investment strategies, coupled with an 
investment strategy for the fixed income assets that is generally 
designed to approximate the interest rate sensitivity of the Cash 
Balance Plan’s benefit obligations. As of the end of 2019, the 
asset allocation for our Cash Balance Plan had a mix range of 
20%-40% equities, 50%-70% fixed income, and approximately 
10% in real estate, 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 predominately invested in fixed income 
securities and cash. 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 23.7. 

Table 23.7:  Projected Benefit Payments 

(in millions) 

Year ended December 31, 

2020 

2021 

2022 

2023 

2024 

Pension benefits 

Qualified 

Non-
qualified 

Other 
Benefits 

$ 

826 

811 

797 

738 

720 

50 

48 

45 

44 

42 

42 

42 

41 

40 

38 

2025-2029 

3,391 

187 

167 

Wells Fargo & Company 

239 

  
 
  
 
  
 
 
Note 23:  Employee Benefits and Other Expenses (continued) 

Fair Value of Plan Assets 
Table 23.8 presents the classification of the fair value of the 
pension plan and other benefit plan assets in the fair value 
hierarchy. See Note 19 (Fair Values of Assets and Liabilities) for a 
description of the fair value hierarchy. 

Table 23.8:  Pension and Other Benefit Plan Assets 

Pension plan assets 

Carrying value at year end 

Other benefits plan assets 

Level 1 

Level 2 

Level 3 

Total 

Level 1 

Level 2 

Level 3 

Total 

(in millions) 

December 31, 2019 

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 

$ 

3 

821 

— 

— 

33 

700 

210 

201 

92 

567 

— 

141 

68 

57

287 

5,259 

167 

217 

97 

290 

113 

9 

374 

120 

249 

35 

50 

48 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

7 

— 

9

290 

6,080 

167 

217 

130 

990 

323 

210 

466 

687 

249 

183 

118 

114 

Plan investments - excluding investments at NAV 

$ 

2,893 

7,315 

16 

10,224 

Investments at NAV (6) 

Net receivables 

Total plan assets 

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 

902 

— 

— 

55 

582 

167 

141 

72 

449 

— 

148 

63 

34

284 

4,414 

118 

114 

186 

238 

89 

7 

357 

110 

205 

33 

32 

44 

Plan investments - excluding investments at NAV 

$ 

2,615 

6,231 

Investments at NAV (6) 

Net receivables 

Total plan assets 

478 

61 

$  10,763 

286 

5,316 

118 

114 

241 

820 

256 

148 

429 

559 

205 

195 

95 

86 

8,868 

566 

43 

$ 

9,477 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

14 

— 

8

22 

53 

— 

— 

— 

— 

— 

— 

— 

— 

12 

— 

— 

— 

4 

69 

69 

— 

— 

— 

— 

— 

— 

— 

— 

9 

— 

— 

— 

4 

145 

— 

177 

— 

— 

73 

19 

11 

— 

22 

— 

— 

— 

—

447 

22 

— 

183 

— 

— 

115 

28 

17 

— 

40 

— 

— 

— 

—

82 

405 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

24

24 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

24

24 

198 

— 

177 

— 

— 

73 

19 

11 

— 

34 

— 

— 

— 

28 

540 

— 

— 

540 

91 

— 

183 

— 

— 

115 

28 

17 

— 

49 

— 

— 

— 

28 

511 

— 

— 

511 

(1) 

(2) 

(3) 

(4) 

(5) 

(6) 

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. 
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. 
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. 
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. 
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. 
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. 

240 

Wells Fargo & Company 

  
 
 
Table 23.9 presents the changes in Level 3 pension plan and 

other benefit plan assets measured at fair value. 

Table 23.9:  Fair Value Level 3 Pension and Other Benefit Plan Assets 

(in millions) 

Quarter ended December 31, 2019 

Pension plan assets: 

Real estate 

Other 

Total pension plan assets 

Other benefits plan assets: 

Other 

Total other benefit plan assets 

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 

Gains (losses) 

Balance 
beginning 
 of year 

Realized 

Unrealized (1) 

Purchases, 
sales 
and 
settlements 
(net) 

Transfers 
Into/ 
(Out of) 
 Level 3 

Balance 
end of 
 year 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

14 

8 

22 

24 

24 

20 

8 

28 

23 

23 

1 

— 

1 

— 

— 

(2) 

— 

(2) 

1 

1 

1 

2 

3 

— 

— 

(1) 

— 

(1) 

— 

— 

(9) 

(1) 

(10) 

— 

— 

(3) 

— 

(3) 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

7 

9 

16 

24 

24 

14 

8 

22 

24 

24 

(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. 

Wells Fargo & Company 

241 

  
 
  
 
Note 23:  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 1 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 $1.1 billion in 2019 and $1.2 billion in both 2018 and 2017. 

Other Expenses 
Table 23.10 separately presents other expenses exceeding 1% of 
the sum of net interest income and total noninterest income in 
any of the years presented. 

Table 23.10:  Other Expenses 

(in millions) 

Operating losses 

Outside professional services 

Contract services (1) 

Leases (2) 

Advertising and promotion 

Outside data processing 

Other 

Year ended December 31, 

2019 

$ 

4,321 

3,198 

2,489 

1,155 

1,076 

673 

3,840 

2018 

3,124 

3,306 

2,192 

1,334 

857 

660 

2017 

5,492 

3,813 

1,638 

1,351 

614 

891 

4,129 

3,789 

Total other noninterest expense 

$  16,752 

15,602 

17,588 

(1) 

(2) 

The amount for 2017 has been revised to conform with the current period presentation 
whereby temporary help is included in contract services rather than in all other noninterest 
expense. 
Represents expenses for assets we lease to customers. 

242 

Wells Fargo & Company 

  
 
 
Note 24:  Income Taxes 

Table 24.1 presents the components of income tax expense. 

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. In 2018, we 
reclassified $400 million from cumulative OCI to retained 
earnings to update amounts to an appropriate tax rate under the 
Tax Act. See Note 26 (Other Comprehensive Income) for more 
information. 

We have determined that a valuation allowance is required 

for 2019 in the amount of $306 million, predominantly 
attributable to deferred tax assets in various state and non-U.S. 
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. 

At December 31, 2019, we had net operating loss carry 
forwards with related deferred tax assets of $363 million. If 
these carry forwards are not utilized, they will mostly expire in 
varying amounts through December 31, 2039. 

We do not intend to distribute earnings of certain non-U.S. 

subsidiaries in a taxable manner, and therefore intend to limit 
distributions of non-U.S. 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 non-U.S. 
taxes. All other undistributed non-U.S. earnings will continue to 
be permanently reinvested outside the U.S. and the related tax 
liability on these earnings is insignificant. 

Table 24.1:  Income Tax Expense 

(in millions) 

Current: 

Federal 

State and local 

Non-U.S. 

Total current 

Deferred: 

Federal 

State and local 

Non-U.S. 

Total deferred 

Total 

Year ended December 31, 

2019 

2018 

2017 

$ 

5,244 

2,005 

154 

7,403 

(2,374) 

(863) 

(9) 

(3,246) 

$ 

4,157 

2,382 

1,140 

170 

3,692 

1,706 

236 

28 

1,970 

5,662 

3,507 

561 

183 

4,251 

156 

564 

(54) 

666 

4,917 

The tax effects of our temporary differences that gave rise 

to significant portions of our deferred tax assets and liabilities 
are presented in Table 24.2. 

Table 24.2:  Net Deferred Tax Liability (1) 

(in millions) 

Deferred tax assets 

Dec 31, 

2019 

Dec 31, 

2018 

Allowance for credit losses 

$ 

2,587 

Deferred compensation and employee 

benefits 

Accrued expenses 

PCI loans 

Basis difference in debt securities 

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 

2,969 

874 

69 

690 

— 

363 

1,207 

8,759 

(306) 

(3,080) 

(4,413) 

(1,626) 

(4,146) 

(511) 

(504) 

(561) 

(890) 

Total deferred tax liabilities 

(15,731) 

Net deferred tax liability (2) 

$ 

(7,278) 

2,644 

2,893 

815 

467 

98 

1,022 

366 

1,272 

9,577 

(315) 

(3,475) 

(4,271) 

(1,301) 

(7,252) 

(427) 

— 

(696) 

(831) 

(18,253) 

(8,991) 

(1) 
(2) 

Prior period amounts have been revised to conform with the current period presentation. 
The net deferred tax liability is included in accrued expenses and other liabilities. 

Wells Fargo & Company 

243 

  
 
  
 
 
Note 24:  Income Taxes (continued) 

Table 24.3 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. 

Table 24.3:  Effective Income Tax Expense and Rate 

(in millions) 

Amount 

2019 

Rate 

Amount 

2018 

Rate 

Amount 

Statutory federal income tax expense and rate 

$ 

4,978 

21.0% 

$ 

5,892 

21.0% 

$ 

9,485 

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 

896 

(460) 

(1,715) 

653 

— 

(195) 

3.8 

(2.0) 

(7.2) 

2.7 

— 

(0.8) 

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 

(3,713) 

(870) 

Effective income tax expense and rate 

$ 

4,157 

17.5% 

$ 

5,662 

20.2% 

$ 

4,917 

December 31, 

2017 

Rate 

35.0% 

3.4 

(3.0) 

(5.2) 

4.9 

(13.7) 

(3.3) 

18.1% 

All three years include income tax expense related to non-
tax-deductible litigation accruals. The 2019 and 2018 effective 
tax rates reflect the reduction in the U.S. federal statutory 
income tax rate from 35% to 21% resulting from the Tax Cuts & 
Jobs Act (Tax Act). The 2018 effective tax rate also reflected the 
reconsideration of reserves for state income taxes following the 
U.S. Supreme Court opinion in South Dakota v. Wayfair, Inc. as 
well as $164 million of income tax expense resulting from the 
final re-measurement of our initial estimates for the impacts of 
the Tax Act. The 2017 effective income tax rate included an 
estimated 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 non-U.S. earnings. 

Table 24.4 presents the change in unrecognized tax benefits. 

Table 24.4:  Change in Unrecognized Tax Benefits 

(in millions) 

Balance at beginning of year 

Additions: 

For tax positions related to the current year 

For tax positions related to prior years 

Reductions: 

For tax positions related to prior years 

Lapse of statute of limitations 

Settlements with tax authorities 

Year ended 
December 31, 

2019 

$ 

5,750 

2018 

5,167 

123 

91 

(378) 

(5) 

(123) 

393 

503 

(262) 

(7) 

(44) 

Balance at end of year 

$ 

5,458 

5,750 

Of the $5.5 billion of unrecognized tax benefits at 

December 31, 2019, approximately $3.8 billion would, if 
recognized, affect the effective tax rate. The remaining 
$1.7 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, 2019 and 2018, we have accrued approximately 
$998 million and $968 million, respectively, for the payment of 
interest and penalties. In 2019, we recognized in income tax 
expense a net tax expense related to interest and penalties of 
$35 million. In 2018, we recognized in income tax expense a net 
tax expense related to interest and penalties of $200 million. 

We are subject to U.S. federal income tax as well as income 

tax in numerous state and non-U.S. jurisdictions. We are 
routinely examined by tax authorities in these various 
jurisdictions. The IRS is currently examining the 2015 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 non-U.S. taxing 
authorities. With few exceptions, Wells Fargo and its subsidiaries 
are not subject to federal, state, local and non-U.S. 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 2014. 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 $1.3 billion to our gross unrecognized tax benefits. 

244 

Wells Fargo & Company 

  
 
  
 
 
Note 25:  Earnings and Dividends Per Common Share 

Table 25.1 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 on share repurchases, and the Consolidated 
Statement of Changes in Equity and Note 21 (Common Stock 
and Stock Plans) for information about stock and options activity 
and terms and conditions of warrants. 

Table 25.1:  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 (2) 

Restricted share rights (2) 

Warrants (2) 

Diluted average common shares outstanding (denominator) 

Per share 

2019 

19,549 

1,611 

17,938 

4,393.1 

4.08 

Year ended December 31, 

2018 

22,393 

1,704 

20,689 

4,799.7 

4.31 

2017 

22,183 

1,629 

20,554 

4,964.6 

4.14 

4,393.1 

4,799.7 

4,964.6 

0.8 

31.5 

— 

4,425.4 

4.05 

8.0 

26.3 

4.4 

17.1 

24.7 

10.9 

4,838.4 

5,017.3 

4.28 

4.10 

$ 

$ 

$ 

$ 

(1) 

(2) 

The years ended December 31, 2019 and December 31, 2018, includes $220 million and $155 million, respectively, as a result of eliminating the discount on our Series K and Series J Preferred Stock. 
The Series K Preferred Stock was partially redeemed on September 16, 2019, and the Series J Preferred stock was redeemed on September 17, 2018. 
Calculated using the treasury stock method. 

Table 25.2 presents the outstanding Convertible Preferred 

Stock, Series L, and options to purchase shares of common stock 
that were anti-dilutive and therefore not included in the 
calculation of diluted earnings per common share. 

Table 25.2:  Outstanding Anti-Dilutive Securities 

Weighted-average shares 

Year ended December 31, 

(in millions) 

2019 

2018 

2017 

Convertible Preferred Stock, Series 
L (1) 

Stock options (2) 

25.3 

— 

25.3 

0.3 

25.3 

1.9 

(1) 
(2) 

Calculated using the if-converted method. 
Calculated using the treasury stock method. 

Table 25.3 presents dividends declared per common share. 

Table 25.3:  Dividends Declared Per Common Share 

Per common share 

Year ended December 31, 

2019 

1.92 

$ 

2018 

1.64 

2017 

1.54 

Wells Fargo & Company 

245 

  
 
  
 
  
 
 
Note 26:  Other Comprehensive Income 

Table 26.1 provides the components of other comprehensive 
income (OCI), reclassifications to net income by income 
statement line item, and the related tax effects. 

Table 26.1:  Summary of Other Comprehensive Income 

(in millions)

Debt securities (1): 

Before 
 tax 

Tax 
effect 

2019 

Net of 
tax 

Before 
tax 

Tax 
 effect 

Year ended December 31, 

2018 

Net of 
tax 

Before 
tax 

Tax 
 effect 

2017 

Net of 
tax 

Net unrealized gains (losses) arising during the period 

$ 

5,439 

(1,337) 

4,102 

(4,493) 

1,100 

(3,393) 

2,719 

(1,056) 

1,663 

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 

Subtotal reclassifications to net income 

263 

(140) 

—

(1) 

122 

(65) 

34 

—

— 

(31) 

198 

(106) 

— 

(1) 

91 

357 

(108) 

— 

(1) 

248 

(88) 

27 

— 

— 

269 

(81) 

— 

(1) 

(61) 

187 

198 

(479) 

(456) 

— 

(737) 

(75) 

181 

172 

— 

278 

123 

(298) 

(284) 

— 

(459) 

Net change 

5,561 

(1,368) 

4,193 

(4,245) 

1,039 

(3,206) 

1,982 

(778) 

1,204 

Derivatives and hedging activities: 

Fair Value Hedges: 

Change in fair value of excluded components on 

fair value hedges (4) 

Cash Flow Hedges: 

Net unrealized 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 

(3) 

(21) 

291 

8 

299 

275 

1 

5 

(72) 

(2) 

(74) 

(68) 

(2) 

(254) 

63 

(191) 

(253) 

95 

(158) 

(16) 

(278) 

67 

(211) 

(287) 

108 

(179) 

219 

6 

225 

207 

292 

2

294 

(238) 

(72) 

— 

(72) 

58 

220 

2 

222 

(551) 

8

(543) 

(180) 

(1,083) 

208 

(3) 

205 

408 

(343) 

5 

(338) 

(675) 

(40) 

10 

(30) 

(434) 

106 

(328) 

49 

(12) 

37 

141 

(8) 

133 

93 

73 

73 

(35) 

5 

(30) 

(20) 

(2) 

(2) 

106 

(3) 

103 

73 

71 

71 

127 

126

253 

(181) 

(156) 

(156) 

(31) 

(29) 

(60) 

46 

1 

1 

96 

97 

193 

(135) 

(155) 

(155) 

150 

3 

153 

202 

96 

96 

(57) 

2 

(55) 

(67) 

3 

3 

93 

5 

98 

135 

99 

99 

763 

(62) 

825 

Other comprehensive income (loss) 

$ 

6,002 

(1,458) 

4,544 

(4,820) 

1,144 

(3,676) 

1,197 

(434) 

Less: Other comprehensive loss from noncontrolling 

interests, net of tax 

Wells Fargo other comprehensive income (loss), net 

of tax 

— 

$  4,544 

(2) 

(3,674) 

(1) 

(2) 
(3) 

(4) 

(5) 

The year ended December 31, 2017, includes net unrealized gains (losses) arising during the period from equity securities of $81 million and reclassification of net (gains) losses to net income related 
to equity securities of $(456) million. 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 years ended December 31, 2018, and December 31, 2019, reflect net unrealized gains (losses) arising during the period and reclassification of net (gains) 
losses to net income from only debt securities. 
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. 
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. 
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. 
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 and 2019 balances are 
reclassified to other noninterest expense on the consolidated statement of income. For 2017 these balances were reclassified to employee benefits. 

246 

Wells Fargo & Company 

  
 
 
Table 26.2 provides the cumulative OCI balance activity on 

an after-tax basis. 

Table 26.2:  Cumulative OCI Balances 

(in millions) 

Balance, December 31, 2016 

Transition adjustment (4) 

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 (5) 

Balance, January 1, 2018 

Reclassification of certain tax effects to retained earnings (6) 

Net unrealized losses arising during the period 

Amounts reclassified from accumulated other comprehensive income 

Net change 

Less: Other comprehensive loss from noncontrolling interests 

Balance, December 31, 2018 

Transition adjustment (7) 

Balance, January 1, 2019 

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, 2019 

Debt 
securities (1) 

Fair value 
hedges (2) 

Cash flow
hedges (3)

Defined 
benefit 
 plans 
 adjustments 

Foreign 
 currency 
translation 
adjustments 

Cumulative 
other 
comprehensive 
 income (loss) 

$ 

(1,099) 

— 

(1,099) 

1,663 

(459) 

1,204 

(66) 

171 

(118) 

53 

31 

(3,393) 

187 

(3,175) 

— 

(3,122) 

481 

(2,641) 

4,102 

91 

4,193 

— 

— 

169 

169 

(158) 

— 

(158) 

— 

11 

— 

11 

2 

(191) 

— 

(189) 

— 

(178) 

— 

(178) 

(2) 

— 

(2) 

—

89 

(1) 

88 

(179) 

(338) 

(517) 

— 

(429) 

— 

(429) 

(89) 

(211) 

222 

(78) 

— 

(507) 

— 

(507) 

(16) 

225 

209 

— 

(1,943) 

— 

(1,943) 

37 

98 

135 

— 

(1,808) 

— 

(1,808) 

(353) 

(328) 

193 

(488) 

— 

(2,296) 

— 

(2,296) 

(30) 

103 

73 

— 

(184) 

— 

(184) 

99 

— 

99 

4 

(89) 

— 

(89) 

9 

(155) 

— 

(146) 

(2) 

(233) 

— 

(233) 

71 

— 

71 

— 

(3,137) 

168 

(2,969) 

1,462 

(699) 

763 

(62) 

(2,144) 

(118) 

(2,262) 

(400) 

(4,278) 

602 

(4,076) 

(2) 

(6,336) 

481 

(5,855) 

4,125 

419 

4,544 

— 

$ 

1,552 

(180) 

(298) 

(2,223) 

(162) 

(1,311) 

(1) 

(2) 
(3) 

(4) 
(5) 
(6) 

(7) 

The year ended December 31, 2017, includes net unrealized gains (losses) arising during the period from equity securities of $81 million and reclassification of net (gains) losses to net income related 
to equity securities of $(456) million. 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 years ended December 31, 2018, and December 31, 2019, reflect net unrealized gains (losses) arising during the period and reclassification of net (gains) 
losses to net income from only debt securities. 
Substantially all of the amounts for fair value hedges are foreign exchange contracts. 
Substantially all of the amounts for cash flow hedges are foreign exchange contracts for the year-ended December 31, 2019, and interest rate contracts for the years ended December 31, 2018 and 
2017. 
Transition adjustment relates to our adoption of ASU 2017-12 – Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting for Hedging Activities. 
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. 
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): Reclassif ication of Certain Tax Effects from Accumulated Other Comprehensive Income in third quarter 2018. 
The transition adjustment relates to our adoption of ASU 2017-08 – Receivables – Nonrefundable Fees and Other Costs (Subtopic 310-20): Premium Amortization on Purchased Callable Debt 
Securities. See Note 1 (Summary of Significant Accounting Policies) for more information. 

Wells Fargo & Company 

247 

  
 
 
Note 27:  Operating Segments 

As of December 31, 2019, we had 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 reporting process. The 
management reporting process is based on U.S. GAAP with 
specific adjustments, such as for funds transfer pricing for asset/ 
liability management, for shared revenues and expenses, and tax-
equivalent adjustments to consistently reflect income from 
taxable and tax-exempt sources. The management reporting 
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. On February 11, 2020, we announced a new 
organizational structure with five principal lines of business: 
Consumer and Small Business Banking; Consumer Lending; 
Commercial Banking; Corporate and Investment Banking; and 
Wealth and Investment Management. The Company is currently 
in the process of transitioning to this new organizational 
structure, including identifying leadership for some of these 
principal business lines and aligning management reporting and 
allocation methodologies. These changes will not impact the 
consolidated financial results of the Company, but are expected 
to result in changes to our operating segments. We will update 
our operating segment disclosures, including comparative 
financial results, when the Company completes its transition and 
is managed in accordance with the new organizational structure. 

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 
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, 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, and CRE 
loan servicing. 

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, 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 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, substantially all of which 
represents products and services for Wealth and Investment 
Management customers served through Community Banking 
distribution channels. 

248 

Wells Fargo & Company 

 
 
Table 27.1 presents our results by operating segment. 

Table 27.1:  Operating Segments 

(income/expense in millions, average balances in billions)

2019 

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) (3) 

Net income (loss) before noncontrolling interests 

Less: Net income (loss) from noncontrolling interests 

Net income (loss) 

2018 

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) (3) 

Net income (loss) before noncontrolling interests 

Less: Net income (loss) from noncontrolling interests 

Net income (loss) 

2017 

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) (3) 

Net income (loss) before noncontrolling interests 

Less: Net income (loss) from noncontrolling interests 

Net income (loss) 

2019 

Average loans 

Average assets 

Average deposits 

2018 

Average loans 

Average assets 

Average deposits 

Community 
 Banking 

Wholesale 
Banking 

Wealth and 
Investment 
Management 

Other (1) 

Consolidated 
Company 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

27,610 

2,319 

17,706 

32,696 

10,301 

2,426 

7,875 

477 

7,398 

29,219 

1,783 

17,694 

30,491 

14,639 

3,784 

10,855 

461 

10,394 

28,658 

2,555 

18,360 

32,615 

11,848 

634 

11,214 

276 

10,938 

459.4 

1,028.4 

782.0 

463.7 

1,034.1 

757.2 

17,699 

378 

9,978 

15,352 

11,947 

1,246 

10,701 

5 

10,696 

18,690 

(58) 

10,016 

16,157 

12,607 

1,555 

11,052 

20 

11,032 

18,810 

(19) 

11,190 

16,624 

13,395 

3,496 

9,899 

(15) 

9,914 

475.3 

861.0 

422.5 

465.7 

830.5 

423.7 

4,037 

5 

13,304 

13,709 

3,627 

904 

2,723 

10 

2,713 

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 

75.6 

84.3 

146.0 

74.6 

83.9 

165.0 

(2,115) 

(15) 

(3,156) 

(3,579) 

(1,677) 

(419) 

(1,258) 

— 

(1,258) 

(2,355) 

24 

(3,232) 

(3,460) 

(2,151) 

(538) 

(1,613) 

— 

(1,613) 

(2,552) 

(3) 

(3,149) 

(3,378) 

(2,320) 

(881) 

(1,439) 

— 

(1,439) 

(59.3) 

(60.3) 

(64.2) 

(58.8) 

(59.6) 

(70.0) 

47,231 

2,687 

37,832 

58,178 

24,198 

4,157 

20,041 

492 

19,549 

49,995 

1,744 

36,413 

56,126 

28,538 

5,662 

22,876 

483 

22,393 

49,557 

2,528 

38,832 

58,484 

27,377 

4,917 

22,460 

277 

22,183 

951.0 

1,913.4 

1,286.3 

945.2 

1,888.9 

1,275.9 

(1) 

(2) 

(3) 

Includes the elimination of certain items that are included in more than one business segment, substantially all of which represents products and services for WIM customers served through 
Community Banking distribution channels. 
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 
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. 
Income tax expense (benefit) for our Wholesale Banking operating segment included income tax credits related to low-income housing and renewable energy investments of $1.8 billion, $1.6 billion 
and $1.4 billion for the years ended December 31, 2019, 2018 and 2017 respectively. 

Wells Fargo & Company 

249 

  
 
 
Note 28:  Parent-Only Financial Statements 

The following tables present Parent-only condensed financial 
statements. 

Table 28.1:  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 

Net income 

Year ended December 31, 

2019 

2018 

2017 

$ 

21,930 

3,356 

43 

(162) 

25,167 

664 

— 

4,931 

2 

1,327 

6,924 

18,243 

(945) 

361 

$ 

19,549 

22,427 

3,298 

49 

(424) 

25,350 

644 

2

4,541 

3

286 

5,476 

19,874 

(544) 

1,975 

22,393 

20,746 

1,984 

146 

1,238 

24,114 

189 

— 

3,595 

5 

1,888 

5,677 

18,437 

(319) 

3,427 

22,183 

(1) 

Includes dividends paid from indirect bank subsidiaries of $21.8 billion, $20.8 billion and $17.9 billion in 2019, 2018 and 2017, respectively. 

Table 28.2:  Parent-Only Statement of Comprehensive Income 

(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: 

Total comprehensive income 

2019 

19,549 

$ 

(45) 

(12) 

75 

4,526 

4,544 

$ 

24,093 

Year ended December 31, 

2018 

22,393 

(12) 

(198) 

(132) 

(3,332) 

(3,674) 

18,719 

2017 

22,183 

94 

(158) 

118 

771 

825 

23,008 

(1) 

The year ended December 31, 2017 includes net unrealized gains arising during the period from equity securities of $3 million and reclassification of net (gains) to net income related to equity 
securities of $(21) million. 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 years ended December 31, 2019 and 2018, reflect net unrealized gains (losses) arising during the period and reclassification of net (gains) losses to net income from only 
debt securities. 

250 

Wells Fargo & Company 

  
 
  
 
 
Table 28.3:  Parent-Only Balance Sheet 

(in millions) 

Assets 

Cash, cash equivalents, and restricted cash due from: 

Subsidiary banks 

Nonaffiliates 

Debt securities: 

Available-for-sale, at fair value 

Loans to nonbank subsidiaries 

Investments in subsidiaries (1) 

Equity securities 

Other assets 

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, 

2019 

Dec 31, 

2018 

$ 

14,948 

16,301 

1 

1 

145,383 

208,076 

1,007 

4,608 

374,024 

8,050 

152,628 

26,200 

186,878 

187,146 

374,024 

$ 

$ 

$ 

— 

1 

139,163 

202,695 

2,164 

4,639 

364,963 

6,986 

135,079 

26,732 

168,797 

196,166 

364,963 

(1) 

The years ended December 31, 2019, and December 31, 2018, include indirect ownership of bank subsidiaries with equity of $170.4 billion and $167.6 billion, respectively. 

Wells Fargo & Company 

251 

  
 
 
Note 28:  Parent-Only Financial Statements (continued) 

Table 28.4:  Parent-Only Statement of Cash Flows 

(in millions) 

Cash flows from operating activities: 

Net cash provided by operating activities 

Cash flows from investing activities: 

Available-for-sale debt securities: 

Proceeds from sales:

 Subsidiary banks 

 Nonaffiliates 

Prepayments and maturities:

 Subsidiary banks 

Purchases:

 Subsidiary banks 

Equity securities, not held for trading: 

Proceeds from sales and capital returns 

Purchases 

Loans: 

Net 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: 

Year ended December 31, 

2019 

2018 

2017 

$ 

27,601 

19,024 

22,233 

— 

— 

— 

— 

326 

(1,052) 

(3) 

(5,286) 

1,703 

(384) 

22 

(4,674) 

— 

— 

— 

— 

355 

(220) 

(7) 

(2,441) 

756 

2,407 

109 

959 

8,658

8,824 

10,250 

(3,900) 

743 

(215) 

(35,876) 

(73,729) 

69,286 

(2,029) 

113 

(17,875) 

Net increase (decrease) in short-term borrowings and indebtedness to subsidiaries 

(636) 

12,467 

(8,685) 

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 used by financing activities 

Net change in cash, cash equivalents, and restricted cash 

Cash, cash equivalents, and restricted cash at beginning of year 

Cash, cash equivalents, and restricted cash at end of year 

$ 

20,369 

(8,143) 

— 

(1,550) 

(1,391) 

380 

(302) 

(24,533) 

(8,198) 

(275) 

(24,279) 

(1,352) 

16,301 

14,949 

1,876 

(9,162) 

— 

(2,150) 

(1,622) 

632 

(331) 

(20,633) 

(7,692) 

(248) 

(26,863) 

(6,880) 

23,181 

16,301 

22,217 

(13,709) 

677 

— 

(1,629) 

1,211 

(393) 

(9,908) 

(7,480) 

(138) 

(17,837) 

(13,479) 

36,660 

23,181 

252 

Wells Fargo & Company 

  
 
 
Note 29:  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 29.1 presents regulatory capital information for 

Wells Fargo & Company and the Bank in accordance with the 
Basel III capital requirements. We must report the lower of our 
Common Equity Tier 1 (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 

Table 29.1:  Regulatory Capital Information 

operational risk component. The Basel III capital requirements 
for calculating CET1 and tier 1 capital, along with RWAs, are fully 
phased-in. However, the requirements for determining tier 2 and 
total capital are still in accordance with Transition Requirements 
and are scheduled to be fully phased-in by the end of 2021. 
Accordingly, the information presented below reflects fully 
phased-in CET1 capital, tier 1 capital, and RWAs, but reflects 
total capital still in accordance with Transition Requirements. 

At December 31, 2019, the Bank and our other insured 
depository institutions were considered well-capitalized under 
the requirements of the Federal Deposit Insurance Act. 

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, 2019, the Bank met these 
requirements. 

December 31, 2019 

Wells Fargo & Company 

December 31, 2018 

December 31, 2019 

Wells Fargo Bank, N.A. 

December 31, 2018 

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 

$ 

138,760 

158,949 

188,333 

138,760 

158,949 

196,223 

146,363 

167,866 

198,798 

146,363 

167,866 

207,041 

145,149 

145,149 

158,615 

145,149 

145,149 

166,056 

142,685 

142,685 

155,558 

142,685 

142,685 

163,380 

1,230,066 

1,913,297 

1,245,853 

1,913,297 

1,177,350 

1,850,299 

1,247,210 

1,850,299 

1,110,379 

1,695,807 

1,152,791 

1,695,807 

1,058,653 

1,652,009 

1,154,182 

1,652,009 

11.28% 

12.92 

15.31  * 

8.31 

11.14  * 

12.76  * 

15.75 

8.31 

12.43 

14.26 

16.89 

9.07 

11.74  * 

13.46  * 

16.60  * 

9.07 

13.07 

13.07 

14.28  * 

8.56 

12.59  * 

12.59  * 

14.40 

8.56 

13.48 

13.48 

14.69 

8.64 

12.36  * 

12.36  * 

14.16  * 

8.64 

Supplementary leverage: (2) 

Total leverage exposure 

$ 

Supplementary leverage ratio 

December 31, 2019 

2,247,729 

7.07% 

Wells Fargo & Company 

December 31, 2018 

2,174,564 

7.72 

December 31, 2019 

2,006,180 

7.24 

Wells Fargo Bank, N.A. 

December 31, 2018 

1,957,276 

7.29 

*Denotes the lowest capital ratio as determined under the Advanced and Standardized Approaches. 
(1) 
(2) 

The leverage ratio consists of Tier 1 capital divided by total average assets, excluding goodwill and certain other items. 
The supplementary leverage ratio (SLR) consists of Tier 1 capital divided by total leverage exposure. Total leverage exposure consists of total average assets, less goodwill and other permitted Tier 1 
capital deductions (net of deferred tax liabilities), plus certain off-balance sheet exposures. 

Table 29.2 presents the minimum required regulatory 
capital ratios under Transition Requirements to which the 

Company and the Bank were subject as of December 31, 2019, 
and December 31, 2018. 

Table 29.2:  Minimum Required Regulatory Capital Ratios – Transition Requirements (1) 

Regulatory capital ratios: 

Common equity tier 1 capital 

Tier 1 capital 

Total capital 

Tier 1 leverage 

Supplementary leverage (2) 

December 31, 2019 

December 31, 2018 

December 31, 2019 

Wells Fargo & Company 

Wells Fargo Bank, N.A. 

December 31, 2018 

9.000% 

10.500 

12.500 

4.000 

5.000 

7.875 

9.375 

11.375 

4.000 

5.000 

7.000 

8.500 

10.500 

4.000 

6.000 

6.375 

7.875 

9.875 

4.000 

6.000 

(1) 

At December 31, 2019, under transition requirements, the CET1, tier 1 and total capital minimum ratio requirements for Wells Fargo & Company include a capital conservation buffer of 2.500% and a 
global systemically important bank (G-SIB) surcharge of 2.000%. Only the 2.500% capital conservation buffer applies to the Bank at December 31, 2019. 

(2)  Wells Fargo & Company is required to maintain a SLR of at least 5.000% (comprised of a 3.000% minimum requirement plus a supplementary leverage buffer of 2.000%) to avoid restrictions on 
capital distributions and discretionary bonus payments. The Bank is required to maintain a SLR of at least 6.000% to be considered well-capitalized under applicable regulatory capital adequacy 
guidelines. 

Wells Fargo & Company 

253 

Tier 1 

Total 

Assets: 

Risk-weighted assets 

Adjusted average assets (1) 

Regulatory capital ratios: 

Common equity tier 1 capital 

Tier 1 capital 

Total capital 

Tier 1 leverage (1) 

  
 
  
 
 
Report of Independent Registered Public Accounting Firm 

To 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, 2019 and 2018, 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, 2019, 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, 2019 and 2018, and the results of its operations and its cash flows for each of the years in the three-year 
period ended December 31, 2019, 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, 2019, 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 26, 2020, 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. 

Critical Audit Matters 

The critical audit matters communicated below are matters arising from the current period audit of the consolidated financial 
statements that were communicated or required to be communicated to the audit committee and that: (1) relate to accounts or 
disclosures that are material to the consolidated financial statements and (2) involved our especially challenging, subjective, or complex 
judgments. The communication of critical audit matters does not alter in any way our opinion on the consolidated financial statements, 
taken as a whole, and we are not, by communicating the critical audit matters below, providing separate opinions on the critical audit 
matters or on the accounts or disclosures to which they relate. 

Assessment of the allowance for credit losses 

As discussed in Notes 1 and 6 to the consolidated financial statements, the allowance for credit losses is the Company’s estimate of 
credit losses inherent in the loan portfolio, including unfunded credit commitments, at the balance sheet date. The allowance for credit 
losses at December 31, 2019 was $10.5 billion, or 1.09% of total loans. Of the total allowance for credit losses, $9.2 billion relates to 
loans collectively evaluated for impairment in accordance with ASC 450-20 and $1.3 billion relates to loans individually evaluated for 
impairment in accordance with ASC 310-10. The Company has an established process to determine the appropriateness of the 
allowance for credit losses that estimates the losses inherent in its portfolio and related unfunded credit commitments. The Company 
develops and documents its allowance methodology at the portfolio segment level - commercial and consumer. For each portfolio 
segment, losses are estimated collectively for groups of loans with similar characteristics, and individually or pooled for impaired loans. 

We identified the assessment of the allowance for credit losses as a critical audit matter because of the complexity and significant 
judgment involved in evaluating the measurement uncertainty in the estimate. There was a high degree of subjectivity related to the 
selection of a credit loss estimation model that fits the credit risk characteristics for particular loan portfolios, including the assessment 
of limitations to credit loss estimation addressed through imprecision. There was also a high degree of subjectivity and potential for 
management bias related to determining an amount of imprecision for inclusion within the Company’s overall estimate of inherent 
credit losses. Further, the assessment of credit risk ratings for commercial loans required the use of significant judgment as well as 
industry knowledge and experience to evaluate individual borrower’s financial strength and the quality of collateral. 

254 

Wells Fargo & Company 

 
The primary procedures we performed to address this critical audit matter included the following: We tested certain internal controls 
over the Company’s allowance for credit losses estimation process that are designed to (1) evaluate and monitor the ability of the model 
methodologies to estimate credit losses for selected commercial and consumer portfolios, (2) assess the limitations to credit loss 
estimation models, (3) determine the amount of imprecision for inclusion within the Company’s overall estimate of the effect of 
quantitative and qualitative factors on inherent credit losses, and (4) assess credit risk ratings for commercial loans. We involved credit 
risk professionals with specialized skills and knowledge who assisted in testing the Company’s process to evaluate the design of selected 
commercial and consumer portfolio model methodologies and the appropriateness of credit risk ratings to estimate losses in 
accordance with relevant U.S. generally accepted accounting principles and identify and assess the limitations to the credit loss 
estimation models. We evaluated the methodologies and assumptions used to estimate certain imprecision amounts. We tested the 
accuracy of the range for certain quantifiable imprecision amounts, including, as applicable, recalculation of the range and procedures 
over relevance and reliability of the inputs into the calculation of the range. We tested whether certain imprecision amounts reflect risks 
inherent in the processes and assumptions used to estimate the allowance for credit losses. We performed trend analyses on the 
imprecision amount relative to the allowance for credit losses to identify any potential for management bias considering portfolio 
trends, internal and external credit metrics, and economic factors. 

Assessment of the residential mortgage servicing rights (MSRs) 

As discussed in Notes 1, 10, 11, 12, and 19 to the consolidated financial statements, the Company recognizes MSRs when it purchases 
servicing rights from third parties, or retains servicing rights in connection with the sale or securitization of loans it originated. The 
Company has elected to carry its residential MSRs at fair value with periodic changes reflected in earnings. The Company’s residential 
MSR asset as of December 31, 2019 was $11.5 billion on an underlying loan servicing portfolio of $1.1 trillion. 

The Company uses a valuation model for determining fair value 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. These assumptions include estimates of prepayment speeds, discount rates, default rates, cost to service (including delinquency 
and foreclosure costs), escrow account earnings, contractual servicing fee income, ancillary income and late fees. The estimated fair 
value of MSRs is periodically benchmarked to independent appraisals. 

We identified the assessment of the valuation of residential MSRs as a critical audit matter because of the complexity and significant 
judgment involved in deriving the estimate. There was a high degree of subjectivity used to evaluate the following key assumptions 
because they are unobservable and the sensitivity of changes to those assumptions had a significant effect on the valuation: 
prepayment speeds, discount rate, and costs to service. There was also a high degree of subjectivity and potential for management bias 
related to updates made to key assumptions due to changes in market conditions, mortgage interest rates, or servicing standards. 

The primary procedures we performed to address the critical audit matter included the following: We tested certain internal controls 
over the Company’s residential MSR valuation process to (1) assess the valuation model, (2) evaluate the key assumptions used in 
determining the MSR fair value, and (3) compare the MSR fair value to independent appraisals. We involved valuation professionals with 
specialized skills and knowledge who assisted in evaluating the design of the valuation model used to estimate the MSR fair value in 
accordance with relevant U.S. generally accepted accounting principles, and to evaluate key assumptions (prepayment speeds, discount 
rates, and costs to service) based on an analysis of backtesting results and a comparison of key assumptions to available data for 
comparable entities and independent appraisals. We assessed the key assumption updates made during the year by considering 
backtesting results, external market events, and independent appraisals or other circumstances and by involving valuation professionals 
to assist in determining that there were no significant assumption updates that a market participant would have expected to be 
incorporated in the valuation at year end that were not incorporated. 

We have served as the Company’s auditor since 1931. 

San Francisco, California 
February 26, 2020 

Wells Fargo & Company 

255 

 
Quarterly Financial Data 
Condensed Consolidated Statement of Income - Quarterly (Unaudited) 

2019 

Quarter ended 

2018 

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 

$  15,595 

16,499 

16,986 

17,003 

16,921 

16,364 

16,015 

15,347 

4,395 

4,874 

4,891 

4,692 

4,277 

3,792 

3,474 

3,109 

11,200 

11,625 

12,095 

12,311 

12,644 

12,572 

12,541 

12,238 

644 

695 

503 

845 

521 

580 

452 

191 

Net interest income after provision for credit losses 

10,556 

10,930 

11,592 

11,466 

12,123 

11,992 

12,089 

12,047 

Noninterest income 

Service charges on deposit accounts 

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 

Lease income 

Other 

Total noninterest income 

Noninterest expense 

Salaries 

Commission and incentive compensation 

Employee benefits 

Technology and equipment 

Net occupancy 

Core deposit and other intangibles 

FDIC and other deposit assessments 

Other 

1,279 

3,572 

1,020 

656 

783 

98 

131 

(8) 

451 

343 

335 

1,219 

3,559 

1,027 

858 

466 

91 

276 

3 

956 

402 

1,528 

1,206 

3,568 

1,025 

800 

758 

93 

229 

20 

622 

424 

744 

1,094 

3,373 

1,176 

3,520 

944 

770 

708 

96 

357 

125 

814 

443 

574 

981 

888 

467 

109 

10 

9 

21 

402 

753 

1,204 

3,631 

1,017 

850 

846 

104 

158 

57 

416 

453 

633 

1,163 

3,675 

1,001 

846 

770 

102 

191 

41 

295 

443 

485 

1,173 

3,683 

908 

800 

934 

114 

243 

1 

783 

455 

602 

8,660 

10,385 

9,489 

9,298 

8,336 

9,369 

9,012 

9,696 

4,721 

2,651 

1,436 

802 

749 

26 

130 

4,695 

2,735 

1,164 

693 

760 

27 

93 

4,541 

2,597 

1,336 

607 

719 

27 

144 

4,425 

2,845 

1,938 

661 

717 

28 

159 

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 

5,099 

5,032 

3,478 

3,143 

3,866 

3,546 

3,796 

4,394 

Total noninterest expense 

15,614 

15,199 

13,449 

13,916 

13,339 

13,763 

13,982 

15,042 

7,120 

966 

6,154 

90 

6,064 

353 

5,711 

7,598 

1,512 

6,086 

79 

6,007 

554 

5,453 

7,119 

1,810 

5,309 

123 

5,186 

394 

4,792 

6,701 

1,374 

5,327 

191 

5,136 

403 

4,733 

1.22 

1.21 

4,665.8 

4,700.8 

1.14 

1.13 

4,784.0 

4,823.2 

0.98 

0.98 

4,865.8 

4,899.8 

0.97 

0.96 

4,885.7 

4,930.7 

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 

3,602 

678 

2,924 

51 

$ 

2,873 

327 

Wells Fargo net income applicable to common stock 

$ 

2,546 

Per share information 

Earnings per common share 

Diluted earnings per common share 

Average common shares outstanding 

$ 

0.61 

0.60 

6,116 

1,304 

4,812 

202 

4,610 

573 

4,037 

0.93 

0.92 

7,632 

1,294 

6,338 

132 

6,206 

358 

5,848 

1.31 

1.30 

6,848 

881 

5,967 

107 

5,860 

353 

5,507 

1.21 

1.20 

4,197.1 

4,358.5 

4,469.4 

4,551.5 

Diluted average common shares outstanding 

4,234.6 

4,389.6 

4,495.0 

4,584.0 

256 

Wells Fargo & Company 

 
Average Balances, Yields and Rates Paid (Taxable-Equivalent basis) - Quarterly (1) - (Unaudited) 

(in millions) 

Earning assets 
Interest-earning deposits with banks 
Federal funds sold and securities purchased under resale agreements 
Debt securities (2): 

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 

Total held-to-maturity debt securities 

Total debt securities 

Mortgage loans held for sale (3) 
Loans held for sale (3) 
Loans: 

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 (3) 

Equity securities 
Other 

Funding sources 
Deposits: 

Total earning assets 

Interest-bearing checking 
Market rate and other savings 
Savings certificates 
Other time deposits 
Deposits in non-U.S 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 (4) 

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 

Average prime rate 
Average three-month London Interbank Offered Rate (LIBOR) 

Average
balance 

Yields/ 
rates 

$ 

127,287 
109,201 

1.63%  $ 
1.72 

103,818 

3.12 

2019 

Interest 
income/ 
expense 

Quarter ended December 31, 
2018 

Average 
balance 

Yields/ 
rates 

Interest 
income/ 
expense 

150,091 
76,108 

2.18%  $ 
2.22 

90,110 

3.52 

523 
472 

811 

70 
354 

1,038 
53 
1,091 
395 
1,910 

248 
123 
593 
1 
965 
3,686 
234 
15 

2,747 
577 
1,255 
239 
214 
5,032 

1.79 
3.58 

2.58 
4.40 
2.63 
3.88 
2.92 

2.19 
3.88 
2.49 
3.28 
2.51 
2.84 
3.90 
4.13 

3.84 
3.40 
4.07 
4.71 
4.41 
3.90 

3.66 
2,678 
5.32 
403 
12.26 
1,233 
5.04 
600 
6.60 
571 
4.92 
5,485 
4.37 
10,517 
2.81 
269 
22 
1.36 
3.51%  $  15,738 

1.09%  $ 
0.59 
1.68 
2.10 
1.50 

174 
1,094 
137 
459 
208 

2,072 
0.85 
439 
1.50 
1,743 
3.02 
141 
2.04 
4,395 
1.30 
— 
— 
0.98 
4,395 
2.53%  $  11,343 

15,636 
39,502 

161,146 
4,745 
165,891 
40,497 
261,526 

45,109 
12,701 
95,303 
39 
153,152 
518,496 
23,985 
1,365 

283,650 
67,307 
122,136 
20,076 
19,421 
512,590 

292,388 
30,147 
39,898 
47,274 
34,239 
443,946 
956,536 
38,278 
6,478 
1,781,626 

63,292 
732,705 
32,358 
87,069 
54,751 

970,175 
115,949 
230,430 
27,279 
1,343,833 
437,793 
1,781,626 

19,943 
26,389 
113,885 
160,217 

351,738 
53,879 
192,393 
(437,793) 
160,217 

1,941,843 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

825 
426 

794 

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 

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 

4.02 
2,868 
5.60 
491 
12.69 
1,211 
5.16 
592 
6.95 
637 
5.25 
5,799 
4.79 
11,396 
2.79 
261 
18 
1.78 
3.93%  $  17,089 

1.21%  $ 
0.43 
0.87 
2.46 
1.66 

165 
741 
48 
575 
236 

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 

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 

285,260 
34,844 
37,858 
45,536 
36,359 
439,857 
946,336 
37,412 
4,074 
1,732,850 

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 

(1) 
(2) 

(3) 
(4) 

Yields/rates and amounts include the effects of hedge and risk management activities associated with the respective asset and liability categories. 
Yields/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. 
Nonaccrual loans and related income are included in their respective loan categories. 
Includes taxable-equivalent adjustments of $143 million and $168 million for the quarters ended December 31, 2019 and 2018, respectively, predominantly related to tax-exempt income on certain 
loans and securities. The federal statutory tax rate was 21% for the periods ended December 31, 2019 and 2018. 

Wells Fargo & Company 

257 

4.83% 
1.93% 

5.28% 
2.62% 

 
 
Glossary of Acronyms 

Allowance for credit losses 

Available-for-sale 

Asset/Liability Management Committee 

Adjustable-rate mortgage 

LCR 

LHFS 

LIBOR 

LIHTC 

Liquidity coverage ratio 

Loans held for sale 

London Interbank Offered Rate 

Low income housing tax credit 

Accounting Standards Codification 

LOCOM 

Lower of cost or market value 

ACL 

AFS 

ALCO 

ARM 

ASC 

ASU 

AUA 

AUM 

AVM 

BCBS 

BHC 

CCAR 

CD 

CDS 

CECL 

CET1 

CFPB 

CLO 

CLTV 

CPI 

CRE 

DPD 

ESOP 

FASB 

FDIC 

FHA 

FHLB 

Accounting Standards Update 

Assets under administration 

Assets under management 

Automated valuation model 

Basel Committee on Bank Supervision 

Bank holding company 

Comprehensive Capital Analysis and Review 

Certificate of deposit 

Credit default swaps 

Current expected credit loss 

Common Equity Tier 1 

Consumer Financial Protection Bureau 

Collateralized loan obligation 

Combined loan-to-value 

Collateral protection insurance 

Commercial real estate 

Days past due 

Employee Stock Ownership Plan 

Financial Accounting Standards Board 

Federal Deposit Insurance Corporation 

Federal Housing Administration 

Federal Home Loan Bank 

FHLMC 

Federal Home Loan Mortgage Corporation 

FICO 

FNMA 

FRB 

GAAP 

GNMA 

GSE 

G-SIB 

HQLA 

HTM 

Fair Isaac Corporation (credit rating) 

Federal National Mortgage Association 

Board of Governors of the Federal Reserve System 

Generally accepted accounting principles 

Government National Mortgage Association 

Government-sponsored entity 

Globally systemic important bank 

High-quality liquid assets 

Held-to-maturity 

LTV 

MBS 

Loan-to-value 

Mortgage-backed security 

MLHFS 

Mortgage loans held for sale 

MSR 

NAV 

NPA 

NSFR 

OCC 

OCI 

OTC 

OTTI 

PCI 

PTPP 

RBC 

RMBS 

ROA 

ROE 

ROTCE 

RWAs 

SEC 

S&P 

SLR 

SOFR 

SPE 

TDR 

TLAC 

VA 

VaR 

VIE 

WIM 

Mortgage servicing right 

Net asset value 

Nonperforming asset 

Net stable funding ratio 

Office of the Comptroller of the Currency 

Other comprehensive income 

Over-the-counter 

Other-than-temporary impairment 

Purchased credit-impaired 

Pre-tax pre-provision profit 

Risk-based capital 

Residential mortgage-backed securities 

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 debt restructuring 

Total Loss Absorbing Capacity 

Department of Veterans Affairs 

Value-at-Risk 

Variable interest entity 

Wealth and Investment Management 

258 

Wells Fargo & Company 

 
Stock Performance 

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, 2019, 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 

2014 

$100 

100 

100 

2015 

$102 

101 

100 

2016 

$106 

114 

129 

2017 

$120 

138 

153 

2018 

$94 

132 

126 

2019 

$114 

174 

172 

5-year 
CAGR 

3%  Wells Fargo 

12%  S&P 500 

11%  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 

Wells Fargo 
(WFC) 

S&P 500 

KBW Nasdaq 
Bank Index 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

$100 

$116 

$105 

$133 

$182 

$226 

$230 

$241 

$272 

$213 

$259 

100 

100 

115 

123 

117 

95 

136 

126 

180 

174 

205 

190 

208 

191 

233 

245 

284 

291 

271 

239 

357 

326 

10-year 
CAGR 

10%  Wells Fargo 
14%  S&P 500 

13%  KBW Nasdaq 

Bank Index 

259 

 
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Wells 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 7,400 locations, more than 13,000 ATMs, the internet (wellsfargo.com) 

and mobile banking, and has offices in 32 countries and territories to support customers who conduct business 

in the global economy. With approximately 260,000 team members, Wells Fargo serves one in three households in the 

United States. Wells Fargo & Company was ranked No. 29 on Fortune’s 2019 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 

Our annual reports on Form 10-K, quarterly reports 

New York Stock Exchange: WFC 

4,134,425,937 common shares outstanding (12/31/19) 

S T O 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  

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 

You can buy Wells Fargo stock directly from Wells Fargo, 

even if you’re not a Wells Fargo stockholder, through 

at www.sec.gov. 

optional cash payments or automatic monthly deductions 

F O R W A R D - L O O K I N G   S T A T E M E N T S  

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 2019 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 28282-1921. 

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  

S H A R E O W N E R   S E R V I C E S  
A N D   T R A N S F E R   A G E N T  

A N N U A L   S H A R E H O L D E R S ’  
M E E T I N G  

KPMG LLP 

San Francisco, California 

1-415-963-5100 

I N V E S T O R   R E L AT I O N S  

1-415-371-2921 
investorrelations@wellsfargo.com 

EQ Shareowner Services 

10 a.m. Mountain Daylight Time 

P.O. Box 64874 

Tuesday, April 28, 2020 

St. Paul, Minnesota 

The Grand America Hotel 

55164-0874 

1-877-840-0492 

555 South Main Street 

Salt Lake City, Utah 

www.shareowneronline.com 

84111-4100 

260 

 
   
  
  
 
 
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
Wells Fargo’s Extensive Network 

LOCATIONS* 

7.4K 

ATMs 

13K 

CUSTOME RS 

70M+ 

WELLSFARGO.C OM** 

30.3M 

digital (online and mobile) active customers 

MOBILE  BANKING** 

24.4M 

mobile active users 

*Number of domestic and global locations. Includes Wells Fargo Advisors Private Client Group and Financial Network locations. 
**Data as of November 2019. 

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

WA 
189 

OR 
128 

MT 
43 

WY 
30 

ID 
85 

NV 
119 

CA 
1,232 

UT 
115 

CO 
198 

AZ 
259 

NM 
91 

AK 
53 

HI 
6 

Data as of December 31, 2019. 

A R O U N D   T H E   W O R L D  

ND 
27 

SD 
55 

NE 
54 

MN 
182 

IA 
85 

WI 
82 

MI 
42 

IL 
103 

IN 
34 

OH 
63 

KS 
31 

OK 
15 

TX 
740 

KY 
9 

TN 
44 

AL 
140 

MS 
25 

MO 
36 

AR 
37 

LA 
20 

ME 
4 

NY 
191 

9 

6 

5 

1 

8 

WV 
10 

PA 
324 

7 

4 

2 

3 

VA 
313 

NC 
352 

SC 
149 

GA 
302 

FL 
701 

1 

2 

3 

4 

5 

6 

7 

8 

9 

CT:  90 

DC :  40 

DE:  22 

MD:  121  

MA:  33 

NH:  6 

NJ:  336  

RI:  6 

VT:  7 

t

r

o

p

e

R

l

a

u

n

n

A

9

1

0

2

|

Argentina 

Australia 

Bahamas 

Bangladesh 

Brazil 

Canada 

Cayman Islands 

Chile 

China 

Colombia 

Israel 

Italy 

Dominican Republic 

Japan 

France 

Germany 

Hong Kong 

India 

Ireland 

Luxembourg 

Netherlands 

New Zealand 

Philippines 

Singapore 

South Korea 

Sweden 

Taiwan 

Thailand 

United Arab Emirates 

United Kingdom 

Vietnam 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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2

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WEL LS   FARGO & COMPANY

420  MONTGOMERY STREET | SAN FRA NC ISCO , CA  | 94104

1- 866-87 8-58 65  | WELLSFARGO.COM

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© 2020 Wells Fargo & Company.  All rights reserved.  
Deposit products offered through Wells Fargo Bank, N.A. Member FDIC. 
CCM3520  (Rev 00, 1/each)

Wells Fargo & Company

2019 Annual Report