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- Wells Fargo's Asset Cap Might Lift by mid-2025, if compliance is maintained
Wells Fargo's Asset Cap Might Lift by mid-2025, if compliance is maintained
Wells' full lending may squeeze industry margins

Wells Fargo announced that the CFPB has ended its 2018 consent order on the bank's compliance risk management. This is the twelfth consent order lifted since 2019 and the sixth in 2025, highlighting significant progress in resolving regulatory issues.
The 2018 CFPB consent order was one of several regulatory actions imposed on Wells Fargo following a series of scandals, most notably the 2016 “fake accounts” incident.
The order targeted deficiencies in the bank’s compliance risk management and required Wells Fargo to overhaul its internal controls and risk infrastructure. The Office of the Comptroller of the Currency (OCC) had issued a parallel enforcement action, which was terminated in February 2025.
“Today’s termination, along with the recent closure of other consent orders, demonstrates that we have completed much of our common risk and control infrastructure work, including work that is required by other orders. I am proud of the work done by our teams and remain confident that we will complete the work needed to close our other open consent orders”
Impact and Next Steps
The termination of this consent order is widely viewed as a key milestone in Wells Fargo’s regulatory rehabilitation. Analysts suggest that this progress could accelerate the lifting of the Federal Reserve’s asset cap, which has limited the bank’s balance sheet to $1.95 trillion since 2018. The asset cap remains one of the most significant restrictions, and its removal would signal a return to full regulatory normalcy for the bank.
Currently, Wells Fargo still faces two outstanding consent orders: one from the OCC related to violations of the Gramm-Leach-Bliley Act and a formal agreement regarding anti-money laundering controls. The bank’s leadership has expressed confidence in resolving these remaining issues.
Market and Regulatory Outlook
The lifting of the CFPB’s consent order has bolstered investor optimism, with some analysts predicting that the Federal Reserve could lift the asset cap as early as the second quarter of 2025.
However, some lawmakers and advocacy groups urge caution, emphasizing the need for continued scrutiny of Wells Fargo’s risk management practices before all restrictions are lifted.
In summary, the CFPB’s termination of the 2018 consent order represents a significant step forward for Wells Fargo as it seeks to move past years of regulatory scrutiny and restore its standing with both regulators and investors.
Source: reuters.com, bankingdive.com, businesswire.com
Our Opinion
If Wells Fargo's asset cap is lifted by Q2 2025, alternative lenders have 6-9 months to prepare for increased competition as the bank re-enters certain lending markets aggressively.
Wells might target profitable, low-risk borrowers with strong cash flow, 700+ credit scores, and 3+ years in business, aiming to attract customers from private lenders by offering rates 2-4% lower.
They might focus on professional services, healthcare practices, and established manufacturing, maintaining strict documentation requirements. Businesses under 2 years old, those with recent credit issues, and high-risk sectors like restaurants and retail will be avoided.
Lenders should prepare retention plans for A+ customers before Wells sends pre-approval offers. This regulatory change poses a competitive threat to key customer segments within 9 months, but you have time to prepare.
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