Cp-16-002959
SETTLEMENT AGREEMENT This Settlement Agreement is made and entered into as of the 28th day of December 2018 (hereinafter, "Effective Date"), by and between the Attorneys General of Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, District of Columbia, Florida, Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin and Wyoming' (the "Attorneys General"), on the one hand, and Wells Fargo & Company, acting for Wells Fargo Bank, N.A. and their current and former parents (collectively, "Wells Fargo"), on the other. WHEREAS, the Attorneys General conducted investigations of the following issues: (i) Sales practices related to consumer and small business checking and savings accounts, credit cards, unsecured lines of credit, and online bill pay services for which Wells Fargo Community Bank employees could qualify for incentive compensation credit; (ii) Sales practices related to renters and simplified term-life insurance products referred to American Modern Home Insurance Group, Inc. ("AMIG"), Assurant, Inc. ("Assurant"), Great West Life & Annuity Insurance Company ("Great West"), and Prudential Insurance Company of America, Pruco Life Insurance Company and Pruco Life Insurance Company of New Jersey (collectively, "Prudential") by Wells Fargo Insurance, Inc. and/or Wells Fargo Community Bank for which Wells Fargo retail bank employees could qualify for incentive compensation credit; With regard to Maryland, any references to the Attorney General or Attorneys General shall mean the Consumer Protection Division, Office of the Attorney General of Maryland.
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