Wells Fargo & Company (WFC) Earnings Call Transcript & Summary

June 15, 2021

New York Stock Exchange US Financials Banks conference_presentation 37 min

Earnings Call Speaker Segments

Betsy Graseck

analyst
#1

Thank you, everybody, for joining us for day 2 of Morgan Stanley's U.S. Financials, Payments & CREEC Conference. I'm going to read a quick disclosure, and then we'll get into it. For important disclosures, please see Morgan Stanley research disclosure website at www.morganstanley.com/researchdisclosures. And if you have any questions, please reach out to your Morgan Stanley sales representative. So today, we are thrilled to have, as kickoff for day 2, Mike Santomassimo, CFO of Wells Fargo. Mike, thanks so much for joining us today.

Michael Santomassimo

executive
#2

Thanks, Betsy. Thanks for having me.

Betsy Graseck

analyst
#3

So I just wanted to kick off with a couple of questions regarding your role as CFO. Why did you take it? What are you hoping to accomplish? I know you kicked off just a few quarters ago, so help us understand that.

Michael Santomassimo

executive
#4

Yes. No, it's great. Look, it was an easy answer -- easy decision for me to come to Wells. And I think when you look at the businesses we have, it's going to be a special set of stuff, right? And that's really almost impossible to replicate. And you look at the position in the consumer space in terms of 1 in 3 households, 70 million total clients, #1 share in commercial banking, and you can go on and on and on in terms of the collection that we've got here. And I think as we sort of get these businesses to work together better, the opportunity should be really significant over a long period of time not only to do more as Wells Fargo but also have a pretty big impact in the communities we operate. So it was an easy one for me to want to be part of that.

Betsy Graseck

analyst
#5

Okay. So a lot of opportunity ahead.

Michael Santomassimo

executive
#6

Yes.

Betsy Graseck

analyst
#7

One of the things that you were able to accomplish pretty quickly is to get those new segment disclosures out and kind of retool how you go to The Street with your financials, so to speak. I guess I wanted to understand, over the longer term, what some of the more attractive revenue opportunities are that you see in the various segments. And maybe you could speak to the investment priorities as well.

Michael Santomassimo

executive
#8

Yes. First, I would say across the place, like our agenda is really clear, right, in terms of what we need to focus on to get at some of those opportunities. First, it was really making sure the management team was in place and at all levels of the company, and Charlie has got a lot of impact there. It's the risk and reg agenda build-out and finishing that work. It's really making sure that we've got the right collection of businesses that is part of the company, and you've seen us sort of take some action there. And it's really -- I'd say it's really making sure that we find all the opportunities that we have, both become more efficient but also to invest across each of the franchises and take advantage of the opportunity that we have there. As you sort of look across some of these segments on the consumer side, it starts with just driving really deeper engagement across those customers, both on the mortgage side where we've got a lot of opportunity to continue to do more for our client base. It's the card business where you've seen us make some announcements across improving both service and sort of the product suite we've got there. It also involves sort of the digital capabilities that we're looking to continue to refresh as we sort of get towards the end of the year. And then I'd also say on the consumer side, it's going after the affluent opportunity on the wealth management side, where it just really hasn't been a focus. Even though we really have all the pieces, we have the investment offering, we have all the things we need as part of our wealth business, it just hasn't really been a big focus. On the commercial side, it starts with really taking advantage of sort of the scale businesses we have, providing Investment Banking services to our commercial bank clients where we've had decade-long relationships and have all the capabilities. It just takes some focus around how we cover those clients. And then more broadly, in the commercial bank, although we've got really great share across the country, there are plenty of markets where we've got growth opportunity both in geographies but also segments across the country. So over time, there should be a lot of opportunity for us to continue to take advantage of that.

Betsy Graseck

analyst
#9

So one of the outlooks that you're suggesting you should be able to deliver on to The Street is an improving expense ratio over time. Can you walk us through some of the opportunities for the expense improvements in each of the segments, what the key drivers are, what type of time frames are we should be thinking about?

Michael Santomassimo

executive
#10

Yes. No, look -- and this is a multiyear journey to get more efficient, right? It doesn't happen in a quarter or 2. And it really starts with like how do you make sure we have a better-run company. We removed the bureaucracy. We put the client first. We improved sort of the experience that we have there through automation and other sort of mechanisms. And so as you sort of look at that, that gives us sort of -- as you look at the detail behind, it gives us sort of confidence that we can sort of get at it. And when you sort of break it down, 1/3 of it comes from really just optimizing the place. We're moving levels, moving spans and layers across the company and just general optimization of sort of how we manage the place. About 20% of it is going to come from continuing to optimize the consumer banking business. A little part of that is driven by branch closures, but really, it's optimizing staffing across the remaining 5,000 branches, which is a bigger part of that as clients move more of their volume to digital channels in particular. I think as you look at Commercial Banking, it's making sure that we've got our coverage model aligned properly, which not only is going to save us money but also is going to put the best and most resources against our best and most profitable and biggest clients, which should help drive growth there. On the Consumer Lending side, it's really about automating and creating a best-in-class client experience with that automation. And I think given our scale in that business across, whether it's autos or mortgages or cards, we should be able to do that quite effectively. And if you look at where some people have done well, it's really the nonbank providers that have done the best job at creating that client experience, and there's no reason why we shouldn't be able to make some pretty big strides there over time. In Commercial Banking -- I talked about Commercial Banking. And then lastly, I'd just say it's really everything else. Think about real estate, our third-party spend in many areas really where we think we can get optimization. And having said that, we are going to continue to make sure we spend whatever it takes in sort of the risk and reg agenda. And despite that, we still think there's plenty of opportunity for us to get at over the next few years to bring expenses down.

Betsy Graseck

analyst
#11

So when I'm thinking about the opportunity set within the different segments, it looks like, relative to peers, the biggest opportunity set in the expense ratio side is going to be coming from consumer, wealth and a little bit Commercial Banking. Would you agree with that?

Michael Santomassimo

executive
#12

Well, I think all of the segments have opportunity. And I think it's a little more, a little less depending on where they stand relative to the peers today. But every single one of them is not as efficient and has opportunity to get better relative to kind of best-in-class peers, and we're focused on really making sure all of them do a better job at that.

Betsy Graseck

analyst
#13

Okay. And then just lastly on this for me is when I'm thinking about the investment bank, there is, it looks like, a pretty efficient platform right now today. Maybe you can talk a little bit about what's in there that differentiates you from peers in that regard and where you're seeing the investment bank investment spend from here. We get a lot of questions from investors on that.

Michael Santomassimo

executive
#14

Yes. If you look at corporate and investment bank, we've really got 3 big components to it. One is the commercial real estate business, which we've got scale in and continue to have a really great business there. We've got our Investment Banking business, which is modest, I think, in size relative to the peers. And I think that's a big opportunity for us, particularly in sort of the middle market space, as I mentioned. I think we're not going to go try and compete globally with folks there, but I think as you sort of look at who our core client segment is, it provides a lot of opportunity to grow that business over time. And I think you -- we're adding people there. We're attracting good people to the platform. We've added a bunch already this year and are continuing to do that in the right spots. And then I think you've got our markets business, which is really meant to be something that helps support the rest of the franchise across, whether it's in the FX rates or other products there. And I think you'll see us continue to do more there. But again, we're not going to go try to compete globally with many of the peers, so we'll be very targeted in terms of our investments.

Betsy Graseck

analyst
#15

Okay. That's super helpful color. So when we put together the investment spends you're making, the expense improvements that you're anticipating, how are you thinking about the return targets that you outlined at the start of the year, especially as you have more line of sight here on both expenses and capital return?

Michael Santomassimo

executive
#16

Yes. Look, I think there's no reason our business mix and the businesses we have can't produce those types of returns over time. And I think where we're focused now is really executing on the things we can control, which is the efficiency agenda that we've got. Hopefully, we'll start to be able to return more capital to shareholders starting in the third quarter. That is a priority as well. And I think with those 2 things, you start to make a good first step in terms of achieving those returns. I think to get to peer returns over time, we're going to need the asset cap lifted, we're going to need some modest increase in rates, we're going to need some benefits from some of the investments we're making. But there's nothing that we found in the model or businesses so far that don't think -- that don't lead us to believe we can't get there over time. But it will take time to do it.

Betsy Graseck

analyst
#17

Okay. Got it. Well, to me, it seems like there would be some opportunity in the stock if the market agreed with you because we do have in our 2025 EPS, your 15% ROE goal. So -- and the stock is trading right now today with something like a 13.5% cost of equity on that basis. So it feels like you'll be rewarded if you get it done.

Michael Santomassimo

executive
#18

We're just focused on getting the work done, and I think the stock will take care of itself.

Betsy Graseck

analyst
#19

All right. Let's look at credit. I think Charlie said last week or so that the reserve release should be substantial, and he's referring to 2Q. Could you give us a sense as to some context how big substantial is?

Michael Santomassimo

executive
#20

Yes. Well, look, I think the good news underneath that is that clients are in really good shape, both on the consumer side and the commercial side. And you can see that coming through in charge-off rates, particularly over the last couple of quarters, but even as you look into Q2. So I think that's the good news story, right, is that clients are doing really, really well, both from the liquidity they have but also sort of how they're sort of managing through the pandemic. I think as you sort of think about the go-forward from here in terms of the economic scenario, it continues to look really good. There are certainly risks there, and so you sort of have to be mindful and think about those risks as you look at your overall allowance. But as you sort of look at that, I think it leads you to further releases. We're not quite done with the work yet for the quarter in terms of exactly what that quantum is going to look like, but it will be -- as Charlie said, it will be significant. But we'll finish that work and we'll see it at the end of the quarter.

Betsy Graseck

analyst
#21

And then just generally on credit, overall, your credit box relative to pre COVID, where would you say it is now?

Michael Santomassimo

executive
#22

Pretty close to being back to where we were. There's a couple of small exceptions related to that and deep down in a couple of businesses, but for the most part, we're back to where we were. Some of that's more recent as we turn back on correspondent nonconforming originations in the latter part of the first quarter. And so we sort of looked at the auto business a bit over the last number of months, but we're pretty darn close to where we were pre COVID. And as you sort of look at widening the credit box, I think we really need to look at this over a cycle, right? And I think getting -- starting to substantially change the approach in an environment like this, just I think we would regret that later, and it's just not who we are and how the credit process works here. And so we really look at being more consistent over a long period of time. And so we're pretty close to where we were.

Betsy Graseck

analyst
#23

Okay. Got it. Let's talk a little bit about the balance sheet and managing the balance sheet first with the context of the asset cap. How much of a challenge is it to operate the balance sheet with this asset cap?

Michael Santomassimo

executive
#24

Well, look, the first couple of years of it being in place really wasn't constraining for the company. It's really as you sort of got into the beginning parts of the pandemic where you started to see the pressure mount. At first, it was both on the liability and the asset side, as you saw big draws and changes on the asset side. The asset pressures have would be abated significantly -- quickly abated significantly since March and April last year. And so really, the constraint is on the liability side, which means like the level of deposits you can take in from clients for the most part. And as you look at it, we've had to make some really hard decisions over the last year, year plus. We've reduced our capital markets balance sheet by approximately $75 billion, big financing trades and stuff between both sides of the balance sheet down, low ROA stuff, but something that is accretive in an environment like this. We've probably taken down deposits $180 billion, mostly in the commercial -- the corporate and investment bank but also our commercial bank as well. And so it's been significant in terms of the impact it's had and the decisions we've had to make. Having said that, like not all growth is dependent upon the asset cap. A bunch of the areas that I highlighted earlier are focused on growing fees that don't require huge increases or increases in the liability side at all. We also have plenty of capacity to be there for clients on -- when they need credit, both on the consumer and commercial side. And so we feel like we've got plenty of opportunities to continue to focus on growth. But the asset cap has been -- has forced us to make some tough decisions to help clients move off deposits into other vehicles.

Betsy Graseck

analyst
#25

So I'm sure it's something that's on the top of the list, well, you've mentioned it many times about doing what you need to do to move forward, address regulatory concerns and do the work you need to do to answer those questions and then get the removal of the asset cap at some point. But the one question we get a lot is, well, what is left to do. So maybe you could just remind us some of the major areas that Wells needs to address. And are these static goals? Or do these goals -- is it a shifting goal post situation that you're dealing with? And ultimately, has this list of to-dos declined yet?

Michael Santomassimo

executive
#26

Yes. Look, I would say that there's a lot of data out there in the public realm around the different consent orders. And I would say -- I remind people it's not just one, it's multiple consent orders that we need to solve. And they're interrelated, right, and they have impacts on each other. So I'm not going to try to rehash all of the components of those things, but what I would say is what we've got to get done is really clear. And now it's really just down to executing it, and as we sort of do that, the regulators will make their determination on when we're done. I would just point out, as I said, there's many of these -- there's a bunch of these things that sort of work together. So I'm sure we're going to have setbacks along the way. I'm sure it is not going to work in a straight line. It never does when you're remediating stuff like this. But the urgency is there, the discipline's there, the focus from the whole management team is there, and we're just working issue by issue, week by week to make sure we've got to deliver on it. And what we've got to get done is clear.

Betsy Graseck

analyst
#27

And given the liquidity pool you do have, it's not like it's limiting your ability to lend.

Michael Santomassimo

executive
#28

No. I think when you look at the balance sheet, as I said, we've got flexibility, plenty of capacity to lend to clients when they need it. I think it's a demand story now more than it is an ability to do it. And I think we feel like we've got that flexibility. The constraint for us, as I said, is really on the liability side and the level of deposits that we've got.

Betsy Graseck

analyst
#29

Okay. I do want to remind people, if they have questions, you can type them into your browser. In the meantime, I'm going to move on to balance sheet and liquidity. So the question here is really one of the ones we're dealing with, with a lot of folks during this conference, which is rates. The front end of the curve fell again this past quarter, and then we also had the long end pull back as well. Could you give us a sense as to how this rate decline this quarter is impacting you?

Michael Santomassimo

executive
#30

Look, on the front end of the curve, like at this level, small moves are -- they're impactful but not really. They're not super significant in terms of having an impact on us right now. I think it will be -- the front end of the curve is going to be much more important as we start to see the tightening cycle start, and that's where you're going to -- given both loans and the way adjustable-rate loans work -- floating-rate loans work as well as deposit pricing. So that's where it's going to be much, much more meaningful. As we sort of think about where we're investing, the longer end of the curve is what matters more, I think, as we look at our reinvestment pace there. And as you noted, that's come down since the beginning of the quarter. And there's a lot of -- it does impact your deployment base of how you're going to reinvest into the securities portfolio.

Betsy Graseck

analyst
#31

Okay. So the question -- the follow-up there is the excess liquidity that you have. It's pretty significant. And how do you decide what to do with it, whether to reinvest, whether to sit on IOER and wait it out? Can you give us a sense as to how Wells thinks through that dynamic?

Michael Santomassimo

executive
#32

We try to be very disciplined about this, right? And you're balancing sort of the carry that you're going to get in the short run with all of the long-term earnings and the OCI risk that's going to come with that and so forth. And so we try to look at both the rate outlook that's there, our rate outlook and what we hear from others, sort of how we're positioned from a balance sheet perspective, and take that into account. And as you look back, as rates were sort of coming down last year, we slowed the pace of reinvestment. So that does give us plenty of dry of powder. We have started deploying it a little bit, I'd say modestly in the first quarter as we added a little over $8 billion to the securities portfolio. And I think we'll continue to do that in a modest way as the opportunities that are there. But look, long rates have come down, as you said. They're still historically really low. Credit spreads are still pretty tight. And so we want to be patient about how we do that. And I think given kind of the medium-term outlook of the way things are trending, we think we'll have better entry points to deploy more. And as you say, it's significant, but you want to make sure you're optimizing sort of over a longer period of time, not just the next couple of quarters.

Betsy Graseck

analyst
#33

Now if the asset cap were to go away, would that change how you're thinking about the redeployment? I mean one of the reasons -- I get this question from people as well. Then you could bring in deposits more rapidly, and with that deposit growth, maybe ladder more aggressively the securities book. But I'm wondering how you think about that.

Michael Santomassimo

executive
#34

Yes. Look, that's part of -- maybe part of it. But I think when you look at -- we've got plenty of flexibility now to do things, and as you said, we got tens of billions of what -- liquidity that we can deploy. And so you're taking that into account. But I'd also point out, as you've sort of seen us over the last year or so, the composition of our deposit base has started to remix as well. So we've seen a 25% increase of consumer deposits, which are the least rate sensitive, stickiest, right? So as those sort of mature and age in, like that actually gives us more capacity to invest over time. And we've seen an offset of, call it, 15% decrease in the most rate-sensitive deposits and the least stickiest over time. And so even just that recomposition of the deposit book, I think, gives us more capacity to deploy when we feel it's the right time. And like I said, we feel like we've got plenty of flexibility now. It's just making sure that we optimize what we do as best we can.

Betsy Graseck

analyst
#35

Okay. Let's turn to loan growth. And maybe you could give us some sense as to how you're thinking about what you've got right now. Is there opportunity to incent more? We already talked about the credit box feels -- it sounds like you're fine where you are in the credit box, and so you're not going to be widening the credit box to incent more loan growth. But give us a sense as to what you're doing to grow the business.

Michael Santomassimo

executive
#36

Yes. And I'll sort of move you through the pieces, right? So if you look at it where we are relative to March, overall loans are down. And commercial loans are kind of stable. I think we could be up a little, down a little, depending where we -- how it shakes out over the last few weeks overall, but they're not growing yet. And there's lots of reasons for that, right? High levels of liquidity, low inventory levels across many different sectors of our clients, supply chain issues increasingly sort of being part of that equation. So at some point, that will turn, and we'll start to see more demand there. And I would just point out that this is impacting like really all size of clients. It's not just the big guys. It's the little ones as well. We're seeing very similar themes that are impacting that. I think we are seeing some encouraging signs around the pipeline in conversations with clients, but it's still early, I think, to really see that come through on the commercial side at this point. On the consumer side, loans are down, which is where we expected, mostly driven by mortgages. Some of that's the prepayment activity that we've seen. Some of that is driven by the resecuritization of some loans we bought last year. I'd say one small positive in the mortgage book is our wealth clients, where those loans are kind of flattish as we sort of look forward. So I think that's encouraging but a relatively small piece. And then really everything else in the consumer side is sort of flattish at this point. Auto is up a little and others bouncing around. I think the good news underneath that is we are seeing really good spend in the card space. And obviously, comparisons to last year are a bit distorted. So if you look at it relative to 2019, I think for the week -- I think it was last week or the week before, we're up almost 30% on debit card spend, double digits on credit card spend in many of the areas that have been most impacted by the pandemic. So I think that's encouraging. But as you've seen across the industry, even in the card space, although spend's up, payment rates are up too, and so not translating to growth at this point. And so we'll see how that shakes out in the second half of the year.

Betsy Graseck

analyst
#37

Okay. There's some other questions on lending, but we can get back to that if we have time at the end. I wanted to turn to more the near-term outlook that you've got. When you pull together what's going on with the interest rate environment, the loan book, how you're trajecting on your efficiency opportunities, et cetera, and just really sticking on the top line, how do you feel about your NII outlook and how it trajects from here?

Michael Santomassimo

executive
#38

Look, at this point, where we stand, like the range we've been talking about of down 0 -- that flattish to down 4% versus Q4 annualized is still the range that we think we'll fall into at this point. I think the biggest win factor continues to be loans and whether we see growth. And as I said, loans are down so that's helpful yet. I think we're all sort of hopeful for the second half of the year, but we'll see how that plays out. Long-term rates are also an important piece of the puzzle here, and we've seen those come down since we last sort of talked about this. So I think there's a lot of time left to play out in the year, but we still think that range is where we'll fall in.

Betsy Graseck

analyst
#39

So the 0 -- this is flat to down 4% year-on-year, full year '21 versus full year '20?

Michael Santomassimo

executive
#40

Down 0 -- flat to down 4% versus the fourth quarter annualized.

Betsy Graseck

analyst
#41

Right. Okay. And so then the question is, for the down 4%, do you need loan growth to improve from here?

Michael Santomassimo

executive
#42

Look, I think it's -- there's a lot that goes into exactly where you're going to fall in the range. I think what we've said over the last couple of times is to get to the middle of the range, you needed overall loans to be sort of flattish. So that's what we said in April. And so that requires some growth from the commercial side. And so overall, loans are down right now. And so we'll see how that shakes out as we come into the third quarter or fourth quarter.

Betsy Graseck

analyst
#43

Got it. Okay. Would the infrastructure bill help at all with that loan growth, you think?

Michael Santomassimo

executive
#44

As you know, infrastructure builds are tough, right? They play out over a long period of time, right? I think they're talking 6 to 8, 10 years or so for that spending to happen. So on the margin, we'll -- maybe. I think we're already seeing pretty high demand in places -- in sectors like construction equipment as -- even now pre any kind of infrastructure bill. And so will it help on the margin? Maybe. But I don't think that's -- it's not a light switch kind of thing where you pass the bill and it starts to flow into the economy in a big way.

Betsy Graseck

analyst
#45

What about the supply chain? You were mentioning that earlier. Any signs of that coming back at all?

Michael Santomassimo

executive
#46

It's still tough, right? I think we're seeing -- we've got a bunch of businesses in our commercial bank where you can kind of see this very clearly where -- in our consumer products, as an example, think boats, RVs, snowmobiles, that kind of thing, where factories are seeing backlogs. Some of that's supply chain related. Some of that is just capacity to deliver against the demand they have. And so that's leading to dealer inventories being really low. And you can see that across the whole range of sectors. And so at some point, that will normalize. Exactly when, I think, is a hard thing to predict, but we'll see.

Betsy Graseck

analyst
#47

Okay. Second thing I wanted to dig in on a little bit of a nearer-term outlook is just how mortgage banking fees are going. You indicated that you're looking to lean into the market in a couple of different areas, including correspondent. At the same time, we've got some primary secondary spreads. It looks like they've been tightening, although it's been volatile recently. So maybe you could give us a sense as to how you're thinking about that line item, mortgage banking fees.

Michael Santomassimo

executive
#48

Yes. Look, we expect that we'll have a small increase in originations versus the first quarter, which I think is really driven by the retail space, less correspondent, more retail sort of driving that. You'll see a bit of a decline in the gain on sale as well. And so we'll see how that shakes out at the end of the quarter. When you think about primary, secondary spreads, and you probably know this, but as you look at where they peak, they peaked back in August. And they've been really coming down since then. And we would expect that they'll be back at sort of more historically normal levels, sort of think 80 to 100 basis points at some point. And the gain on sale will start to -- is correlated -- as we sort of look at that in the mortgage business, not always directly in any given period, but it will be correlated over time. And there's a few things that are sort of happening there. First is as you sort of think about primary and secondary spreads, part of that is driven by capacity to originate in the industry. Part of that is driven by demand for mortgages, right? And part of that is driven by the impacts on the secondary rate from a bunch of different factors. And what you've seen in the mortgage industry is people are adding capacity over the last year. They're being very competitive on rates, and that's part of what's been driving that primary, secondary spread down and any corresponding tightening of gain-on-sale margins. Now what you're starting to see is that as the Fed begins to even potentially talk or talk about talking about tapering, depending on how you want to characterize it, you're starting to see a slight widening of mortgage spreads. Not a lot yet, maybe 10 basis over the last couple of weeks or so, but -- and that's -- so that's going to have an impact as well on that spread. And so -- and I think that will start to have a bigger impact over time is that messaging and leads up to more tapering in the mortgage market.

Betsy Graseck

analyst
#49

Anything else on the quarter or the near-term outlook that you want to convey, maybe brokerage trading investment gains or expenses or any of the other line items there?

Michael Santomassimo

executive
#50

Yes. No, look, I think market levels are continuing to be helpful as you look at the advisory fees in our wealth business, so you'll see that. I'd just point out it is -- we bill many of those fees on a quarter in advance -- lag or a quarter in advance. So there's a bit of a lag to some of that as you sort of see that come through, but that's been really, really helpful. And as you sort of look at the market, that's been also constructive when you look at our private equity and venture businesses as well. And so you'll see a strong line item there as well for the quarter.

Betsy Graseck

analyst
#51

The question list is building on capital and dividend questions here. So we all know the SCB is going into play soon. You have a significant amount of excess capital. Charlie said last week, I think, something like 1 year-ish to get to your target of -- I think it's around 10%. Is that right on CET1? Is that the right...

Michael Santomassimo

executive
#52

Yes. I would think of it as 100 basis points or -- plus or minus with maybe a little bit of a buffer on top of that to whatever our regulatory minimum is, right? And as you know, CCAR, we're all going to -- CCAR is coming quickly. And as you sort of think about all the inputs to that, it's possible our stress capital buffer goes up. We'll see as the results come back. And it's really driven by the severity of the variables that they sort of gave us or the scenario they gave us for the quarter or for this submission. We're also expecting that our -- or we know that our GSIB score will go down in the first quarter of 2022. And so you'll have a little bit of a potential up and a down, and we'll see how that sort of shakes out. But in any event, we've got -- it's clear we've got a lot of excess capital that we hope we can start, in a prudent way, giving back to shareholders, assuming the restrictions come off in the third quarter.

Betsy Graseck

analyst
#53

So I get that you will find your regulatory minimum capital requirement in roughly a week's time, and then from there, you have the ability to really optimize pretty quickly. So one of the questions I've been getting is why not do some forward repurchases. Wells has done that in the past. Obviously, it was with a different management team.

Michael Santomassimo

executive
#54

Look, I think we've got to do this in a prudent way, right? And we're all under restrictions in the second quarter, right? So we're not buying. There's no ability to buy back shares now, right? And as you sort of look at the pace, like investors are one constituent. As you sort of look at the rest of -- we've got to think about all the risks that are still embedded in sort of the outlook for the economy and the world over the coming quarters. And as you know, when you have significant excess capital, it's not a -- you don't try to deliver it all back in a quarter. It just wouldn't be a prudent way to do it. And so as we sort of look at all of the -- it is a priority, and we'll do it in the right way with -- in consultation with the board. But we'll do it over time.

Betsy Graseck

analyst
#55

And is it something that you can imagine more than 100% payout ratio on a couple of quarters? I mean -- or are you limited, do you think, to your earnings level?

Michael Santomassimo

executive
#56

Yes. I think we've got -- under the stress capital buffer regime, I think we've got the flexibility to do what we think is prudent, right, and taking into account all the rest. And so it doesn't prohibit you from going over 100%.

Betsy Graseck

analyst
#57

And then just one of the other questions here coming in is regarding the dividend and how you think about setting that. I mean before COVID hit, you were running at a 35%, 40% payout ratio, and we've heard Charlie talk about maybe a 2-step increase or what have you. Give us a sense as to what the thought process is around what the right payout ratio is for you.

Michael Santomassimo

executive
#58

Yes. Well, look, we are focused on the payout ratio, right, not necessarily the absolute dividend, right? And as you sort of look at where it is now, it's clear it's low, right? And part of that is just how it was set last year and given the backward- looking formula, the amount of uncertainty was still there, right, so -- back in the third quarter. And so we are where we are. And I think as you sort of look at it, we know we need to get to a more reasonable sort of payout. And I think you can sort of look to peer payouts as a good guide over time. But as we sort of talked about on buybacks, it may not happen all in 1 move, but I think we've got to do what's prudent there. And dividends -- getting the dividend to the right place is an important piece of it.

Betsy Graseck

analyst
#59

So just one quick follow-up that came through on the question list. When you mentioned spend up 30% on debit card, was this versus 2019 or versus 2020? And is it Q to date or most recent week?

Michael Santomassimo

executive
#60

That was the most recent week first, and it was a little less than 30%. So approximately -- a little less than 30%, but it was the most recent week versus 2019.

Betsy Graseck

analyst
#61

Okay. Great. So we have 1 more minute. Final question, as you look out over the next year, what are you most focused on accomplishing here?

Michael Santomassimo

executive
#62

I think I'll end where I started, right, which is really on the things that we've got to get done across the company, right, and really make sure the team is the right team at all levels of the company, executing on the risk and regulatory build-out and remediation that we've got to get done, finishing the divestitures that we sort of announced already and investing in sort of those scale businesses and taking advantage of the opportunities that we have there, right? And so I think it goes back to the same 5 or 6 things that we've got to really just show that we're going to execute on over time.

Betsy Graseck

analyst
#63

All right. Great. Thanks, Mike, so much for joining us today.

Michael Santomassimo

executive
#64

Yes. Thanks for having me.

Betsy Graseck

analyst
#65

Okay. We'll move on to the next session now.

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