Mulligan

This is a straight compliance piece, where a corporation is held liable for the misdeeds of its employees (agents).

“Wells Fargo to Pay $3.4 Million Over Advisers’ Flub,” The Wall Street Journal, October 17, 2017 B10.  Apparently, some of the bank’s financial advisers recommended volatility ETFs when they shouldn’t have.  The advisers also didn’t have adequate training.

This is straightforward.  Should some manager be fired or disciplined?  Maybe.  This would not seem the type of event that calls into question the Board’s duty to supervise, unless this is the third time this same compliance issue has arisen.  This is only the second time.  The bank paid nearly $3 million in fines and restitution in 2012 for a similar violation.

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Filed under Board, Compliance, Compliance, Compliance Verification, Controls, Corporation, Directors, Duty, Duty of Care, Employees, Governance, Internal controls, Oversight, Oversight, Requirements

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