Eric Poer,¹ an internationally-recognized forensic accounting, investigations, and disputes expert, led the forensic accounting and data analytics team retained to support A&O Shearman² in conducting an independent investigation into Wells Fargo’s sales practices—an inquiry launched in response to one of the most significant financial consumer fraud scandals in U.S. history.

Mr. Poer and his team’s forensic analyses uncovered systemic misconduct and laid the foundation for extensive reforms that redefined Wells Fargo’s leadership, governance, and culture. These changes restored public trust, strengthened governance, and positioned the bank for sustainable growth, demonstrating how big data and forensic analysis can catalyze organizational transformation.

Background 

The investigation was commissioned by the independent directors of Wells Fargo’s Board of Directors following allegations that, between 2002 and 2016, Wells Fargo’s Community Bank employees opened millions of unauthorized customer accounts and financial products without consent. These allegations pointed to the bank’s aggressive volume-based sales model, which pressured employees to sell products regardless of actual customer need. 

In 2020, Wells Fargo agreed to pay $3 billion USD to resolve criminal and civil investigations by the U.S. Department of Justice and the Securities and Exchange Commission,³ highlighting the scale of the misconduct and the urgency for reform.  

Expert Impact 

Uncovering Systemic Misconduct Through Data 

With unrestricted access to the bank’s data, Mr. Poer and his team analyzed millions of records — from employee terminations and customer accounts to funding trends — to assess the scope of the bank’s aggressive sales culture and identify systemic issues driving misconduct.⁴ Michael Garibaldi⁵ and Chris Riper⁶ led significant workstreams that helped uncover the scale and impact of the misconduct.  

The forensic analyses from Mr. Poer’s team revealed that, as sales goals became increasingly unattainable, sales integrity allegations and associated employee terminations increased, and account quality declined.⁷ This analysis informed the Board’s conclusion that the misconduct stemmed from a high-pressure sales culture, and a decentralized corporate structure that masked the scale of the problem. 

Historic Reforms Built from Expert Analysis 

The Board’s report, guided by the forensic analyses from Mr. Poer’s team, outlined clear, data-driven findings and comprehensive reforms, including overhauls to sales incentives, control structures, and culture. 

The reforms delivered transformational results for Wells Fargo. In May 2025, the Federal Reserve announced it had terminated enforcement orders and lifted the bank’s $1.95 trillion asset cap, signaling restored trust and allowing the bank to pursue unimpeded growth. 

“The Federal Reserve’s decision to lift the asset cap marks a pivotal milestone in our journey to transform Wells Fargo,” said Wells Fargo CEO Charles Scharf in a June 2025 statement.⁸ “We are a different and far stronger company today because of the work we’ve done. ... [and] the processes and cultural changes we have made.” 

Steven D. Black, the Chair of Wells Fargo’s Board of Directors, also noted, “I want to thank our Board of Directors for their work in achieving today’s outcome, including the substantial changes we have made to board composition and oversight.” 

1. As of May 2024, Eric is a Managing Director at Secretariat and a leader in the firm’s Global Disputes and Investigations Practice. At the time of this engagement, Eric was a Senior Managing Director with FTI Consulting.  ↩︎
2. Formerly Shearman & Sterling. In 2024, Shearman & Sterling merged with Allen & Overy to form A&O Shearman.  ↩︎
3. 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 ↩︎
4. Independent Directors of the Board of Wells Fargo & Company - Sales Practices Investigation Report, p. 3 ↩︎
5. As of September 2025, Michael is a Managing Director at Secretariat. At the time of this engagement, Michael was a Managing Director with FTI Consulting. ↩︎
6. As of June 2024, Chris is a Managing Director at Secretariat. At the time of this engagement, Chris was a Senior Managing Director with FTI Consulting. ↩︎
7. Independent Directors of the Board of Wells Fargo & Company - Sales Practices Investigation Report, p. 6 ↩︎
8. Wells Fargo Confirms that the Federal Reserve Has Removed the Limits on Growth in Total Assets Imposed in its 2018 Consent Order and Announces a Special Employee Award ↩︎

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