BUS 4210 Module 7 Wells Fargo's Sales Scandal and Recovery Example

Reviewed by Edgar Pennington, MBA Thomas Edison State University Updated October 2026

This BUS 4210 Module 7 sample paper answers the seventh case study assignment for the Business Administration Capstone, on ethics and social responsibility. Written within TESU's Bachelor of Science in Business Administration (BSBA), it traces Wells Fargo from the 2016 findings on unauthorized accounts, through a 2018 consent order that capped its assets and settlements of $3 billion in 2020 and $3.7 billion in 2022, to June 3, 2025, when the Federal Reserve removed the asset cap. Using the textbook's three drivers of unethical strategy and research on the side effects of narrow goals, it explains why the conduct happened and draws lessons for incentive design. BUS-4210 is the catalog listing.

CourseBUS-4210 Business Administration Capstone
ModuleModule 7
Paper typeCase study assignment 7: ethics and social responsibility
LengthAbout 855 words, 6 pages
FormatAPA 7 student paper
SchoolThomas Edison State University
ProgramBachelor of Science in Business Administration
UpdatedOctober 2026

Free sample paper for BUS 4210 Module 7

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Eight Accounts per Customer: What Wells Fargo's Scandal Teaches About Strategy and Ethics

Student Name

Bachelor of Science in Business Administration, Thomas Edison State University

BUS-4210: Business Administration Capstone

Mentor Name

Month Day, Year

What this page is doingThe title refers to the cross-selling goal associated with the scandal. Facts come from Wells Fargo's annual report and federal enforcement announcements.
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Eight Accounts per Customer: What Wells Fargo's Scandal Teaches About Strategy and Ethics

Introduction

Thompson et al. (2018) argue that ethical behavior is part of good strategy, not a constraint on it, and identify three main drivers of unethical strategies: faulty oversight that allows the overzealous pursuit of personal gain, heavy pressures on company managers to meet or beat performance targets, and a company culture that puts profitability and good performance ahead of ethical behavior. Wells Fargo's sales practices scandal, and the years of penalties and restrictions that followed, illustrate all three. This case analysis examines what happened, why, what it cost, and what changed before regulators lifted the bank's growth restriction in 2025.

What Happened

For years Wells Fargo's retail bank promoted cross-selling, encouraging employees to sell each customer more accounts and products, with the slogan eight is great. Branch employees faced daily sales quotas. In September 2016, federal and local regulators found that employees had opened deposit and credit card accounts without customers' authorization to meet those goals, and the bank paid $185 million in penalties. Later reviews raised the number of potentially unauthorized accounts into the millions. In February 2018 the Federal Reserve entered a consent order requiring the board to improve governance and oversight and limiting the bank's total assets to their size at the end of 2017 until it did (Wells Fargo & Company, 2026). In 2020 it settled criminal and civil investigations of the sales practices for $3 billion (U.S. Department of Justice, 2020), and in 2022 it was ordered to pay $3.7 billion for widespread mismanagement of auto loans, mortgages and deposit accounts (Consumer Financial Protection Bureau, 2022).

Why It Happened

All three of the textbook's drivers were present. Oversight was faulty: senior managers and the board treated reports of misconduct as a problem of individual employees rather than of the sales system. Performance pressure was intense: quotas cascaded from regional managers to branches to individual bankers, and failing to meet them threatened jobs. The culture prized cross-selling as the bank's signature strength, so questioning the goals felt disloyal.

Research explains how goals produced this behavior. Ordonez et al. (2009) argued that goal setting, though effective, has systematic side effects when goals are too specific, too challenging or too narrow: people focus on the measured target, take risks and cut ethical corners to reach it, and organizations develop cultures that tolerate those shortcuts. The number of accounts per customer was a measured target that could be met by opening accounts customers never used, which is exactly the side effect the researchers described.

The Costs

The costs were large and lasting.

ConsequenceDetail
Penalties and settlements$185 million in 2016; $3 billion in 2020; $3.7 billion in 2022
Growth restrictionTotal assets capped from February 2018 until June 3, 2025
LeadershipTwo chief executives departed; a new chief executive took over in 2019
ReputationYears of customer distrust, congressional hearings and media scrutiny

The asset cap was the most strategic cost: for more than seven years Wells Fargo could not grow its balance sheet while rivals did, which limited lending, deposits and market share. The case shows the textbook's business case for ethics clearly: unethical strategies can lift short-term results but expose a company to penalties, restrictions and lost trust that far outweigh the gains.

Ethical Frameworks

Under ethical universalism, opening accounts without consent is wrong everywhere, regardless of local practice or competitive pressure; no framework in the textbook would justify it. The relevant question for managers is not whether the conduct was wrong but how a large company allowed it to happen at scale, which points to incentive design, oversight and culture rather than to individual employees alone.

Recovery and Lessons

Wells Fargo eliminated product sales goals for retail bankers, changed leadership and spent years rebuilding risk management and governance. On June 3, 2025, the bank confirmed that the Federal Reserve had removed the asset cap, though the remaining provisions of the consent order stayed in place (Wells Fargo & Company, 2026). Three lessons apply to any company. Incentives should measure outcomes customers value, such as accounts actively used, not raw counts of products. Boards should treat patterns of misconduct as signals about the system. And compliance should be part of how performance is judged, so that managers are not rewarded for results achieved in ways the company would condemn.

The Role of the Board

Thompson et al. (2018) stress that boards are responsible for overseeing management's strategy and ethics. Wells Fargo's consent order required its board to improve its governance and oversight of the company, which shows that regulators saw board oversight, not only branch behavior, as part of the failure. A board that reviews sales goals, complaint data and employee hotline reports together is better placed to see when incentives are producing misconduct.

Conclusion

Wells Fargo's scandal grew from a strategy that turned cross-selling into narrow quotas, reinforced by weak oversight and a culture that prized the numbers. The penalties and seven years of capped growth show that ethics is part of strategy, and that incentive systems must be designed with their side effects in mind.

References

Consumer Financial Protection Bureau. (2022, December 20). CFPB orders Wells Fargo to pay $3.7 billion for widespread mismanagement of auto loans, mortgages, and deposit accounts [Press release].

Ordonez, L. D., Schweitzer, M. E., Galinsky, A. D., & Bazerman, M. H. (2009). Goals gone wild: The systematic side effects of overprescribing goal setting. Academy of Management Perspectives, 23(1), 6-16. https://doi.org/10.5465/amp.2009.37007999

Thompson, A. A., Peteraf, M. A., Gamble, J. E., & Strickland, A. J., III. (2018). Crafting and executing strategy: The quest for competitive advantage, concepts and cases (21st ed.). McGraw-Hill Education.

U.S. Department of Justice. (2020, February 21). Wells Fargo agrees to pay $3 billion to resolve criminal and civil investigations into sales practices involving the opening of millions of accounts without customer authorization [Press release].

Wells Fargo & Company. (2026). Annual report on Form 10-K for the fiscal year ended December 31, 2025. U.S. Securities and Exchange Commission.

What the BUS 4210 Module 7 instructions ask for

Module 7's BUS-4210 case study assignment addresses ethics and social responsibility in strategy. Expect to analyze a company whose strategy raised ethical issues, identify the drivers of the conduct using the textbook's framework, apply ethical principles, assess the business costs and recommend changes to incentives, oversight or culture. Base the facts on regulatory findings, settlements and the company's own disclosures, cited carefully, and use research on how goals and incentives shape behavior. Keep the analysis focused on how the strategy and management systems produced the conduct, not only on condemning it, and end with lessons that apply beyond the case. Date and source every penalty or order you mention. Keep the tone analytical.

Inside the BUS 4210 Module 7 example

The analysis sets out the facts with dates, amounts and sources, then applies the textbook's three drivers one at a time with evidence. Research on goal setting explains the mechanism linking quotas to misconduct, which moves the analysis beyond blame. A table summarizes the costs, and the paper explains why the asset cap was the most strategic one. The ethics section applies a framework briefly and redirects attention to systems. The recovery section reports the 2025 outcome from the company's filing and draws three lessons for incentive design. The conclusion links ethics and strategy in two sentences. Read it for how facts, framework and research build toward lessons. Note the table.

BUS 4210 Module 7 rubric: what earns full marks

Case seven receives a percentage mark. They look for accurate facts from credible sources, correct application of the textbook's drivers of unethical strategy and of ethical frameworks, and a clear account of the business costs. Research on incentives or organizational behavior strengthens the analysis. Recommendations should address systems, such as goals, oversight and culture, and apply beyond the single case. Careful citation of regulatory sources, a table where it clarifies, headings and correct APA style complete the grade. Papers that only condemn conduct, or blame individual employees without examining incentives, tend to score lower. Lessons that would change how another company designs incentives earn particular credit. Careful sourcing matters here.

BUS 4210 Module 7 help from the desk

Students often write ethics cases as moral commentary without connecting the conduct to the company's strategy and management systems. Another weakness is relying on news summaries for facts that regulators and the company have documented directly. Our writers can prepare BUS 4210 ethics and social responsibility analyses of the company in your case. Gather the enforcement announcements, settlements and the company's own disclosures first. Identify which of the three drivers were present and how, explain the mechanism with research, total the costs, and recommend specific changes to incentives and oversight. Finally, check that each recommendation targets a system rather than a person, since systems produced the conduct.

Write yours, or have the desk draft it

This paper is an original model document written by our desk, not a submitted student paper and not an official Thomas Edison State University document. Read it for the moves, then write your own to the instructions in your classroom. If you want one built to your exact prompt and rubric, the first custom sample is free and arrives in 24 to 48 hours.

More BUS 4210 and Bachelor of Science in Business Administration sample papers

BUS 4210 Module 7 questions, answered

Where can I find a free BUS 4210 Module 7 sample paper?

The seventh Business Administration Capstone case study assignment is shown above, analyzing Wells Fargo's sales practices scandal and its 2025 release from the asset cap.

What drives unethical strategies according to Thompson's textbook?

Faulty oversight that allows overzealous pursuit of personal gain, heavy pressure to meet performance targets, and a culture that puts profits ahead of ethics.

What are the side effects of overly narrow goals?

Research by Ordonez and colleagues found they can narrow focus, encourage risk-taking and unethical shortcuts, and foster cultures that tolerate them.

When was Wells Fargo's asset cap removed?

The Federal Reserve removed it on June 3, 2025, after it had been in place since a February 2018 consent order.

What is the business case for ethical strategy?

Unethical strategies can raise short-term results but expose firms to penalties, restrictions and lost trust that outweigh the gains.