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Government Relations and Public Policy

Like many companies, Wells Fargo engages in public policy advocacy on issues that impact our business at the local, state, and federal levels. We believe that participating in the public policy process helps protect our customers, employees, and businesses, and is an important part of responsible corporate citizenship.

Governance and oversight

The Government Relations and Public Policy (GRPP) team is responsible for managing development and execution of strategies that advance our public policy priorities. The Head of GRPP reports to the Vice Chairman of Public Affairs, who is a direct report to the Chairman and CEO.

The Corporate Responsibility Committee (CRC)(PDF) of the Wells Fargo Board of Directors oversees the Company’s significant Government Relations strategies, policies, and programs. At least annually, the CRC receives an update from the head of GRPP on the alignment of the Company’s political activities and contributions, significant lobbying priorities, and principal trade association memberships with the Company’s public policy priorities.

Advocacy and lobbying

Lobbying enables Wells Fargo to advocate for a broad range of public policy issues that are important to the Company. GRPP works closely with the lines of business and enterprise functions to determine the company’s public policy positions and then works to communicate those positions with government policymakers, public officials, and regulators at the federal, state, and local levels to promote and advance those public policy positions.

At least annually, the Corporate Responsibility Committee (CRC) of the Wells Fargo Board of Directors receives an update from the Wells Fargo Head of Government Relations and Public Policy on the significant public policy priorities to the Company and where the Company has chosen to focus its engagement with government officials.

The Company complies with federal, state, and local laws concerning lobbying registration and reporting. Wells Fargo's lobbying disclosure reports provide an overview of the Company’s legislative and policy priorities and amounts spent on such efforts at any given time.

Copies of federal lobbyist disclosure reports are available on the U.S. House website. You can also access copies of state and local disclosures on our 2023 State and Local Lobbyist Disclosure Reports (PDF).

Wells Fargo does not engage in direct grassroots lobbying. If we do engage in direct grassroots lobbying in the future, we will disclose such activity where and as required by law.

Campaign finance and PACs

Wells Fargo's political action committees (PACs) are funded by voluntary contributions from eligible employees and directors and support candidates for elected office who understand the important role the financial services industry plays in the economy.

Decisions about which candidates the PACs support are made by the Government Relations and Public Policy (GRPP) team using established criteria to guide decision-making. This criteria includes supporting candidates who:

  • Represent the communities where we have a large presence;
  • Understand the important role the financial services industry plays in the economy;
  • Are in legislative or political leadership roles;
  • Serve on important committees that have jurisdiction over issues that impact the financial services sector.

The PACs review candidates based on the totality of their positions on matters important to the Company. A Wells Fargo PAC contribution is not an endorsement of a candidate; Wells Fargo will not always agree with every vote, stance, or action taken by candidates the PAC supports and it is impossible to predict the future actions of a lawmaker. Previous support does not mean the Wells Fargo PAC will support a candidate in the future.

The PAC reviews its budget, contributions, (and approach to giving) on an ongoing basis. All Wells Fargo PACs report to the Federal Elections Committee and/or to state agencies as required by law. Wells Fargo publishes a summary of our most recent campaign disbursements (PDF) of the Wells Fargo Employee PACs. This report is updated annually.

At least annually, the Corporate Responsibility Committee (CRC) of the Wells Fargo Board of Directors receives an update from the Head of Government Relations & Public Policy (GRPP) on Wells Fargo’s political action committees.

Past reports

Corporate political spending

Wells Fargo does not use company money or resources to influence any U.S. domestic or foreign candidate elections, including assisting candidate campaign committees, political parties, caucuses or independent expenditure or other political committees, or any other type of election-related activity. If, in the future, we change our policy on independent expenditures we will disclose those expenditures on our website, and also present them to our Board of Directors for review.

Wells Fargo may contribute to entities organized under Section 527 of the Internal Revenue Code ("527 organizations") but payments may only be used for operational and administrative purposes, not to support or oppose any candidate for U.S. federal, state, or local office, or to support or oppose any ballot initiatives. Additionally, payments to 527 organizations may not be transferred to any federal, state, or local PAC, any other form of political committee, or any other entity for the purpose of making contributions or expenditures, independent or otherwise, to support or oppose any candidates for U.S. federal, state, or local office, or to support or oppose any ballot initiatives. GRPP obtains attestation letters from 527 organizations receiving support confirming that all payments will be used in a manner that is consistent with restrictions on political activity under federal, state, and local law and that the payments will not be used for the activities listed above. View the current list of contributions to 527 organizations (PDF), which is updated annually.

Additionally, Wells Fargo may make contributions for ballot initiatives that could affect its business operations. When Wells Fargo makes these types of ballot initiative contributions, it does so to promote the interests of the company without regard to the private political preferences of Wells Fargo’s executives. On a periodic basis Wells Fargo will disclose the amount and recipient of ballot initiative contributions over $25,000, which may include a 501(c)(4) organization. View the list of contributions for ballot initiatives over $25,000 (PDF).

Past reports

Participation in trade association and independent groups

Wells Fargo is active in many financial services industry and general business trade associations. Trade groups often determine industry public policy consensus but our participation in these groups comes with an understanding that we may not always agree with every position taken. In instances where we disagree with trades of which we are members, we are committed to sharing our perspective in a constructive manner, working within the organization’s structure toward greater alignment on policy issues important to Wells Fargo and our stakeholders.

Decisions about our involvement with public policy-oriented trade groups are made by Government Relations and Public Policy and business and enterprise functions leaders. Wells Fargo’s trade association memberships are approved initially and annually thereafter by the head of GRPP to determine whether membership is warranted based on the company’s evolving business goals and strategies. At least annually, the Corporate Responsibility Committee (CRC) of the Wells Fargo Board of Directors receives an update from the Head of Government Relations & Public Policy (GRPP) on the Wells Fargo’s principal public policy-oriented trade association memberships.

We prohibit trade associations and groups of which we are a member from using our corporate funds for campaign and election activities. We inform these organizations of our policy prohibiting the use of membership dues and fees for contributions to candidate committees, independent expenditure committees, or other direct or indirect contributions to election campaigns, and expect them to adhere to it. We are not members of any tax-exempt organization in the U.S. that is primarily organized to write, endorse, and promote model legislation.

Wells Fargo publishes a list of the principal financial services industry trade associations that received membership dues from Wells Fargo and its subsidiaries. Based on information reported to us, the amount of dues designated by the organizations as attributable to Wells Fargo and used for lobbying was approximately $1.7 million during the most recent membership period. Here is a list of our principal financial services industry trade associations (PDF) and the percentage of membership dues spent on lobbying, as reported to Wells Fargo by each organization.

Compliance

Wells Fargo is committed to complying with all applicable laws regarding political contributions, including MSRB Rule G-37, SEC Rule 15Fh-6, SEC Rule 206(4)-5, CFTC Rule 23.451 and applicable state and local restrictions and limits. We have policies and procedures in place consistent with this commitment. Wells Fargo maintains compliance processes intended to ensure that its activities are conducted in accordance with those policies, our Code of Conduct, and with all relevant laws governing political contributions and lobbying activities.

Team member activity

Wells Fargo’s Code of Conduct encourages employees to engage in civic and political activities on their own time based on their individual desires and political preferences but not representing Wells Fargo. Employees may not engage in any political activity during work time or using Wells Fargo property to conduct such activity, and they cannot be reimbursed for any campaign contributions made from personal funds. Employees are free to make personal contributions on their own behalf to candidates and related political entities of their choice as long as they comply with the Code of Conduct and any applicable policies. Personal political contributions made by employees reflect their own beliefs and not those of Wells Fargo.