Page 23 - Wells Fargo Bank (C) Case Study

they reward improper behavior. Wells Fargo’s proxy says as

much. It noted that the human resources committee meets
each year with the company’s chief risk officer “to review

and assess any risks posed by our enterprise incentive

compensation programs,” the company said. (6, 12)

Only a relatively small portion of the compensation of Wells

Fargo’s executives can be clawed back. The bank’s claw-back

provisions are specific about the circumstances in which it
can recoup money from executives - most hinge on

misconduct that forces the company to significantly revise

its financial results or pay that was received based on

inaccurate financial information. Neither is the case here.

During Stumpf’s Senate testimony he also balked when

asked if the bank would claw back some of Tolstedt’s

compensation. (12)