Climate Finance Policy Engagement Analysis
Climate Lobbying Overview: Wells Fargo appears to have limited transparent direct engagement on climate-related policies, with generally supportive top-line messaging on climate.
Top-Line Messaging on Climate-Related Finance Policy: In its 2022 TCFD Report Wells Fargo stated support for action to achieve net zero by 2050 and in December 2023 congressional testimony CEO Charlie Scharf stated support for the goals of the Paris Agreement. In its 2024 Climate Report Wells Fargo reported engaging with policymakers on climate-related issues, but details of this engagement are unclear.
Position on Regulated Corporate Climate Disclosure: In a comment letter to the SEC in 2022, Wells Fargo outlined significant objections to the Commission's proposed climate disclosure rule, characterizing disclosure requirements as "overly prescriptive" and encouraging increased flexibility in emissions disclosures. In its 2022 CDP response, Wells Fargo stated that it supported the SEC’s climate disclosure rule “with major exceptions,” and in its 2022 TCFD Report it stated that it offered “support and constructive feedback” to the SEC on the proposal. According to California lobbying disclosures, in 2023 Wells Fargo lobbied on SB 253 and SB 261, California’s emissions and climate risk disclosure bills. Details of this engagement are unclear.
Position on Incorporating Climate Factors Into Investor Duties: According to Iowa lobbying disclosures, in 2023 Wells Fargo opposed HSB 180, a bill that sought to discourage ESG investing by limiting state contracts with financial institutions that “boycott” fossil fuel companies.
Position on Incorporating Climate Factors Into Risk Management/Prudential Regulation: According to Wells Fargo’s 2022 TCFD Report, it engaged via trade associations with US banking regulators on proposed climate risk management principles. A 2022 memo from the Office of the Comptroller of the Currency (OCC) shows that Wells Fargo, as constituents of the Bank Policy Institute, met with the OCC to outline “challenges” to its draft principles for climate-related financial risk management. According to Iowa lobbying disclosures, in January 2024 Wells Fargo lobbied on SSB 3094, a bill that seeks to prohibit financial companies from using ESG factors in risk management. Details of Wells Fargo’s engagement are unclear.
Position on Energy, Industry, and Land Transitions: Wells Fargo appears generally supportive of the transition of the energy mix. In its 2022 CO2eMission Methodology report, Wells Fargo appears to support decarbonization of the power sector, and in its 2023 CO2eMission Supplement it broadly supported electrification of transport. Also in its 2023 CO2eMission Supplement, Wells Fargo appeared supportive of policies promoting Sustainable Aviation Fuels (SAFs), including fuel blending mandates and low-carbon fuel standards.
In its July 2023 Sustainability and Governance Report Wells Fargo stated that it engaged with policymakers on the Inflation Reduction Act (IRA) to “inform program design” and encourage “effective implementation” but details of this engagement are unclear. Wells Fargo has appeared supportive of the IRA’s climate investments in its 2024 Climate Report.
Industry Association Governance: Wells Fargo has disclosed a list of its "principal" industry associations but appears to exclude more than 3 industry associations which are engaged on climate-related policy including the Association for Financial Markets in Europe, the Canadian Bankers Association, the International Swaps and Derivatives Association, and the Greater Boston Chamber of Commerce. Moreover, Wells Fargo's disclosure of its industry associations' activities is limited to top-line climate statements.
InfluenceMap collects and assesses evidence of corporate climate policy engagement on a weekly basis, depending on the availability of information from each specific data source (for more information see our methodology). While this analysis flows through to the company’s scores each week, the summary above is updated periodically. This summary was last updated in Q4 2024.