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Wells Fargo Bank, N.A.

Lender or loan platform

PPP
Type
Company or group
Role
Lender or loan platform
Programs
PPP
Updated

The profile

Wells Fargo published its PPP fees: about $420 million on 2020 loans, which it gave to community lenders and nonprofits, and about $270 million on 2021 loans, for which it pledged only "any net profits."

  • Type: National bank; PPP lender
  • Parent: Wells Fargo & Company

In the archive

Wells Fargo made 280,717 Paycheck Protection Program loans for $13.8 billion, in the SBA's loan file, with an average loan of $49,080, the smallest among the largest banks.1 It entered the program under a Federal Reserve cap on its total assets, said on April 5, 2020 that it had "reached its capacity of $10 billion to lend under the PPP," and had 1,004 loans approved when the first round's money ran out on April 16.21 Its own fee figures can be checked against the SBA data: its filings report "approximately $420 million" deferred on 2020 loans and "approximately $270 million" on the first half of 2021, and the loan-by-loan model gives $420.7 million and $269.4 million.341

The asset cap and the fees

A 2018 Federal Reserve consent order, issued after the fake-accounts scandal, held Wells Fargo's total assets at their 2017 level. The bank's April 5, 2020 release said it was "restricted in our ability to serve as many customers as we would like under the PPP" and promised that "fees generated through the program will be distributed as charitable grants to nonprofits that support small businesses."2 Chief executive Charlie Scharf was quoted in it.

Three days later the Fed amended its order. Wells Fargo could leave PPP loans out of the cap, but 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 Treasury or an approved small-business nonprofit.5 The pledge came first; the order made giving up the fees the price of the exception. No filing we read says how much of its PPP book Wells Fargo excluded.

The 2020 fees went out through the Open for Business Fund. The bank's January 2022 results presentation reported: "Fulfilled our ~$420 million commitment, which included grants to 235 CDFIs and nonprofits."6 For 2021 loans, the quarterly reports carried a narrower sentence: "We have committed to donate any net profits related to PPP loans funded in 2021."7 The 2021 annual report reports the 2020 commitment fulfilled and does not mention the 2021 one; we found no amount for it in any later filing. How Much Did Wells Fargo Make From Pandemic Relief? traces both pledges.

The Fed lifted the asset cap on June 3, 2025.8

Sued over the line and the fees

By June 2020 a plaintiff was asking the Judicial Panel on Multidistrict Litigation to combine eight putative class actions over the bank's PPP lending, most of them alleging that it moved bigger, better-paying loans to the front.9 The panel refused on August 5, 2020, finding in the borrower cases that "individualized factual issues concerning the circumstances of each loan application will significantly diminish the potential efficiencies from centralization."10 The cases ended in voluntary dismissals and arbitration. In Marselian v. Wells Fargo, the court granted the bank's motion to compel arbitration in January 2021 under the plaintiff's business account agreement.11 No court ruled on the order in which Wells Fargo processed applications. A House Select Subcommittee staff report, using the bank's data, found that it "processed single-employee applicants only three days slower than its largest applicants."12

Accountants who had helped borrowers apply sued for a share of the fee. T.C. Koziara, PLLC v. Wells Fargo was dropped on October 12, 2020, less than a month after the bank moved to dismiss.13 Wells Fargo was also one of seven lender defendants in American Video Duplicating v. Citigroup, where the court held that the CARES Act did not require lenders to pay agent fees absent an agreement.14 The Agents Got Nothing follows those suits.

Sources

Notes

  1. SBA PPP FOIA loan-level data, release of Sept. 30, 2024, loans with Wells Fargo Bank, National Association as originating lender, priced under 85 FR 20811, 86 FR 3692 and 86 FR 3712; see the lender page. Original: SBA PPP FOIA loan-level data (original: data.sba.gov · stored capture) ↩
  2. Wells Fargo, "Wells Fargo Receives Strong Interest in the Paycheck Protection Program (PPP)" (Apr. 5, 2020). Original: https://newsroom.wf.com/English/news-releases/news-release-details/2020/Wells-Fargo-Receives-Strong-Interest-in-the-Paycheck-Protection-Program-PPP/default.aspx ↩
  3. Wells Fargo & Company 2020 Annual Report (Exhibit 13 to Form 10-K). Original: https://www.sec.gov/Archives/edgar/data/72971/000007297121000197/wfc-20201231_d2.htm ↩
  4. Wells Fargo Form 10-Q for the quarter ended June 30, 2021. Original: https://www.sec.gov/Archives/edgar/data/72971/000007297121000267/wfc-20210630.htm ↩
  5. Federal Reserve, Amendment of Consent Order, Wells Fargo & Company, Docket No. 20-007-B-HC (Apr. 8, 2020), para. 5(d). Original: https://www.federalreserve.gov/newsevents/pressreleases/files/enf20200408a1.pdf ↩
  6. Wells Fargo 4Q21 financial results presentation (Jan. 14, 2022). Original: https://www.sec.gov/Archives/edgar/data/72971/000007297122000003/ex993-wellsfargo4q21pres.htm ↩
  7. Wells Fargo Form 10-Q for the quarter ended Mar. 31, 2021. Original: https://www.sec.gov/Archives/edgar/data/72971/000007297121000221/wfc-20210331.htm ↩
  8. Federal Reserve, announcement that Wells Fargo is no longer subject to the asset growth restriction (June 3, 2025). Original: https://www.federalreserve.gov/newsevents/pressreleases/enforcement20250603a.htm ↩
  9. Brief in support of motion for transfer and centralization, In re Wells Fargo PPP Litigation, MDL No. 2954 (J.P.M.L. June 9, 2020). ↩
  10. Order denying transfer, In re: Wells Fargo Paycheck Protection Program Litigation, MDL No. 2954 (J.P.M.L. Aug. 5, 2020); schedule of actions. ↩
  11. Order granting motion to compel arbitration, Marselian v. Wells Fargo & Co., No. 4:20-cv-03166-HSG (N.D. Cal.), Dkt. 37. Original: https://storage.courtlistener.com/recap/gov.uscourts.cand.359257/gov.uscourts.cand.359257.37.0.pdf ↩
  12. House Select Subcommittee on the Coronavirus Crisis, staff report, "Underserved and Unprotected" (Oct. 2020), p. 15. ↩
  13. Notice of voluntary dismissal, T.C. Koziara, PLLC v. Wells Fargo & Co., No. 1:20-cv-00588 (M.D.N.C. Oct. 12, 2020), Doc. 18; Wells Fargo's memorandum in support of its motion to dismiss (Sept. 15, 2020). ↩
  14. Order granting defendants' motions to dismiss, American Video Duplicating Inc. v. Citigroup Inc., No. 2:20-cv-03815-ODW (C.D. Cal. Nov. 16, 2020), Doc. 131. Original: https://storage.courtlistener.com/recap/gov.uscourts.cacd.780998/gov.uscourts.cacd.780998.131.0.pdf ↩
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