DOWNGRADE SHOULD REFLECT HARM CAUSED BY THE BANK, BUT BANK SHOULD NOT BE
ALLOWED TO APPEAL BEHIND CLOSED DOORS

San Francisco, CA, Dec. 7, 2016— Earlier today, Reuters reported that the Office of the Comptroller of the
Currency (OCC), the primary regulator of Wells Fargo Bank, is set to award a double-downgrade to Wells Fargo
on its Community Reinvestment Act (CRA) rating.

According to the Reuters report, the OCC is expected to announce a “Needs to Improve” rating for Wells Fargo
in January of next year. The rating is considered a “double downgrade” because Wells Fargo’s previous CRA
rating was “Outstanding.” There are four possible CRA grades a bank can be awarded: Outstanding;
Satisfactory; Needs to Improve; and Substantial Noncompliance.
Paulina Gonzalez, executive director of the California Reinvestment Coalition, responded with this
statement today:
“Given the long and growing list of enforcement actions against Wells Fargo for harmful and illegal practices,
we expected at least a double downgrade and wouldn’t have been surprised if regulators were planning to award
the lowest CRA rating of “Substantial Noncompliance.”
The bank has admitted to harming homeowners, student loan borrowers, service members, and other consumers,
and it’s appropriate that their new CRA rating reflects the impact of the bank’s practices against its own
customers and the damage it has created in communities across the nation. Worse, it continues to insist on
customers using forced arbitration to settle these problems- even for the fake accounts it created.
Tim Sloan, an insider at the bank, was at a conference yesterday, and had the audacity to suggest that the
banking industry needs fewer regulations under President-Elect Donald Trump. We can’t think of a worse
messenger for the idea that Too Big To Fail Banks need looser rules than the CEO of a bank who has broken so
many rules and engaged in widespread fraud against its own customers.
We are also deeply troubled by the nearly four year delay by the OCC in awarding Wells a new CRA rating after
its 2012 exam. Would the bank have engaged in so many harmful activities if regulators had awarded this
“Needs To Improve” in a more timely manner?
Perhaps most concerning is the suggestion that the bank may have attempted to appeal this long-delayed rating.
The public weighed in on Wells’ CRA exam back in 2012, with an unprecedented number of individuals and
organizations urging the OCC to downgrade the bank for its many harmful practices, including steering
borrowers into more expensive mortgages, illegal mortgage servicing and foreclosing practices, and its notorious
“direct deposit advance” loan product that was nothing more than a payday loan with Wells Fargo’s logo
stamped on it.
The public is angry at Wells Fargo over the widespread identity theft scandal, and the punishment of lower level
employees while senior executives escaped with golden parachutes. We can’t imagine how angry people would
be if they learned that Wells Fargo was trying to get a “do-over” in its CRA grade after the damage it has caused
to consumers and communities.
The OCC recently informed the bank that it is limiting Wells’ power to give out golden parachutes and to make
board or senior executive level appointments, which is good. However, it’s important to note that those
prohibitions were put in place after Tim Sloan, a 30-year insider, was appointed to the CEO position (without
input from the OCC, as far as we can tell).”