According to the Complaint, Wells Fargo & Company is a financial services company that provides a range of products and services, including banking, insurance, investments, mortgage, leasing, credit cards, and consumer finance. The Company operates through physical stores, the internet, and other distribution channels worldwide.

The Complaint alleges that throughout the Class Period, Defendants made materially false and misleading statements, and failed to disclose material adverse facts about the Company's business, operational, and compliance policies. Specifically, the Complaint alleges Defendants made false and/or misleading statements and failed to disclose to investors that: (i) Wells Fargo had inadequate disclosure controls and procedures and internal controls over financial reporting, particularly with respect to its risk and compliance management, policies and programs; (ii) the Company was not compliant with the regulatory consent orders entered into in 2018; (iii) the Company's remedial plans were inadequate, incomplete, and insufficient to prevent from future consumer abuses; (iv) as a result of the continued noncompliance with the regulatory consent orders, the Company was threatened with supervisory and/or enforcement actions and penalties; (v) the Company's remedial measures and risk and compliance management remained inadequate to protect against consumer fraud; (vi) as a result of the foregoing, Defendants' positive statements about the Company's business, operations, and prospects were materially misleading and/or lacked a reasonable basis and omitted materials facts.