⚠ The Regulators Have Not LeftModerate threat

Wells Fargo (WFC) — threat to the moat

Wells Fargo's asset cap is gone, but the order that imposed it and a 2024 money-laundering agreement are still open.

The lifting of the asset cap did not end Wells Fargo's regulatory supervision. Its 2025 annual report says the bank is still subject to a February 2018 consent order with the Federal Reserve on the board's oversight of the company and its risk management, and to "a September 2024 formal agreement with the OCC" on anti-money-laundering and sanctions practices1.

Regulatory actions still openFeb 2018FRB consentorder, board andrisk managementSep 2024OCC formal agreement,AML and sanctionsJun 2025asset cap removed,order staysEarly 2026fourteenth orderterminatedWells Fargo Form 10-K FY2025; Federal Reserve June 2025; 2026 proxy
Two actions remain after fourteen were closed.

The bank spells out what that costs. Complying with those actions may continue to increase its costs and "reallocate resources away from growing its existing businesses"2. It also warns that regulators "have indicated the potential for escalating consequences" for banks with repeat issues3.

The record is improving. The bank's proxy counts "the termination of 14 consent orders", the latest in early 20264.

This threat is not to the deposit franchise, which held through the worst of it. It is to the cost base and to the freedom to grow, the two things the bank most needs.

The bank's warnings are specific. It says regulators could impose "additional consent orders, regulatory agreements or civil money penalties" if issues are not resolved5. And it says it could "continue to become subject to consent orders and settlement agreements" over mortgage servicing6, one reason it plans to service fewer mortgages.

The remaining open action on anti-money-laundering dates from 12 September 2024, when the bank announced that Wells Fargo Bank entered into a formal agreement with the currency comptroller7. It is an agreement, not a consent order, but it covers the kind of control failure that regulators punish hardest.

The cost of compliance shows up in total expense. The bank expects about $55.7 billion of noninterest expense in 20268, and it spent $27,991 million in the first half9. A full-year figure well above the guidance, with no matching revenue, would suggest the remaining orders were still consuming the bank.

The number that tests this threat
Moat Explorer calc
Noninterest expense, first half
$27,991M (H1 2026), about 50.3% of the ~$55.7bn full-year guide

The cost base the orders help set; running well above the guide without revenue growth would mean compliance was still consuming the bank.

How it's calculated: Q1 2026 noninterest expense 14,330 plus Q2 2026 13,661 (Q2 2026 release), divided by the ~$55.7bn 2026 guidance in the Q2 2026 presentation.
Source: Moat Explorer calculation from Wells Fargo filings ↗
References
  1. ReportedIts 2025 annual report says the bank is still subject to a February 2018 consent order with the Federal Reserve on the board's oversight of the company and its risk management, and to "a September 2024 formal agreement with the OCC" on anti-money-laundering and sanctions practices.
    Wells Fargo 2025 Annual Report to Shareholders (financial statements, MD&A and segment note), part of the Form 10-K for fiscal 2025 - Item 1A risk factors and regulatory matters. — FY2025 · publ. 24 February 2026 · source ↗
  2. ReportedComplying with those actions may continue to increase its costs and "reallocate resources away from growing its existing businesses".
    Wells Fargo 2025 Annual Report to Shareholders (financial statements, MD&A and segment note), part of the Form 10-K for fiscal 2025 - Item 1A risk factors and regulatory matters. — FY2025 · publ. 24 February 2026 · source ↗
  3. ReportedIt also warns that regulators "have indicated the potential for escalating consequences" for banks with repeat issues.
    Wells Fargo 2025 Annual Report to Shareholders (financial statements, MD&A and segment note), part of the Form 10-K for fiscal 2025 - Item 1A risk factors and regulatory matters. — FY2025 · publ. 24 February 2026 · source ↗
  4. ReportedThe bank's proxy counts "the termination of 14 consent orders", the latest in early 2026.
    Wells Fargo 2026 proxy statement (DEF 14A) - the chief executive's tenure and special award, and the termination of 14 consent orders. — 2026 · publ. 18 March 2026 · source ↗
  5. ReportedIt says regulators could impose "additional consent orders, regulatory agreements or civil money penalties" if issues are not resolved.
    Wells Fargo 2025 Annual Report to Shareholders (financial statements, MD&A and segment note), part of the Form 10-K for fiscal 2025 - Item 1A risk factors and regulatory matters. — FY2025 · publ. 24 February 2026 · source ↗
  6. ReportedAnd it says it could "continue to become subject to consent orders and settlement agreements" over mortgage servicing, one reason it plans to service fewer mortgages.
    Wells Fargo 2025 Annual Report to Shareholders (financial statements, MD&A and segment note), part of the Form 10-K for fiscal 2025 - Item 1A risk factors and regulatory matters. — FY2025 · publ. 24 February 2026 · source ↗
  7. ReportedThe remaining open action on anti-money-laundering dates from 12 September 2024, when the bank announced that Wells Fargo Bank entered into a formal agreement with the currency comptroller.
    Wells Fargo Form 10-K for fiscal 2025 - cover page and Item 1 business: legal form, employees, open regulatory actions. — FY2025 · publ. 24 February 2026 · source ↗
  8. ReportedThe bank expects about $55.7 billion of noninterest expense in 2026, and it spent $27,991 million in the first half.
    Wells Fargo second-quarter 2026 earnings presentation, Form 8-K exhibit 99.3 - segment returns, deposit cost, market shares and the 2026 outlook - the 2026 outlook, deposit cost and loan yield. — Q2 2026 · publ. 14 July 2026 · source ↗
  9. Moat Explorer calcThe bank expects about $55.7 billion of noninterest expense in 2026, and it spent $27,991 million in the first half.
    Moat Explorer calculation from Wells Fargo's reported figures ($ millions unless stated). Deposits: cost of total deposits = interest on interest-bearing deposits / (average interest-bearing + average noninterest-bearing deposits): 2020 2,804 / 1,376,011 = 0.20%; 2021 388 / 1,437,812 = 0.03%; 2022 2,349 / 1,424,269 = 0.16%; 2023 16,503 / 1,346,282 = 1.23%; 2024 24,282 / 1,345,915 = 1.80%; 2025 20,449 / (987,198 + 360,047 = 1,347,245) = 1.52%. Bank of America 2025: 34,513 / (1,469,705 + 514,477 = 1,984,182) = 1.74%. Gap to JPMorgan 1.80% - 1.52% = 0.28 points x 1,347,245 = about 3,772 (about $3.8 billion); gap to Bank of America 1.74% - 1.52% = 0.22 points. Noninterest-bearing share of average deposits: 2020 412,669 / 1,376,011 = 30.0%; 2021 499,644 / 1,437,812 = 34.8%; 2022 505,770 / 1,424,269 = 35.5%; 2023 399,737 / 1,346,282 = 29.7%; 2024 352,379 / 1,345,915 = 26.2%; 2025 360,047 / 1,347,245 = 26.7%. Average deposits 2023-2025 range 1,345,915 to 1,347,245 = 1,330 (about $1.3 billion). Period-end deposits 1,371,804 / 1,335,991 - 1 = 2.7% (Dec 2017 to Dec 2024); Dec 2025 to Jun 2026 1,501,405 - 1,426,207 = 75,198 (about $75 billion). Consumer Banking and Lending share of average deposits Q2 2026 828.4 / 1,465.6 = 57%. Held-to-maturity: Dec 2024 carrying 234,948 - fair value 193,779 = 41,169 unrealised loss; June 2026 loss 32,408 / common equity 165,000 = 19.6%. Balance sheet: total assets 2,282,201 / 1,951,757 - 1 = 16.9% above the 2017 cap level; 2,282,201 - 1,929,845 = 352,356 (about $352 billion); 2,282,201 / 1,929,845 - 1 = 18.3% (about 18%). CIB total assets 862,472 / 597,278 - 1 = 44%. Average loans Q2 2026 1,026.5 - 916.7 = 109.8; CIB 359.4 - 285.9 = 73.5; 73.5 / 109.8 = 67% (about two-thirds). CIB share of average loans 359.4 / 1,026.5 = 35.0% (Q2 2026); 285.9 / 916.7 = 31.2% (Q2 2025). Trading-related assets 401.5 / 283.7 - 1 = 41.5%; Markets loans 111.2 / 79.0 - 1 = 40.8%; CIB average loans 359.4 / 285.9 - 1 = 25.7%. Tangible common equity / total assets: Dec 2024 135.6 / 1,929.8 = 7.0%; June 2026 139.7 / 2,282.2 = 6.1%. Branches 4,079 - 5,032 = -953; 4,079 / 5,032 - 1 = -19%. Mobile active customers 33.7 / 29.9 - 1 = 13%. Headcount 197,466 / 212,804 - 1 = -7%. Personnel expense 36,281 / noninterest expense 54,842 = 66% (about two-thirds). Efficiency gap to JPMorgan (66% - 52%) x 83,699 = about 11,718 (about $11.7 billion). JPMorgan deposits 2,559,320 / 1,426,207 - 1 = 79%; market value 911.91 / 250.90 = 3.6 times. Capital: CET1 headroom 10.3% - 8.5% = 1.8 points. Returned 2025 (17.7 billion buybacks + 6.5 billion dividends - 1.053 billion preferred dividends) / 20.285 billion net income to common = 114%. Average diluted shares 3,242.3 / 5,108.3 - 1 = -36.5% (2016 to 2025). EPS 6.26 / 4.12 - 1 = 52%. Revenue 83,699 / 86,057 - 1 = -2.7% (2015 to 2025). Trailing twelve months to June 2026: revenue 21,436 + 21,292 + 21,446 + 22,622 = 86,796; net income 5,589 + 5,361 + 5,253 + 6,407 = 22,610; EPS 1.66 + 1.62 + 1.60 + 2.00 = 6.88. First half 2026: net income 5,253 + 6,407 = 11,660; net interest income 12,096 + 12,317 = 24,413; noninterest expense 14,330 + 13,661 = 27,991, about 50.3% of the ~55,700 guidance. Market value 250.90 / 298.75 - 1 = -16% (end 2017 to Sept 2026). Segments (2025): revenue 37,362 + 11,978 + 19,232 + 16,328 = 84,900; plus Corporate 747, less Reconciling Items 1,948 = 83,699. Shares of segment revenue: Consumer Banking and Lending 37,362 / 84,900 = 44%; Commercial Banking 11,978 / 84,900 = 14%; CIB 19,232 / 84,900 = 23%; Wealth and Investment Management 16,328 / 84,900 = 19%. Shares of company net income 21,338: Consumer Banking and Lending 7,865 = 37%; CIB 7,283 = 34%; Commercial Banking 4,184 = 20%; Wealth and Investment Management 2,119 = 10%. CIB share of segment net income 7,283 / (7,865 + 4,184 + 7,283 + 2,119 = 21,451) = 34%; of total revenue 19,232 / 83,699 = 23%. Wealth net income / revenue 2,119 / 16,328 = 13%. Commercial Banking net income 4,184 / 5,104 - 1 = -18%. CIB Banking 2,522 + 2,507 + 2,008 = 7,037. Investment banking 2,008 / 1,404 - 1 = 43%. Credit card revenue 6,375 / 5,809 - 1 = 10%; Auto 1,016 / 1,464 - 1 = -31%. Advisory assets 1,127 / 891 - 1 = 26%. Consumer Banking and Lending share of Q2 2026 revenue 10,288 / 22,622 = 45%. Consumer Banking and Lending provision 3,362 / total provision 3,658 = 92%. Markets loans 111.2 - 79.0 = 32.2; 32.2 / 73.5 = 44% of the CIB loan increase. Investment banking share of CIB revenue 1,404 / 19,191 = 7% (2023); 2,008 / 19,232 = 10% (2025). Debit plus credit card purchase volume 530.5 + 186.0 = 716.5 billion. More deposits: noninterest-bearing deposits 505,770 - 360,047 = 145,723 (about $146 billion, 2022 to 2025); average deposits 1,424,269 - 1,347,245 = 77,024 (about $77 billion). Interest on interest-bearing deposits 24,282 - 20,449 = 3,833 (about $3.8 billion). Bank of America 2024 all-in deposit cost 38,442 / 1,924,106 = 2.00%. JPMorgan average deposits 2,506,565 / 1,347,245 = 1.9 times. Average loans to average deposits Q2 2026 1,026.5 / 1,465.6 = 70%. Bank of America deposits 2,018,729 / 1,426,207 - 1 = 42%. Held-to-maturity share of total assets 198,573 / 2,282,201 = 8.7% (June 2026); 208,023 / 2,148,631 = 9.7% (Dec 2025). More balance sheet and valuation: branches closed 5,032 - 4,777 = 255 (2021); 4,598 - 4,311 = 287 (2023); 4,177 - 4,090 = 87 (2025); 4,090 - 4,079 = 11 (H1 2026); 4,311 - 4,079 = 232 (end 2023 to June 2026). Second half 2025 assets 2,148,631 - 1,981,269 = 167,362 (about $167 billion). Market value 233.86 / 298.75 - 1 = -22% (end 2017 to end 2024); Bank of America 394.32 / 250.90 - 1 = 57%; market value over trailing net income 250.90 / 22.61 = 11.1 times. Risk-weighted assets 137.7 / 0.103 = about 1,337 billion (about $1.34 trillion). Total equity 182,323 / 2,282,201 = 8.0%. 2016 penalties 100 + 35 + 50 = 185 million. Commercial Banking net interest income 7,902 / 11,978 = 66%. Consumer Banking and Lending deposit surplus 779,994 - 322,052 = 457,942 (about $458 billion) - capital, balance sheet, valuation, returns and comparisons with JPMorgan and Bank of America. — Length additions: held-to-maturity Dec 2025 208,023 - 175,797 = 32,226; carrying value 208,023 - 198,573 = 9,450 (about $9.5 billion in six months). Interest on interest-bearing deposits 16,503 / 2,349 = 7.0 (about seven times). Consumer Banking and Lending net interest income 29,183 / 37,362 = 78%. Average deposits per branch 1,437,812 / 4,777 = 301 (2021); 1,347,245 / 4,090 = 329 (2025). Deposits Dec 2024 to Jun 2026 1,501,405 - 1,371,804 = 129,601 (about $130 billion). TLAC cushion 23.22 - 21.50 = 1.72 points; 22.81 - 21.50 = 1.31 points. CIB assets 862,472 / 2,282,201 = 38%; CIB period-end assets 787,751 / 597,278 - 1 = 32%. CIB investment banking 1,814 / 1,404 - 1 = 29%; 2,008 / 1,814 - 1 = 11%; Q2 2026 628 / 5,425 = 12%. CIB revenue per dollar of expense 19,232 / 9,436 = 2.04; Consumer Banking and Lending 37,362 / 23,515 = 1.59. CRE 5,083 / 19,232 = 26%. Q2 2026 expense 13,661 / 13,379 - 1 = 2.1%; revenue 22,622 / 20,822 - 1 = 8.6%. Headcount 205 - 197 = 8 thousand. Average assets per employee 1,933.4 / 212,804 = $9.1 million (Q2 2025); 2,227.9 / 197,466 = $11.3 million (Q2 2026), +24%. Personnel expense per employee 36,281 / 205,000 = 0.177 ($177,000). Efficiency gap to Bank of America (66% - 61.65%) x 83,699 = 3,641 (about $3.6 billion). Risk-weighted assets about 1,340 billion x 1% = about $13 billion per point; 9.80% - 8.50% = 1.30 points x 1,340 = about $17 billion. Stockholders equity 180,190 / 206,936 - 1 = -12.9%. Charge-offs 876 x 4 = 3,504 (about $3.5 billion); 14,129 / 139,700 = 10.1%. JPMorgan cost of total deposits 2024 2.08% against Wells Fargo 1.80%. ROTCE H1 2026 16.1% - 14.4% = 1.7 points. Target 17.5% x 139.7 = 24.4 billion; 24.4 / 20.285 = 1.20. Net income 6,407 x 4 = 25,628 (about $25.6 billion). H1 2026 expense 27,991 / 55,700 = 50.3%; net interest income 24,413 / 50,000 = 48.8%. Credit card revenue 6,375 / 5,908 - 1 = 7.9%; Auto 1,016 / 1,464 - 1 = -30.6%. Home Lending 3,364 / 37,362 = 9.0%; originations 26.3 / 986.2 = 2.7%. Buybacks 22.7 billion / 79.80 = 284 million shares; 284 / 3,085.6 = 9.2%. Tangible book 1 / 1.79 = 0.56. Dividend 0.50 x 4 x 3.02 billion = 6.04 (about $6.0 billion). Accounts 16 million / 32.8 million = 49%. Remediation 236 / 160,700 = 0.15%. Advisory assets 1,127 / 2,509 = 45%. Investment banking fees 3,027 / 83,699 = 3.6%. Advisory fees 10,498 / 36,215 = 29%. Branches 4,090 - 4,079 = 11. Buyback runway 22.7 / 17.7 = 1.3 years (about fifteen months); 22.7 / (7 x 2) = 1.6 years. Deposits 1,347,245 / 1,376,011 - 1 = -2.1%. Q2 2026 consumer bank share 10,288 / 22,622 = 45%. Card fees 4,589 / mortgage banking 1,152 = 4.0. 2015-2026 · publ. September 2026 · source ↗
    Method: Arithmetic on figures reported in Wells Fargo's annual reports, Forms 10-Q, earnings releases and presentations, JPMorgan's and Bank of America's Forms 10-K and market data; operands shown in the source line.
Sources
Generated September 28, 2026