Wells Fargo & Company 2021 Targeted 165(d) Resolution Plan
Wells Fargo & Company
2021 Targeted 165(d) Resolution Plan
Public Section
June 2021
Public Section
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Wells Fargo & Company
2021 Targeted 165(d) Resolution Plan
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Public Section
Forward-Looking Statements and Other Disclaimers
This document contains forward-looking statements about Wells Fargo & Company's future plans, objectives,
and resolution strategies, including its expectations, assumptions, and projections regarding the implementation
of those strategies and the effectiveness of the Company¡¯s resolution planning efforts.
Because forward-looking statements are based on the Company's current expectations and assumptions
regarding the future, they are subject to inherent risks and uncertainties. In addition, the resolution planning
process as a whole, and its expectations and projections regarding the implementation and effectiveness of the
Company¡¯s resolution strategies, are based on hypothetical scenarios and assumptions and may not reflect
events to which the Company is or may become subject. Accordingly, you should not unduly rely on forwardlooking statements as actual results could differ materially from expectations. Forward-looking statements
speak only as of the date made and the Company does not undertake to update them to reflect changes or events
that occur after that date. For more information about the Company and the factors that could cause actual
results to differ materially from the Company's expectations, refer to the ¡°Forward-Looking Statements¡±
discussion in Wells Fargo & Company¡¯s most recent Quarterly Report on Form 10-Q as well as to the Company¡¯s
other reports filed with the Securities and Exchange Commission, including the discussion under ¡°Risk Factors¡±
in the Company's Annual Report on Form 10-K for the year ended December 31, 2020, as filed with the
Securities and Exchange Commission and available on its website at .
The 2021 Targeted 165(d) Resolution Plan is based on many significant assumptions, including assumptions
about the actions of regulators and creditors, the state of the financial markets and the economy, and the impact
of a significant loss event on the Company and its subsidiaries. While the Company would expect to take the
actions described in this 2021 Targeted 165(d) Resolution Plan, some or all of these assumptions may prove to be
incorrect in an actual resolution situation. Therefore, the actions the Company would take in an actual
resolution situation may differ. The resolution strategies described in the 2021 Targeted 165(d) Resolution Plan
are not binding on a bankruptcy court, the Company¡¯s regulators, or any other resolution authority. The strategy
described in our 2021 Targeted 165(d) Resolution Plan is not binding in the event of an actual resolution of Wells
Fargo. Accordingly, the scenarios and assumptions underlying the 2021 Targeted 165(d) Resolution Plan reflect
events and circumstances that may not arise, and the impact of these events may be very different if they do
arise in circumstances other than those contemplated in the 2021 Targeted 165(d) Resolution Plan.
All financial data in this document is as of December 31, 2020, except where otherwise indicated.
Wells Fargo & Company
2021 Targeted 165(d) Resolution Plan
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Public Section
Table of Contents
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
Introduction.............................................................................................................................................................................................................
Company Overview................................................................................................................................................................................................
Core Business Lines................................................................................................................................................................................................
Material Entities.....................................................................................................................................................................................................
Company's Preferred Resolution Strategy........................................................................................................................................................
Resolution Focus Areas and Capabilities...........................................................................................................................................................
Resolution Planning Oversight............................................................................................................................................................................
Approach to Maintaining Financial Resiliency..................................................................................................................................................
Non-U.S. Operations..............................................................................................................................................................................................
Financial Information.............................................................................................................................................................................................
Identities of Principal Officers.............................................................................................................................................................................
Glossary....................................................................................................................................................................................................................
Wells Fargo & Company
2021 Targeted 165(d) Resolution Plan
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9
10
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58
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Public Section
1. Introduction
1
Wells Fargo & Company has a long-standing commitment to maintain our financial strength, serve our
customers through the best and worst economic times, and continually improve our resiliency. These
qualities are tested during difficult times and the past 18 months confirmed that. In the challenging and
evolving environment of a global pandemic, we remained steadfastly focused on stability. We maintained
strong capital and liquidity levels during these times and, as a result, served our customers¡¯ financial needs in
unique ways to help them remain resilient too. In addition, we demonstrated our strong operational resiliency
by continuing to serve customers while over 200,000 employees worked remotely. This Public Section
describes actions that we would anticipate taking, pursuant to our Resolution Plan, in the event of severe
financial stress to resolve the Company without extraordinary government support.
One of our financial resiliency goals is to maintain a strong capital position. We ended 2020 with a Common
Equity Tier 1 ratio of 11.6% under the Standardized Approach and 11.9% under the Advanced Approach,
which demonstrated improvements year over year as shown in the following figure. This ratio helps gauge our
ability to withstand stress.
Figure 1-1
Common Equity Tier 1 Ratio
11.9
11.4
11.1
10.7
4Q19
1Q20
11.0
11.1
2Q20
Standardized Approach
11.4
11.5
3Q20
11.6
11.9
4Q20
Advanced Approach
Another goal is to maintain a strong liquidity position. We currently maintain available liquid assets in excess
of our forecasted resolution liquidity execution need (RLEN) requirement and continually monitor financial
resources at each material entity against established triggers that could indicate deterioration of available
liquidity to facilitate timely management actions. From the first quarter of 2012, when financial institutions
began enhancing their liquidity position, to the first quarter of 2021, our liquid assets, as a percentage of total
assets, increased from approximately 15% to 35%. We ended 2020 with a higher liquidity coverage ratio than
1
Wells Fargo & Company including its subsidiaries is referred to as the ¡°Company,¡± ¡°Wells Fargo,¡± ¡°we,¡± ¡°our,¡± or ¡°us,¡± and, as a stand-alone entity, is
referred to as the ¡°Parent.¡±
Wells Fargo & Company
2021 Targeted 165(d) Resolution Plan
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