Wells Fargo & Company

According to the complaint, defendants made materially false and/or misleading statements, as well as failed to disclose material adverse facts about the company’s business, operations, and prospects. Specifically, defendants allegedly failed to disclose to investors that:

(i) Wells Fargo had misrepresented its commitment to diversity in the company’s workplace;
(ii) Wells Fargo conducted fake job interviews in order to meet its Diverse Search Requirement*;
(iii) the foregoing conduct subjected Wells Fargo to an increased risk of regulatory and/or governmental scrutiny and enforcement action, including criminal charges;
(iv) all of the foregoing, once revealed, was likely to negatively impact Wells Fargo’s reputation; and
(v) as a result, the company’s public statements were materially false and misleading at all relevant times.

*as described in the complaint as “a diverse slate hiring policy, requiring that at least 50% of interview candidates must represent a historically underrepresented group with respect to at least one diversity dimension (including race/ethnicity, gender, LGBTQ, veterans, and people with disabilities) for most posted roles in the U.S. with total direct compensation greater than $100,000 per year.”