The Office of the Comptroller of the Currency’s decade-long enforcement effort over Wells Fargo’s fake-accounts scandal produced more than $43 million in civil penalties from eleven former executives, plus hundreds of millions more against the bank itself. The final individual case closed on October 22, 2025, when the OCC settled with former community bank group risk officer Claudia Russ Anderson for zero dollars and dropped the lifetime industry ban it had spent years pursuing.1American Banker. OCC Settles Its Last Remaining Wells Fargo Case for $0
What the OCC Was Punishing
Beginning as early as 2002 and continuing through at least 2016, Wells Fargo’s cross-selling culture pushed employees to open roughly 1.5 million unauthorized deposit accounts and apply for about 565,000 credit cards without customers’ knowledge or consent.2Consumer Financial Protection Bureau. CFPB Fines Wells Fargo $100 Million for Widespread Illegal Practice of Secretly Opening Unauthorized Accounts The conduct became public in September 2016, when the CFPB, the OCC, and the City and County of Los Angeles announced a combined $185 million in penalties. CEO John Stumpf resigned the following month.
OCC Penalties Against the Bank
The OCC’s September 2016 consent order addressed the unauthorized accounts directly. In April 2018, the agency issued a broader cease-and-desist order with a $500 million civil penalty, reaching enterprise-wide compliance failures as well as unfair practices tied to collateral protection insurance on auto loans and mortgage rate-lock extension fees.3OCC. OCC Issues Cease and Desist Order and $500 Million Penalty Against Wells Fargo That order required Wells Fargo to overhaul its compliance program, seat an independent compliance committee, and get regulatory approval before naming senior executives or board members.4OCC. Wells Fargo Consent Order EA-2018-025
The OCC terminated that 2018 compliance order on February 13, 2025, after validating the bank’s corrective work.5Wells Fargo Newsroom. Wells Fargo Confirms Termination of 2018 OCC Compliance Consent Order6OCC. OCC Enters Into Formal Agreement With Wells Fargo Bank, N.A.7American Banker. Wells Fargo Exits Another Consent Order
Executives Who Settled Early
In January 2020, the OCC announced consent orders with three former members of the operating committee.
John Stumpf, the former chairman and CEO, paid a $17.5 million civil penalty and accepted a lifetime ban from banking. The OCC found that he failed to supervise the head of the Community Bank, ignored repeated complaints about sales pressure, and relied on internal assurances that the misconduct was isolated. He had already forfeited roughly $70 million in equity awards, bonuses, and salary before the consent order.8OCC. John Stumpf Consent Order EA-2020-004
Hope Hardison, the former chief administrative officer, paid $2.25 million.9American Banker. OCC Drops Hammer on Stumpf, Seven Other Ex-Wells Fargo Execs Michael Loughlin, the former chief risk officer, paid $1.25 million and accepted a cease-and-desist order; the OCC found that from 2010 to 2018 he failed to warn the CEO and board about the Community Bank’s sales-model risks and repeatedly rated its management of those risks as “satisfactory” in internal memos.10OCC. Michael Loughlin Consent Order EA-2020-003
The Executives Who Fought Back
On January 23, 2020, the OCC filed administrative charges against five executives who did not settle, seeking a combined $37.5 million in penalties.11OCC. OCC Charges Five Former Senior Executives of Wells Fargo
Carrie Tolstedt, the former head of the Community Bank, faced a proposed $25 million penalty and a lifetime industry ban. The OCC alleged she was “significantly responsible” for the misconduct. She settled in March 2023 for a $17 million penalty and a permanent prohibition order.12OCC. OCC Issues Prohibition Order and Penalty Against Carrie Tolstedt
James Strother, the former general counsel, was originally hit with a $5 million proposed penalty. He settled in January 2021 for $3.5 million and agreed to cooperate with ongoing federal investigations. The OCC alleged he had turned a “blind eye to rampant criminal and legal violations.”13Corporate Counsel. Ex-Wells Fargo General Counsel to Pay $3.5M Penalty for Role in Phony Account Scandal
That left Claudia Russ Anderson, former chief auditor David Julian, and former executive audit director Paul McLinko. All three refused to settle and went through a 38-day administrative hearing.
How the Last Three Cases Collapsed
On January 14, 2025, Acting Comptroller Michael Hsu issued final decisions imposing $18.5 million in combined penalties on the remaining executives: $10 million and a lifetime ban for Russ Anderson, $7 million and a cease-and-desist order for Julian, and $1.5 million and a cease-and-desist order for McLinko.14Banking Dive. OCC Fines Three Ex-Wells Fargo Execs $18.5 Million All three appealed to federal court, and the OCC’s numbers did not survive.
In April 2025, the agency entered consent orders with Julian and McLinko for a fraction of the amounts. Julian agreed to pay $100,000, down from $7 million. McLinko agreed to $50,000, down from $1.5 million. Both received personal cease-and-desist orders instead of industry bans, and both settled without admitting the OCC’s allegations or the administrative law judge’s findings.15OCC. OCC Enters Into Consent Orders With Former Wells Fargo Executives David Julian and Paul McLinko Julian’s order also required him to disclose it to any future banking employer.16Wolters Kluwer. Wells Fargo Former Auditors Enter Into OCC Consent Orders
The Russ Anderson settlement in October 2025 went further still: no penalty, and the lifetime ban dropped. The deal came as oral arguments approached in the Eighth Circuit, where her legal team was arguing that the OCC’s in-house proceedings denied her the protections of a federal courtroom, invoking the Supreme Court’s 2024 decision in SEC v. Jarkesy to claim entitlement to an Article III court and a jury trial.17Wolters Kluwer. Petitioner Brief, Anderson v. OCC, 8th Circuit She had also challenged the OCC’s decision to raise her proposed penalty from $5 million to $10 million during the proceedings. Her attorneys said the OCC “finally understood their case never had merit” once federal court review loomed.1American Banker. OCC Settles Its Last Remaining Wells Fargo Case for $0 The OCC noted that millions in compensation had already been clawed back from her. She was 67 and said she had retired, so the lifted ban was largely symbolic.18Banking Dive. OCC Drops Fine in Wells Fake Accounts Settlement With Claudia Russ Anderson
Individual Penalties at a Glance
All penalties were paid to the U.S. Treasury.
- John Stumpf: $17.5 million, lifetime industry ban
- Carrie Tolstedt: $17 million, lifetime industry ban
- James Strother: $3.5 million
- Hope Hardison: $2.25 million
- Michael Loughlin: $1.25 million, cease-and-desist
- David Julian: $100,000 (reduced from $7 million), cease-and-desist
- Paul McLinko: $50,000 (reduced from $1.5 million), cease-and-desist
- Claudia Russ Anderson: $0 (reduced from $10 million), no ban
The identities and penalties of the remaining three executives who make up the total of eleven are not detailed in available OCC records.15OCC. OCC Enters Into Consent Orders With Former Wells Fargo Executives David Julian and Paul McLinko
Criminal Charges and Parallel Regulatory Actions
The OCC’s civil penalties were not the only consequence. Tolstedt was the only former executive to face criminal charges, pleading guilty to one count of obstructing a bank examination over a 2015 memo that understated the number of employees fired or resigned for sales misconduct.19Courthouse News Service. Sole Wells Fargo Executive Charged in Cross-Selling Scandal Dodges Prison Time In September 2023, U.S. District Judge Josephine Staton sentenced her to three years of probation with six months of home confinement, a $100,000 fine, and 120 hours of community service, rejecting prosecutors’ request for a 12-month prison term.20Banking Dive. Wells Fargo’s Carrie Tolstedt Sentenced to Probation, Avoids Prison
At the bank level, Wells Fargo agreed in February 2020 to pay $3 billion under a three-year deferred prosecution agreement resolving federal criminal and civil investigations into the fake-accounts practices, and admitted responsibility for the conduct.21ABC News. Wells Fargo Agrees to $3 Billion Settlement Over Fake Accounts In December 2022, the CFPB ordered the bank to pay $3.7 billion over mismanagement of auto loans, mortgages, and deposit accounts, including a $1.7 billion civil penalty and more than $2 billion in refunds to over 16 million consumer accounts.22Consumer Financial Protection Bureau. CFPB Orders Wells Fargo to Pay $3.7 Billion
Where Wells Fargo Stands Now
The Federal Reserve’s February 2018 asset cap, which held Wells Fargo’s total assets at $1.95 trillion and cost the bank an estimated $36 billion in forgone profits over its seven-year run, was lifted in June 2025. The Fed terminated the underlying 2018 enforcement action on March 5, 2026, after two required third-party reviews confirmed the bank’s governance and risk-management improvements.23Federal Reserve. Federal Reserve Board Terminates Enforcement Action Against Wells Fargo24Banking Dive. OCC Terminates 2021 Wells Fargo Consent Order Since CEO Charlie Scharf took over in 2019, the bank has resolved twelve consent orders, six of them in 2025 alone.25Banking Dive. Wells Fargo Clears 12th Consent Order, 2 Remain Two OCC orders still hang over the bank: the 2024 anti-money laundering formal agreement and the 2015 Gramm-Leach-Bliley consent order.