EXHIBIT 24

Case: 1:20-cv-02402 Document #: 130-24 Filed: 08/19/22 Page 1 of 6 PageID #:3386
Confidential. March 2015 | Risk Materiality Assessment Template

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A B C D E F G H I J K

# Assessment Attribute Attribute Type Attribute SubType Risk Type Response Risk Level Score Weight per 

Question Response Description (Required)

Supporting 

Documentati

on

A. Qualified C2C Issue Definition

1

Does the issue appear to have an 

actual or perceived negative impact 

on affected consumers (i.e. an 

individual, including an individual 

with a Representative, who 

maintains, is offered, or applies for 

a financial product or service from 

Wells Fargo for personal, family, or 

household purposes), or applicants 

or customers who are governed by 

the jurisdication of the CFPB 

through the Enumerated 

Consumer Financial Laws?

Perceived impact may 

mean that WF does not 

believe an error occurred 

but an outside party or 

regulator may believe the 

negative impact exists and 

we are remediating due to 

that perception. 

Definition - N/A Yes Continue to Next 

Question N/A

A examination was initiated to review customers who were denied a loan 

modification due to the process used to estimate attorney fees.

The Home Preservation Application (HPA) tool used by the Wells Owned, Bank and 

Private, FNMA, FHLMC and VA portfolios was placed into production April 13, 2010 

with logic to utilize a State Fee Matrix that provided maximum allowable foreclosure 

attorney fees and costs.**As of 3/20/2018, it was determined that VA is out of 

scope as they did not utilize the state fee matrix.

The HPA tool was automated to pull in attorney fees that were paid at the time of 

the decision from MSP screen (DDCH) and added them to the maximum allowable 

from a state matrix. 

Potential Impact to the customer: This practice potentially over stated the dollar 

amount for recoverable fees that were incurred at the time of the decision, which 

could have created an HTI impact making the payment unaffordable and potentially 

declining for either affordability and/or NPV. 

The fee matrix usage was eliminated from the HPA tool on 10/20/2015.

2

Does the issue appear to require 

historical remediation related to 

past events?

If WF can take action to 

prevent the negative 

impact, it is not a C2C 

issue.

Definition - N/A Yes Continue to Next 

Question N/A Yes. The State Fee Matrix was utilized within the HPA tool from April 13, 2010 through October 20, 2015.

3

Does the issue appear to be 

systemic in nature (i.e., affecting 

multiple consumers due to one or 

more common root causes)?

This does not necessarily 

mean caused by a system 

failure. It means that 

multiple customers are 

impacted by the same 

failure.

Definition - N/A Yes Continue to Next 

Question N/A Yes, multiple consumers have been impacted by this issue. 

4

Does the issue appear to be within 

the control of Wells Fargo or parties 

under Wells Fargo’s control (for 

example, third-party service 

providers)?

Excludes BCP incidents or 

other external forces. Definition - N/A Yes

C2C Issue - Complete 

Sections B-F

N/A Yes, this issue is within the control of Wells Fargo.

B. Materiality Assessment

1

Does the issue appear to affect 

more than XXX accounts? 

Use the Risk and Materiality 

Thresholds listed for your 

business below.

Materiality - Operational Risk No Continue to Next 

Question N/A Validated by Wells Fargo Audit Services (WFAS) and RECOR Data Validation Team (DVT).

2

Does the issue involve potential 

remediation equal to or greater 

than $XXXXXX in total? 

Use the Risk and Materiality 

Thresholds listed for your 

business below.

Materiality - Financial Risk No Continue to Risk 

Assessment N/A Remediation amount is below threshold.

Business Group

Dollar 

Threshold 

(millions)

Account 

Threshold 

(thousands)

Commitment to Customer Program

Risk & Materiality Assessment Template

Risk & Materiality Assessment

Instructions: The purpose of the Risk and Materiality Assessment is to assist in the determination of whether the issue qualifies as a Commitment to Customer Issue, recognizing that this Policy and the Corporate Program in general are not intended to address issues of a de minimis nature. 

The Steering Committee will establish Commitment to Customer Issue risk and materiality thresholds. On at least an annual basis, these thresholds will be reviewed and subject to adjustment, as appropriate. This template may be used to perform omissions testing. Completion of section A 

will assist in the determining if the issue at hand qualifies as a C2C issue. The user will be prompted to complete the risk and materiality sections (B-F), as necessary. Attributes marked with an asterisk and answered affirmatively require timely notification be provided to the CFPE.

Note that this assessment methodology will be approved by the Commitment to Customer Steering Committee.

Case: 1:20-cv-02402 Document #: 130-24 Filed: 08/19/22 Page 2 of 6 PageID #:3387
Confidential. December 2015 | Risk Materiality Assessment Template 2

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A B C D E F G H I J K

# Assessment Attribute Attribute Type Attribute SubType Risk Type Response Risk Level Score Weight per 

Question Response Description (Required)

Supporting 

Documentati

on

Risk & Materiality Assessment

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Community Banking Group 

(CBG) $ 1.5 25.0

Consumer Lending Group (CLG)

 Real Estate Lending (RE)

 Consumer Credit Solutions 

(CCS)

 Dealer Services (DS)

$ 10.0

$ 5.0

$ 5.0

50.0

25.0

25.0

Wealth Brokerage and 

Retirement (WBR) $ 5.0 5.0

Wholesale (WHSL) $ 5.0 25.0

C. Risk Assessment - Identification Source

1

Was the issue identified through a 

regulatory examination, inquiry 

and/or complaint?*

The inquiry or complaint 

would also have come from 

a regulator, not through 

standard internal 

processes. 

Risk Identification 

Source Regulatory Risk No 0 3

No, the issue was not identified through a regulatory examination, inquiry or 

complaint. The issue was discovered while an assessment was taking place for a 

separate issue within Settlement.

2

Was the issue identified by a thirdparty business partner and/or 

government-sponsored entity 

(GSE) with which and/or to whom 

Wells provides services (e.g., 

mortgage loan servicing, joint 

marketing, etc.)? 

Risk Identification 

Source Third-Party Risk No 0 1 No, the issue was not identified by a third party business provider or a GSE.

3 Was the issue identified by a thirdparty service provider? Risk Identification 

Source Third-Party Risk No 0 1 No, the issue was not identified by a third party service provider.

4

Was the issue identified through a 

high-profile channel (e.g., news 

media, social media, etc.)?

Risk Identification 

Source Reputational Risk No 0 1 No, the issue was not identified through a high-profile channel.

5

Was the issue identified through a 

consumer lawsuit and/or other 

legal action?*

Risk Identification 

Source Legal Risk No 0 3 No, the issue was not identified through a consumer lawsuit or other legal action.

6

Was a similar issue identified in 

regulatory action taken against 

another institution?*

Answer yes if our 

remediation is driven in 

whole or in part by the 

action taken at the other 

institution. 

Risk Identification 

Source

Regulatory Risk, 

Legal Risk No 0 3 No, we are not aware of a similar issue being identified against another financial institution.

D. Risk Assessment - Affected Population 0.00 12.00

1

Does the issue appear to affect 

high-risk consumers, protected 

classes, or vulnerable populations 

(e.g., service members, loss 

mitigation/workout mortgage 

borrowers, foreclosures, etc.), or 

does the issue appear to involve 

potential discrimination and/or 

pose potential Fair Lending-related 

risks?*

Answer yes if the nature of 

the issue uniquely or 

disproportionately impacts 

high risk consumers.

Risk Affected 

Population Reputational Risk Yes 3 3 Yes, this issue impacts Loss Mitigation and Foreclosure loans. 

2

Does the issue appear to affect 

consumers nation-wide (and/or 

globally)?

Risk Affected 

Population N/A Yes 1 1 Yes, this issue does affect consumers nation-wide.

3

Does the issue appear to affect 

consumers across multiple 

products?

Risk Affected 

Population N/A No 0 1 No, the issue is limited to Home Lending Loss Mitigation products.

Case: 1:20-cv-02402 Document #: 130-24 Filed: 08/19/22 Page 3 of 6 PageID #:3388
Confidential. December 2015 | Risk Materiality Assessment Template 3

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A B C D E F G H I J K

# Assessment Attribute Attribute Type Attribute SubType Risk Type Response Risk Level Score Weight per 

Question Response Description (Required)

Supporting 

Documentati

on

Risk & Materiality Assessment

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4

Does the issue appear to affect 

consumers across multiple lines of 

businesses (LOBs) and/or service 

delivery channels?

To cross LOB's, the issue 

must extend beyond 

Home Lending.

Risk Affected 

Population N/A No 0 1 No, the issue is limited to Home Lending.

E. Risk Assessment - Nature of Issue 4.00 6.00

1 Does the issue appear to be a 

repeat issue?

Repeat issue means that 

the same issue has 

recurred despite corrective 

action to prevent and NEW 

Risk Nature of Issue Operational Risk No N/A N/A No, this is not a repeat issue.

2

Does the issue appear to be 

attributable (in whole or part) to a 

third-party service provider? 

Respond yes if an error by 

a third party was a driver 

for the remediation.

Risk Nature of Issue Third-Party Risk No 0 1 No, the issue is not attributable to a 3rd party service provider.

3

Does the issue appear to be related 

to a high-risk product or service 

(e.g., credit card add-on product, 

mortgage loan modification, special 

purpose-credit programs, etc.)?*

There are no high risk 

products identified by 

Home Lending, If the issue 

relates to modifications, 

answer question D1 (High 

Risk Nature of Issue

Reputational 

Risk, Regulatory 

Risk

No 0 3 There are no high risk products identified by Home Lending.

4

Does the issue appear to involve 

potential privacy and/or 

information security-related risks?

Risk Nature of Issue Regulatory Risk No 0 1 No, the issue does not appear to involve privacy and/or information security related 

risks.

5

Does the issue appear to involve 

potential non-compliance with 

consumer protection laws or 

regulations, including those 

enumerated consumer financial 

laws applicable to the business?*

Only Law Department can 

state that a violation has 

occurred. LOB may 

respond No if there are 

clearly no compliance 

aspects of the issue after 

consulting with RECOR. 

Risk Nature of Issue Regulatory Risk Yes 3 3 [Redacted - WP & ACP]

6

Does the issue appear to involve 

potential non-compliance with 

consumer protection laws or 

regulations, including those 

enumerated consumer financial 

laws applicable to the business?*

Partner with Investor 

Services or Agency 

Relations if a violation is 

suspected. 

Risk Nature of Issue Third-Party Risk, 

Legal Risk Yes 1 1 [Redacted - WP & ACP]

7

Does the issue appear to involve 

potential non-compliance with 

consumer protection laws or 

regulations, including those 

enumerated consumer financial 

laws applicable to the business?*

Answer yes if the error 

cannot be cured due to 

missed timing or other 

factor that cannot be 

corrected after the fact. 

Risk Nature of Issue Operational Risk No 0 2 [Redacted - WP & ACP]

8

Does the issue appear to pose 

potential serious reputation risk to 

the Bank? 

Consider Rep Risk 

questions C4, D1, and E3. 

If those are Yes, then 

Sponsor should consider 

identifying as serious risk. 

Risk Nature of Issue Reputational Risk No N/A N/A No serious reputational risk. 

F. Risk Assessment - Corrective Action and Remediation 4.00 11.00

Case: 1:20-cv-02402 Document #: 130-24 Filed: 08/19/22 Page 4 of 6 PageID #:3389
Confidential. December 2015 | Risk Materiality Assessment Template 4

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A B C D E F G H I J K

# Assessment Attribute Attribute Type Attribute SubType Risk Type Response Risk Level Score Weight per 

Question Response Description (Required)

Supporting 

Documentati

on

Risk & Materiality Assessment

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1

Are there any known record 

retention, data integrity or other 

operational challenges associated 

with obtaining data and calculating 

potential financial restitution?* 

Risk Corrective Action 

and Remediation

Financial Risk, 

Operational Risk No 0 3 No record retention or data integrity challenges.

2

Does the issue involve potential 

corrective action that may require 

an extended period of time to 

complete (with or without a feasible 

interim solution)?*

This should consider your 

final corrective action, not 

long-term efficiency 

enhancements that are 

release dependent.

Risk Corrective Action 

and Remediation Operational Risk No 0 3 No, the state fee matrix is no longer in use. 

0.00 6.00

8.00 35.00

Yes

Low

Low

No

Yes

Executed By Cathy Gutierrez / Jason DePino

Risk Date 4/5/18

20-35 LOB Approver Brian Spensley Approval

10-19 Date 4/11/18

≤9 RECOR Approver Brian Dietz Approval

Date 4/18/18

Functional Title

Spensley, Brian LoB Approver

Thompson, Jill

Lending Officer, Default 

Underwriting Escalation 

Team – Primary Business 

Contact 

Archer, Kari L. 

Business Support 

Consultant, Default 

Underwriting Escalation 

Team

Gutierrez, Cathy

Default Customer Impact 

Resolution (DCIR) 

Incident Owner 

Depino, Jason A. 

Default Customer Impact 

Resolution (DCIR) 

Incident Owner 

Rodriguez, Ruby Servicing Operational Risk 

Management - CIT Analyst

Y

Y

Jason.A.Depino@wellsfargo.com

ruby.rodriguez@wellsfargo.com 

5 - Notify CFPE?*

Moderate

4- Is this Issue subject to 

Governance Working Group 

acceptance? 

Legend

G. Conclusion

2 - Assessed Materiality Level

3 - Assessed Risk Level

1 -- Is this a C2C Issue?

Brian.A.Spensley@wellsfargo.com 

Low

Risk Level

High

Interested Parties Included:

Name Email Participated Y/N

cathy.gutierrez@wellsfargo.com 

jillthompson@wellsfargo.com Y

Kari.L.Archer@wellsfargo.com Y

Y

Case: 1:20-cv-02402 Document #: 130-24 Filed: 08/19/22 Page 5 of 6 PageID #:3390
Confidential. December 2015 | Risk Materiality Assessment Template 5

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A B C D E F G H I J K

# Assessment Attribute Attribute Type Attribute SubType Risk Type Response Risk Level Score Weight per 

Question Response Description (Required)

Supporting 

Documentati

on

Risk & Materiality Assessment

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Alvarez, Adam Customer Excellence Data 

Analytics (CEDA)

Bothwell, Katherine M. RECOR

Camp, James Operational Risk 

Consultant, Settlement

Cannady, Annette Customer Service 

Cortese, Ralph V.

RECOR WFHL FCRA 

Program Compliance 

Manager

Drzewiecki, Kathleen Business Support 

Consultant, BK

Edwardson, Jessica M. Operational Risk 

Consultant, Settlement

Giroux, Chelsea Foreclosure

Good, Todd Customer Care and 

Recovery Group (CCRG)

Graves, Darla J. Investor Reporting FHLMC

Guttry, Tammy Operational Risk 

Consultant, CAMO

Hohenstern, Kimberly Customer Service 

Hutzell, Travis Customer Excellence Data 

Analytics (CEDA)

Johnson, Lynne MHA Operation Reporting

Johnson, Tonya Paralegal

Kohls, Bob Legal

Ossian, Brandy Finance

Parker, Linda G ORC Credit Bureau 

Reporting

Rivera, Ramon Home Preservation 

Specialists (HPS)

Rodriguez, Ruby CIT Analyst

Simpson, Roger ORC Credit Bureau 

Reporting

Solis, Gerry Customer Service

Vaske, Lori COE Communications

Williams, Julie T. Customer Service julie.williams@wellsfargo.com Y

Nicole Nichols Y

Jeff Liggett Y

Y

Y

Y

Y

Y

ramon.rivera@wellsfargo.com

ruby.rodriguez@wellsfargo.com 

roger.simpson@wellsfargo.com 

gerry.solis@wellsfargo.com 

lori.vaske@wellsfargo.com 

lynne.m.johnson@wellsfargo.com 

tonya.johnson2@wellsfargo.com 

bobkohls@wellsfargo.com 

brandy.ossian@wellsfargo.com 

LINDA.G.PARKER@wellsfargo.com 

todd.a.good@wellsfargo.com 

Darla.J.Graves@wellsfargo.com 

Tammy.A.Guttry@wellsfargo.com 

kimberly.hohenstern@wellsfargo.

travis.hutzell@wellsfargo.com 

Annette.Cannady@wellsfargo.com 

Ralph.V.Cortese@wellsfargo.com 

kathleen.m.drzewiecki@wellsfargo

.com

jessica.m.edwardson@wellsfargo.

com

chelsea.giroux@wellsfargo.com 

adam.alvarez@wellsfargo.com 

Katherine.M.Bothwell@wellsfargo.

james.t.camp@wellsfargo.com 

Case: 1:20-cv-02402 Document #: 130-24 Filed: 08/19/22 Page 6 of 6 PageID #:3391