How Much Did Wells Fargo Make From Pandemic Relief?

I. Two numbers, and the bank's own

Most lenders never said what the PPP paid them, so the answer has to be modeled, as it was for Womply's fees. Wells Fargo said, twice, and the model can be checked against it.

Question	Figure	Source	Kind
What did the SBA owe Wells on its 2020 loans?	$420.7 million on 193,018 loans	SBA loan-level data, priced loan by loan	modeled
What did Wells say it booked on them?	"approximately $420 million" of processing fees	Wells Fargo 2020 Annual Report (Exhibit 13 to Form 10-K, filed Feb. 23, 2021)	company filing
What did the SBA owe Wells on its 2021 loans?	$269.4 million on 87,699 loans	SBA loan-level data, priced loan by loan	modeled
What did Wells say it booked on them?	"approximately $270 million"	Form 10-Q for the quarter ended June 30, 2021	company filing
How much did Wells give away?	about $420 million, the 2020 fees, paid out by the end of 2021	2021 Annual Report (Exhibit 13 to Form 10-K, filed Feb. 22, 2022)	company filing
What happened to the 2021 fees?	a pledge of "any net profits"; no amount reported	Forms 10-Q for the first three quarters of 2021	company filing; outcome not public

The two modeled halves add to $690.1 million, the eighth-largest fee total among the 4,688 lenders in the SBA file (PPP lenders by estimated fees). The series ranking of fee collectors adds agents and contractors and ranks each on its fees after documented payments to agents, using a collector's own fee figures where its filings give them. Wells is ranked on its two filed figures, about $690 million together, and is sixth, behind Womply (ranked on its billings and covered in its own piece), JPMorgan Chase, Bank of America, Blueacorn and Cross River Bank. Both the filed and the modeled figures are fees before the cost of the staff and systems that processed the loans, which no Wells filing we read discloses. They leave out the 1 percent interest the loans paid while they were outstanding, which the 2020 pledge did not cover.

II. Who paid Wells, and for what

The SBA paid the lender of record a processing fee on every PPP loan and guaranteed the loan in full. For 2020 loans the fee was 5 percent of loans up to $350,000, 3 percent up to $2 million and 1 percent above that (85 FR 20811). For 2021 loans of $50,000 or less, the fee became the lesser of 50 percent of the loan or $2,500 (86 FR 3692; 86 FR 3712).

Say a florist borrowed $20,000 from Wells in May 2020. The SBA paid Wells $1,000. Had she borrowed the same $20,000 in February 2021, the SBA would have paid $2,500.

Wells made small loans. Its PPP loans averaged $49,080; JPMorgan Chase's averaged about $94,700 and Bank of America's about $70,100 (PPP per-lender totals). Four in five Wells loans (79.5 percent) were for $50,000 or less. A small-loan book under a schedule that paid the highest rate on small loans came to 5.0 cents in modeled fees per dollar lent. On the same model, JPMorgan's came to 4.1 cents and Bank of America's to 4.3. Among the 15 largest PPP lenders by dollars, only Cross River Bank and Harvest Small Business Finance came out higher.

The split by size shows where the money came from:

Wells loans by size	Loans	Share of loans	Modeled fees	Share of fees
$50,000 or less	223,058	79.5%	$293.1M	42.5%
$50,000 to $350,000	52,857	18.8%	$294.2M	42.6%
$350,000 to $2 million	4,471	1.6%	$89.5M	13.0%
$2 million and up	331	0.1%	$13.3M	1.9%

The 2021 rule raised the rate. Wells's 2020 loans paid about $2,180 each, 4.1 cents per dollar. Its 2021 loans paid about $3,070 each, 7.7 cents per dollar (Wells Fargo lender page; fee schedules by vintage).

We found no record of Wells sharing these fees with an agent or a referral platform. The SBA's rule let a lender pay part of its fee to an agent who helped a borrower apply, and agents sued Wells for a share. The North Carolina case, T.C. Koziara, PLLC v. Wells Fargo, was dropped on October 12, 2020, less than a month after Wells moved to dismiss (notice of voluntary dismissal). In California, American Video Duplicating named Wells with six other lenders. The court held on November 16, 2020 that the CARES Act "does not provide a private cause of action to recover agent fees absent an agreement between agent and lender" (order). The order noted that it "appears every court that has decided this issue has held" the same (The Agents Got Nothing). The plaintiffs dismissed the case with prejudice on February 2, 2021 (stipulation).

III. The asset cap: $10 billion, then an exception with a price

Wells entered the program under a Federal Reserve order. After the fake-accounts scandal, a 2018 consent order held the company's total assets at their level of December 31, 2017, measured on a two-quarter daily average (2020 Annual Report). CNBC put the cap at $1.95 trillion (CNBC, April 8, 2020).

On Sunday, April 5, 2020, two days after small businesses could first apply, Wells announced the result. "Intake from customers indicates Wells Fargo has reached its capacity of $10 billion to lend under the PPP," its release said, and the bank would focus on nonprofits and businesses with fewer than 50 employees. Charlie Scharf, six months into the chief executive's job, said the company was "restricted in our ability to serve as many customers as we would like under the PPP." The same release made the pledge: "fees generated through the program will be distributed as charitable grants to nonprofits that support small businesses" (Wells Fargo, "Wells Fargo Receives Strong Interest in the Paycheck Protection Program (PPP)," April 5, 2020).

Three days later the Fed amended its order. Wells could leave PPP loans out of the cap. In any quarter it did, it "shall transfer the processing fees or similar remuneration for inducing participation in the Program derived from such excluded loans … to the U.S. Treasury or a non-profit organization that provides support to small businesses acceptable to the Reserve Bank," in cash, within 45 days of the quarter's end. Scharf signed the amendment for the company (Federal Reserve, Amendment of Consent Order, Docket No. 20-007-B-HC, April 8, 2020, para. 5(d)). The pledge came first, by three days; the order then made giving up the fees the price of the exception. Wells's annual report describes the condition as applying "to the extent the Company chooses to exclude these exposures from the asset cap." No filing we read says how much of its PPP book Wells excluded.

The first round ran out of money on April 16. By then the SBA had approved 1,004 Wells Fargo loans that are still in its loan file, for $100.2 million. JPMorgan Chase had 25,993 approved, for $12.0 billion, and Bank of America 9,056, for $3.6 billion (SBA loan-level data, our count). Four economists who studied the rollout singled Wells out: "its share of PPP lending in the first round was just a small fraction of its share of small business lending" (Granja, Makridis, Yannelis and Zwick, Journal of Financial Economics, 2022, pp. 734–735).

Wells made nearly all of its 2020 loans after the program reopened on April 27 with new money (Granja et al.). By the end of 2020 it reported $10.5 billion funded to about 194,000 borrowers (2020 Annual Report). The SBA file shows 193,018 loans approved in 2020 for $10.3 billion. The bank that announced a $10 billion capacity on April 5 finished the year $500 million above it. Wells's 2020 loans were 3.8 percent of the program's 2020 loans and 2.0 percent of its 2020 dollars. Over both years Wells made 2.4 percent of all PPP loans (lender page). A 2022 Wells press release said the bank served "more than 10% of small businesses in the U.S." (Business Wire, April 19, 2022).

The Fed removed the asset cap on June 3, 2025 (Federal Reserve).

IV. Where the $420 million went

The pledge got narrower in writing as it went. In April 2020 it covered "fees generated through the program." The June 2020 quarterly report covered "the gross processing fees received from funding PPP loans." The 2020 annual report covered "all of the gross processing fees received in 2020 from funding PPP loans." From the first quarter of 2021, loans made that year were covered by a different sentence: "We have committed to donate any net profits related to PPP loans funded in 2021" (Form 10-Q, March 31, 2021).

Wells booked the 2020 fees over time. It deferred them and recognized them "as interest income over the term of the loans," and it donated them "as the fees are recognized in earnings" (Form 10-Q, June 30, 2020). Each dollar therefore appeared twice in the income statement, once as interest income and once, in the other expenses line, as "higher charitable donations expense driven by the donation of PPP processing fees" (2020 Annual Report). The filings track the pace:

Through	Fees Wells had deferred on 2020 loans	Donated to date	Source
June 30, 2020	$397 million	none	Form 10-Q, Q2 2020
Sept. 30, 2020	$417 million	$51 million	Form 10-Q, Q3 2020
Dec. 31, 2020	about $420 million	about $85 million	2020 Annual Report
Mar. 31, 2021		about $125 million	Form 10-Q, Q1 2021
June 30, 2021		about $260 million	Form 10-Q, Q2 2021
Sept. 30, 2021		$305 million	3Q21 results presentation
Dec. 31, 2021		about $420 million, "fulfilled"	2021 Annual Report

The money went out through the Open for Business Fund, announced on July 9, 2020 as "an approximately $400 million effort." Its first $28 million went to community development financial institutions (CDFIs). Its first named grantees were the Expanding Black Business Credit Initiative, for a Black Vision Fund, and the Local Initiatives Support Corporation, which said it would reach more than 2,800 entrepreneurs (Wells Fargo, "Wells Fargo Launches $400 Million Small Business Recovery Effort," July 9, 2020). By March 2021, more than $125 million had gone to 75 CDFIs. By September 2021 the total was $305 million to 215 CDFIs, and $55 million of it had gone to 93 nonprofits that advise small businesses. The January 2022 results presentation reported the commitment "fulfilled," with grants to "235 CDFIs and nonprofits," including $20 million in Charlotte. The same slide said Wells expected "to make remaining grant announcements in 1Q22" (Wells Fargo 1Q21, 3Q21 and 4Q21 results presentations). The grantees then lent, granted or advised. We found no grant-by-grant list with amounts.

The count of what the fund achieved kept growing after the money stopped. Every figure below is Wells's own; the later ones, it says, come from its grantees:

Published	Document	Small businesses	Jobs	Wells's verb
Jan. 2021	4Q20 results presentation		roughly 50,000	"helping … keep"
Apr. 2021	1Q21 results presentation	22,800 owners	more than 66,000	"projected"
July 2021	2Q21 results presentation	41,000 owners	more than 117,000	"projected"
Oct. 2021	3Q21 results presentation	nearly 150,000	more than 250,000	"estimated"
Jan. 2022	4Q21 results presentation	nearly 152,000	more than 255,000	"estimated"
Jan. 2024	4Q23 results presentation	203,000	254,000	"keep or create"
July 2024	impact release	more than 336,000	more than 461,000	"grantees report"

The 2024 release added that grantees reported "more than $1.4 billion in equity grants, low-cost loan products, loan deferrals, modifications, and forgiveness" and "a 7:1 leverage of Wells Fargo funding." Its count of recipients was "over 200 nonprofits" (Wells Fargo, "Wells Fargo Shares Economic Impact from Open for Business Fund," July 24, 2024). None of these figures has been audited in any document we found.

V. The other $270 million

The 2021 fees came with the smaller promise. The June 2021 quarterly report said Wells had funded about $3.5 billion of PPP loans in the first half of the year and deferred "approximately $270 million of related SBA processing fees." It had "committed to donate any net profits from processing fees received from PPP loans funded in 2021." The September 2021 report repeated both pledges side by side.

The 2021 annual report, filed in February 2022, reports the 2020 commitment fulfilled and does not mention the 2021 one. Neither do the three 2022 quarterly reports, the 2022 annual report or the 2022 proxy statement. None says what Wells counted as costs, what net profit it found, or whether it gave any away.

Under the Fed's order, had Wells excluded its 2021 PPP loans from the asset cap, it would have owed the processing fees on them, which is more than net profit. A net-profit pledge fits a bank that kept its 2021 loans inside the cap; the filings do not say which it did. A Wells statement of its 2021 PPP costs and donations, or the Federal Reserve Bank of San Francisco's record of transfers under paragraph 5(d), would settle it.

VI. The queue suits: eight cases, no ruling on the queue

Wells was sued over the order it worked in. On April 19, 2020, plaintiffs filed class actions in the Central District of California against Wells, JPMorgan, Bank of America and U.S. Bank, alleging that each bank "concealed from the public that it was reshuffling the PPP applications it received and prioritizing the applications that would make the bank the most money" (the complaints, as Banking Dive reported them on April 21, 2020). The fee schedule supplied the motive the complaints alleged: $17,500 for a $350,000 loan, $100,000 for a $10 million one. Wells had written to waiting customers on April 10. As the San Francisco Business Journal reported it and Banking Dive quoted it: "While you remain in queue based upon when you submitted your initial interest, due to high demand we are not able to begin your application at this time."

By June 9 there were eight putative class actions in six districts, and one plaintiff asked the Judicial Panel on Multidistrict Litigation to combine them as MDL No. 2954 (brief; schedule of actions). One of the eight turned out to be an agent-fee case, and two were dropped before the panel ruled. On August 5, 2020 the panel refused, finding that "individualized factual issues concerning the circumstances of each loan application will significantly diminish the potential efficiencies from centralization"; some plaintiffs, it noted, had received PPP loans through Wells Fargo (order denying transfer).

Then the cases ended. In four of the seven, arbitration was moved for or compelled:

Case	Court	End
Scherer v. Wells Fargo Bank	S.D. Tex.	voluntarily dismissed between June 9 and Aug. 5, 2020
BSJA, Inc. v. Wells Fargo	C.D. Cal.	voluntarily dismissed between June 9 and Aug. 5, 2020
Physical Therapy Specialists v. Wells Fargo Bank	D. Colo.	joint motion to stay for arbitration, Aug. 18, 2020; voluntarily dismissed Aug. 31, 2020
Ma v. Wells Fargo & Co. (securities suit against the company, Scharf and his finance chief)	N.D. Cal.	dismissed without prejudice by stipulation, Nov. 12, 2020
DNM Contracting v. Wells Fargo Bank	S.D. Tex.	Wells's motion to compel arbitration and dismiss granted, Dec. 18, 2020
Karen's Custom Grooming v. Wells Fargo & Co.	S.D. Cal.	dismissed without prejudice on a joint motion, Jan. 15, 2021; Wells's arbitration motion denied as moot
Marselian v. Wells Fargo & Co.	N.D. Cal.	arbitration compelled, Jan. 20, 2021; dismissed with prejudice by stipulation, May 20, 2021

The Marselian complaint alleged that Wells "prioritize[d] loan applications from larger companies seeking higher loan amounts" to "maximize" its fees, after saying it would focus on "nonprofits and businesses with fewer than 50 employees." Judge Gilliam did not reach that. He sent the dispute to arbitration under the Business Account Application the plaintiff had signed when he opened his business account: "The Customer's use of any Wells Fargo Bank, N.A. ('Bank') deposit account, product or service will confirm the Customer's receipt of, and agreement to be bound by, the Bank's applicable . . . account agreement that includes the Arbitration Agreement" (Order Granting Motion to Compel Arbitration, N.D. Cal. No. 4:20-cv-03166, Jan. 20, 2021). Whether a federal emergency loan application fell under the account's arbitration clause was, the court held, for the arbitrator to decide. No court ruled on whether Wells processed applications in order. Borrower suits against other banks ended in arbitration or on the statute.

Two records speak to the allegation anyway. A House Select Subcommittee staff report in October 2020 used the banks' own loan data. It found that Wells "processed single-employee applicants only three days slower than its largest applicants," and that Wells and Bank of America processed by line of business "without substantial timing discrepancies." At JPMorgan the same report found wholesale clients funded in 3.1 days on average and business-banking clients in 14.9 ("Underserved and Unprotected," pp. 14–16). In the SBA file, Wells's round-one approvals leaned toward larger loans, slightly. Of its 2020 loans between $350,000 and $2 million, 1.4 percent were approved by April 16; of those of $50,000 or less, 0.4 percent. At JPMorgan the figures were 47 percent and 4 percent. Program-wide they were 69 percent and 21 percent.

VII. What Wells said

"Industry-leading commitment to donate all gross processing fees" (July 9, 2020). That month Banking Dive called Wells "the only bank of its size to donate gross processing fees — not just the net profit, the portion exceeding costs." For its 2021 loans, Wells pledged the net profit.

"Voluntarily committed" (the 2020 and 2021 annual reports and the 2021 quarterly reports). The April 5 pledge came before the Fed's April 8 amendment. The same annual reports carry the Fed's condition too, in the passage on the consent order, apart from the pledge under the COVID-19 heading.

"Average loan size of $50,000, the lowest among all large financial institutions" (2Q21 results presentation). The SBA file gives $49,080, and the claim holds against the other big banks: JPMorgan Chase's loans averaged about $94,700 and Bank of America's about $70,100. Two of the 15 largest PPP lenders by dollars averaged less: Cross River Bank, at $26,928, and Harvest Small Business Finance, at $20,057.

"Restricted in our ability to serve as many customers as we would like" (Scharf, April 5, 2020). By the end of round one, 1,004 of its loans had been approved.

"We took the gross processing fees the government paid us for administering the Paycheck Protection Program in 2020 and committed all of it to a roughly $420 million fund" (Scharf, July 24, 2024). The sentence is accurate. It covers 193,018 of the bank's 280,717 PPP loans.

Method, and what would change the numbers

Modeled fees. Each loan in the SBA's PPP loan-level file (release of September 30, 2024) is priced under the fee rule for its approval date and draw; loans are counted by approval year. The model assumes the SBA paid a fee on every loan in the file. Fees on loans later cancelled or reduced may not have been paid in full, so the modeled figures are fees owed, not received. For Wells the model can be tested: it gives $420.7 million for 2020 against the bank's "approximately $420 million," and $269.4 million for 2021 against "approximately $270 million."

Round-one counts. Loans approved from April 3 through April 16, 2020, by the SBA's approval date, among loans still in the September 2024 file. Loans cancelled before then are not in the file, so these counts are a floor.

Documented figures. Every deferral, donation and pledge figure is quoted from Wells Fargo's SEC filings and results presentations for 2020 through 2023, and from its press releases of April 5 and July 9, 2020 and July 24, 2024. The fund's business and job counts are Wells's figures from its grantees.

What is not public. Wells's cost of processing its PPP loans; how much of its PPP book it excluded from the asset cap, quarter by quarter; the result of the 2021 net-profit pledge; and a grant-by-grant list of the Open for Business Fund.

Sources: SBA PPP loan-level data (Sept. 30, 2024), priced under 85 FR 20811, 86 FR 3692 and 86 FR 3712 (Wells Fargo lender page; PPP lenders by estimated fees; PPP per-lender totals); Wells Fargo & Company Forms 10-Q for the quarters ended June 30 and Sept. 30, 2020, March 31, June 30 and Sept. 30, 2021 and March 31, June 30 and Sept. 30, 2022; 2020, 2021 and 2022 Annual Reports (Exhibit 13 to Form 10-K); proxy statements filed March 16, 2021 and March 14, 2022; 2Q20 quarterly supplement and 4Q20, 1Q21, 2Q21, 3Q21, 4Q21 and 4Q23 results presentations (Form 8-K exhibits); Federal Reserve Board press release and Amendment of Consent Order, Docket No. 20-007-B-HC (April 8, 2020); Federal Reserve, June 3, 2025; CNBC, April 8, 2020; Wells Fargo press releases of April 5, 2020, July 9, 2020, April 19, 2022 (Business Wire) and July 24, 2024; Banking Dive (April 21 and July 9, 2020); House Select Subcommittee on the Coronavirus Crisis, "Underserved and Unprotected" (October 2020); Granja, Makridis, Yannelis and Zwick, "Did the Paycheck Protection Program Hit the Target?", Journal of Financial Economics 145 (2022); In re Wells Fargo Paycheck Protection Program Litigation, MDL No. 2954 (brief, schedule of actions, order denying transfer); Marselian v. Wells Fargo & Co., N.D. Cal. No. 4:20-cv-03166, Dkt. 37 (Jan. 20, 2021) and Dkt. 38 (May 20, 2021); Karen's Custom Grooming, LLC v. Wells Fargo & Co., S.D. Cal. No. 3:20-cv-00956, Dkt. 26 (Jan. 15, 2021); Ma v. Wells Fargo & Co., N.D. Cal. No. 3:20-cv-03697, Dkt. 34 (Nov. 12, 2020) (complaint and docket); DNM Contracting, Inc. v. Wells Fargo Bank, N.A., S.D. Tex. No. 4:20-cv-01790, Dkt. 25 (Dec. 18, 2020); Physical Therapy Specialists, P.C. v. Wells Fargo Bank, N.A., D. Colo. No. 1:20-cv-01190, Dkts. 33, 35 and 36 (Aug. 2020); T.C. Koziara, PLLC v. Wells Fargo & Co., M.D.N.C. No. 1:20-cv-00588; American Video Duplicating, Inc. v. Citibank, N.A., C.D. Cal. No. 2:20-cv-03815 (order, stipulation). Related: How Much Did Womply Make From Pandemic Relief?