Consumer complaint received 2025-10-27 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Problem accessing account
Company: WELLS FARGO & COMPANY
State: CA

Complaint narrative:
ENHANCED CFPB COMPLAINT Wells Fargo Bank , N.A . 

Subject : Pattern of employee misrepresentation, false assurances, and systemic failure to maintain commercially reasonable security procedures under UCC Article 4A and OCC Safety & Soundness standards. 

On XX/XX/year>, I received four Wells Fargo Advanced Access codes by text from short-code XXXX between XXXX XXXX  and XXXXXXXX XXXX XXXXXXXX XXXX 
Concerned that these codes indicated an attempted unauthorized login, I immediately contacted Wells Fargo. 

After being transferred through initial representatives, I was referred to Employee ID XXXX, who took the call at approximately XXXX XXXX XXXXXXXX XXXX 
During the call, she repeatedly stated that the messages were bank mistakes and routine internal activity, and she assured me XXXX percent that no one was trying to access my account. 
She opened XXXXXXXX XXXX XXXXXXXX as the record of that conversation, documenting her representation that the texts were internal and harmless. 

Minutes later, I called Wells Fargo again to verify this explanation. 
XXXX ID XXXX answered and reviewed XXXXXXXX XXXX XXXXXXXX. He confirmed that it had actually been opened as a fraud investigation and that the previous employees statements were false and misleading. 
He recorded the correction in File XXXX XXXXXXXX, noting that the earlier employee had provided incorrect information. 

During this second call, I requested the most basic safeguard any modern financial institution should support : that all account changes or transactions occur only in branch and only after my identity is verified using my debit card PIN, not a drivers license alone. 
The employee documented my request and replied that Wells Fargo does not have the technology or alert capability to inform or restrict branch personnel accordingly. 
The verbatim note entered in File XXXX reads : Customer wants every transaction and every change in the account to be done in branch. 
Customer must be verified with his debit card otherwise, no transaction or changes should be made. 
Customer also wanted everyone to be alerted including branch bankers about this but I advised that we dont have that type of alert capability. 

This admission exposes a severe deficiency in Wells Fargos security architecture. 
The bank lacks even the most fundamental tools to communicate customer-specific security restrictions internally or to enforce in-branch identity verification using a debit card PIN. 
Such a limitation renders its authentication procedures not commercially reasonable under UCC 4A-202 ( b ).

Under 4A-204 ( a ), when a banks inadequate security procedures allow fraud despite a customers ordinary care, the loss is the banks responsibility. 

Beyond the technical failure, this incident adds to a clear, documented pattern of employee misrepresentation and deceit that I have experienced across multiple Wells Fargo interactions. 
In earlier cases ( see CFPB Case XXXX [ insert ] and OCC Case XXXX  [ insert ] ), other Wells Fargo employees also provided false assurances including a claim that I had approved a wire transfer at a time when my wire-notification system had been disabled.

This recurring behavior shows that misrepresentation is not exceptional at Wells Fargo ; it appears to be systemic and routine, reflecting either deliberate internal minimization or training deficiencies that mislead consumers about real risks.

Such conduct violates the expectation of honesty and due care that national banks owe to their customers under federal consumer-protection laws and OCC Safety and Soundness standards ( XXXX XXXX XXXX XXXX XXXX XXXX which require institutions to : Maintain adequate internal controls and authentication processes ; Communicate operational restrictions effectively throughout the organization ; and Safeguard customer assets from unauthorized access. 

Wells Fargos own admission that it doesnt have that type of alert capability demonstrates failures on all three counts.

It also raises serious questions under the Consumer Financial Protection Act ( 12 U.S.C. 5531, 5536 ) prohibiting unfair, deceptive, or abusive acts or practices ( UDAAP ). 
Representing fraudulent-access alerts as routine internal mistakes, and assuring customers of safety when an investigation is already open, is deceptive conduct that erodes consumer trust and conceals material risks. 

The combined effect is a security posture so weak that a criminal with only basic technical skills could bypass Wells Fargos safeguards.

The banks system relies not on layered authentication but on hope the benevolence or inexperience of thieves which is far below the standard of care expected of a federally regulated financial institution in 2025.

Note to CFPB and Responding Institution : This submission contains verifiable data including exact timestamps, employee identification numbers, internal file references, and verbatim internal notations that document the banks admissions and procedural weaknesses. I respectfully request that Wells Fargos response address each factual element listed herein directly and not rely on generalized or template language. A generic response will not resolve the core issues of misrepresentation and failure to maintain commercially reasonable security procedures under UCC 4A-202 and 4A-204 and the OCC Safety and Soundness Standards ( 12 C.F.R. 30 Appendix A ).

Please ensure any Wells Fargo reply includes : A factual explanation of why four Advanced Access codes were generated on XX/XX/year> and what triggered them ; An internal confirmation or denial that File XXXX XXXXXXXX was opened as a fraud investigation ; A technical explanation of Wells Fargos current branch-notification and debit-card-PIN verification capabilities ; and Identification of which business unit or executive officer is accountable for these security controls.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation