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

November 4, 2022

New York Stock Exchange US Financials Banks conference_presentation 41 min

Earnings Call Speaker Segments

Unknown Analyst

analyst
#1

Good morning, everyone. Welcome to Day 2. We are going to get started here. I am happy to be on the stage with Mary Mack from Wells Fargo. So Mary before we kind of get into the issues, maybe you could just take us through the sort of your history at Wells Fargo, the -- I know you've worn a lot of hats over the years.

Mary Mack

executive
#2

I promise you I wouldn't take you through all of it. But I have been at Wells Fargo for, I think it's 38 years. I started at what was First Union. I spent 20 years as a wholesale banker at First Union, ended up in sort of all areas of that. Boomeranged from the corporate investment bank to retail, still as First Union. Spent a few years there, went over and spent a dozen years in our retail brokerage firm, Wells Fargo Advisors. Was running Wells Fargo Advisors for a few years, when I got a call from the then, I guess, COO saying there was a little problem in the consumer bank and he wanted me to come over and fix it. I asked him if he cared where I lived. So I was living in St. Louis. My husband was practicing along the East Coast and I really didn't want to move to San Francisco. My one question was really, "Do you care where I live?" He said, "No, I could care less." I moved back to Charlotte. And I didn't ask what the little problem was in the consumer bank, and that was 2 or 3 weeks, I think, maybe a month before we announced the sales practices settlement or order. And so I have been doing that in some form or fashion ever since. And that, that -- do you want me to describe what that, that is?

Unknown Analyst

analyst
#3

Yes. Let's go into that.

Mary Mack

executive
#4

So I have -- yes. Our consumer bank is -- has several parts to it. I have the branches, the deposit side and small business. Kleber Santos runs our consumer lending business. So Kleber has credit card, auto, home lending, personal loans. And then Barry Sommers is a little bit of a hybrid, where Barry has our brokerage and investment and high net worth business.

Unknown Analyst

analyst
#5

Perfect. So you're the perfect person to ask about the health of the consumer, from sort of your perch, running the branch system and so forth. What do you -- what's your sense of how the consumer is doing as they deal with higher rates and higher inflation and all the other stuff?

Mary Mack

executive
#6

Well, all the other stuff that we're -- that we as consumers are dealing with. It's actually been a pretty healthy story for consumers. When you think about higher rate, sure, but also low unemployment, higher wages, the coming off the stimulus money and higher savings. We're looking -- when we look at our consumer portfolio overall, and the deposit customer, certainly there are some pockets of weakness, but they are pockets; I mean, generally, it's a pretty healthy story.

Unknown Analyst

analyst
#7

Are there segments of those pockets that you could characterize for us, like the folks at the lower end? Have you seen the deposit balances decline more, or anything along those lines that you can share?

Mary Mack

executive
#8

Yes. If you look into the deposit base, there are certainly some customers who are feeling the impacts of inflation, fuel prices, definitely higher rates than others. Generally, those with low balances in the -- under $1,000, they certainly are feeling. You've got a higher debit card average spend because gas costs more at the pump than it did 1 year ago. And we can see that in that sort of cohort of customers.

Unknown Analyst

analyst
#9

Just looking a little bit at the numbers on the third quarter. It kind of looked like debit spending was a little bit -- the growth rate was less and credit card was a little bit more. Is that at -- like do you feel like consumers are starting to need to borrow more to maintain the lifestyle? Or is that just like a vagary of the numbers in third quarter?

Mary Mack

executive
#10

Well, the debit spending has been incredibly consistent, really. And there's some transactions -- average transactions are up because of inflation, and you're seeing that. But it's still above pre-pandemic levels, like 2% to 5% kind of growth. But it's been incredibly consistent. For us, we have seen a lot of higher credit card spending. And not only are our customers now going on vacation when they didn't before or spending in areas where -- like entertainment that might have been suppressed, but we also have had a lot of growth in credit card with a lot of the new offerings, and we see that certainly in the portfolio.

Unknown Analyst

analyst
#11

Let's swing over to the deposit side. Obviously, that's one of the big issues de jour. How is your experience with deposit growth and deposit betas compared to sort of what you might have expected walking into this dynamic rate environment?

Mary Mack

executive
#12

So it's been pretty consistent with what we imagined and planned for. What we've seen so far really is the consumer spending. And for context, I mean, we've seen a surge over the last 2.5 years of like 30% to 40% in consumer deposits. So I think it's kind of natural that we would see consumers begin to spend some of that, which is what we've seen in the portfolio so far. A little bit of -- I mean you're starting to see a little bit of movement on rate as our customers seek some rate alternatives or are looking for high rate. But up to this point, it's really been sort of a spending story and not a lot of movement.

Unknown Analyst

analyst
#13

So just kind of looking back over the last couple of cycles, and every cycle is different, and this one is steeper, faster. How would you expect deposit betas, let's say, over the cycle, kind of the endpoint on deposit betas look compared to the past cycles? I think that going back to, let's say, the 2005 to '07 cycle, it looked like it got to about 67% of -- just looking at deposit rates versus Fed funds, 2019, I think it was more like 40%. I would -- like where do you think the endpoint might be on this one? Or is it impossible to tell?

Mary Mack

executive
#14

Well, it's really hard to predict. So I won't. But it's -- we're early in. The movements have been different. You are starting to see, and we'll -- we expect the betas to go up from here. I mean it's a natural part of the cycle and the lag that we would expect to see. So I mean, I wouldn't know how to predict because all but -- even those 2 cycles are very different from one another. But we can all expect it to rise.

Unknown Analyst

analyst
#15

So what are the challenges of retaining deposits in this environment? I mean you've got pricing, consumer spending. And how do you think about it in terms of how hard to fight to keep deposits? I mean, obviously, some deposits are just going to go They may not be price-sensitive. Like how do you find this battle of the -- this inclination for deposits to leave?

Mary Mack

executive
#16

Well, again, you got to think about it in the context of the surge that we've seen because I think the consumer spending story, part of that is natural. And we're certainly seeing that as consumers spend down some of those balances or spend again when they have it at the same levels over a period of time. So that's just a natural part of it. For us, I think we've got to focus on relationships. You've got to focus on customers and customer relationships. We'll be competitive. We'll -- we're watching that really closely to make sure that we remain competitive, but it's a -- for us, it's a customer and a customer relationship sort of play.

Unknown Analyst

analyst
#17

Keep the relationship in. So along those lines a little bit, one of the other flash points in the industry has been in the area of overdraft. Can you just share with us kind of what actions you guys have taken on overdraft? And what's the customer reaction? Do they care if overdraft fees are waived? Or is it just something that was given to them?

Mary Mack

executive
#18

I think they care. They care a lot.

Unknown Analyst

analyst
#19

They care, okay.

Mary Mack

executive
#20

So we started looking at really what did customers need, rather than just going at it from a fee question, although that's an important question to ask, but we had to step back and say what do customers need. And I would tell you that customers need -- different customers need different things. And some customers just need more transparency to understand what it is and what's happening. And so our new mobile app gives a lot of transparency to a customer at an individual transaction level to figure out what's going on in a way they might not have been able to with traditional ways of tracking that down. We eliminated the nonsufficient funds fees and transfer fees. So if there was a linked account or there was a transfer in, those fees were eliminated early in the year. And we saw immediate reduction in calls or customers who want to know what they were, naturally, because those fees were no longer in place. Some customers needed just maybe a heads-up or notice. And so we introduced 24-hour extra day grace, and we're actually running some ads on it right now. You get an extra day, we give you an alert that says, that, hey, if you don't take some kind of action in the next 24 hours, it looks like you could be overdrawn. And we're seeing a pretty good number of customers take action, which is great, and a good outcome. And we're getting -- really to your other question, we're getting really good feedback on it from customers, hey, thanks; you helped me avoid this and that's meaningful. They have money. They had money to access. They just needed a heads-up. We've seen -- and we already have -- we've got a number of customers who just don't want to pay overdraft fees. So we've got Clear Access, which is a no-overdraft-fee account. And that we've got right at 1.5 million, maybe over 1.5 million of those accounts. We just opened it or just introduced it about 2 years ago. We were up 57% year-over-year last year. So it's been really well received. We have some customers who have more month than paycheck and they needed their paycheck early. So we started rolling out the early access in September, I believe, and we're on a rolling schedule where customers will get their paycheck deposited essentially when we get the file, as soon as we get the information from their employers. Could be up to 2 days. It kind of depends on when we get that. So all of those -- that combination of things. And then there's a group of customers we believe that needed short-term access to but just a little bit more money. And we'll roll out -- we're in, I think, in testing right now. That's something that's happening in Kleber's world in Consumer Lending with Flex Loan, which will be a short-term liquidity access for customers to be able to just put a little bit more money in their account to cover.

Unknown Analyst

analyst
#21

Great. So technology-enabled solution that made it easier for the customer to avoid something that they really didn't like. And that's -- that was an impressive number of angles that you came at this with.

Mary Mack

executive
#22

Well, again, to us, it wasn't just 1 problem. It wasn't just a fee problem. It was -- there was an access problem. It was an information problem. And we really needed to solve each one of those, not just one.

Unknown Analyst

analyst
#23

Great. So at the beginning of our conversation, you talked about how you came into the -- came into your current position. I think you were actually speaking here at this conference shortly after...

Mary Mack

executive
#24

I was. We took a trip down memory lane, right before we started, and I had almost forgotten that.

Unknown Analyst

analyst
#25

So could you talk a little bit about the changes? I know this is kind of a big question, but -- and a lot has happened. But just kind of pulling back, what are the changes that you put in place to deal with the scandal, if you will. And sort of a little mini State of the Union about like how you feel about where now -- where you are now versus then with the customer, let's say.

Mary Mack

executive
#26

So I will start by saying we still have more work to do, and we'll always have more work to do. I don't know if you ever get finished with the customer business, but it would be -- and it'd be easier to tell you the things that hadn't changed. If I think back over time, there are things that have. But immediately, we needed to reset the sort of the focus of our team and eliminated product sales goals, changed their incentive plans to focus around sort of a balanced customer experience and kind of overall growth story. And those messages are really important to the team, right, to be able to ground them in that. We were focused initially on customer retention because it was a lot of news, and we just needed to make sure that customers remembered that the reason they chose Wells Fargo didn't change. The Wells Fargo that they walked into, the branch they walked into was the same one before and after. And I'm delighted to say that our attrition is still lower than it was pre sales practice announcement. So those things were successful. And then we needed to move through a lot of the governance, oversight routines, leadership changes, entirely restructured the organization as well as changed a substantial number of the leaders at all levels, down to the branch. And that's been in place. We've at the same time been dealing with, oh, things like COVID, and everything else in the client-facing part of the -- customer-facing part of the business. So we've got more work to do. There's been a real acceleration, in particular, under Charlie's leadership of the overall risk and control framework and infrastructure across the company, which supports us and the other businesses. So all of that has made that kind of progress.

Unknown Analyst

analyst
#27

And could I put the employee twist on it as well? Like how have employees fared through this kind of period of turmoil, and emerging out the other side?

Mary Mack

executive
#28

Yes. Let me start by just saying that the employee through this has probably been -- makes me the most proud to represent this part of the company. If I think back to what our team has done, in particular, in the branches, in the contact centers who were dealing with customers who were reading about a company they didn't recognize and wanting to make sure that they were okay. They are the ones that were the front-facing, let me tell you why you should feel good about where you are, people for us. And then take them through that into COVID where while the rest of the world was scrambling and looking for a hand sanitizer, they were opening branches every single day, thank goodness for drive-throughs, I have to say. We had more than we may have wanted at the time, but exactly the number we needed through that. And they were the ones who have been return-to-office the whole time. And the cool thing about that for us and the company is it's really changed the entire organization's point of view around our frontline employees. I've got investment bankers thanking the tellers for what they're doing in the face of Wells Fargo through the pandemic. So it's been an incredibly resilient group of folks. We also needed to recognize that. So we paid them for it. We did some appreciation pay on a couple of occasions through COVID, which was really well received. Then we made a significant increase in the minimum wage for all of our front-facing folks. So that all feels good. Now at the same time, we have been a source of efficiencies for the company because we needed to rightsize our staffing and our footprint for the changing customer behavior that was happening in the branches. Before COVID, we had maybe twice as many customers that were coming in. If I took a show of hands right now and ask how many of you all have been to a branch in the last month, you may not raise your hand, but there are almost 1 million customers a day who would. And so we -- but we need to recalibrate. So that's a little stressful, obviously, on our team as we're thinking about branch rationalization and staffing and staffing models, et cetera. But I think on balance, the feedback they give us is -- continues to improve. The feedback we get, we hire a lot. Maybe most, but certainly a lot of the new hires to Wells Fargo come in through our organization. They're a great source of talent, a very diverse source of talent. I have a majority diverse team that I think, feels pretty good about where they are on that journey.

Unknown Analyst

analyst
#29

Great. Let's talk a little bit about the branch network. I mean you've -- I think you're down from -- let's say, you're down like 1,200 branches, I think, over the last 6 years, something like that. And yet relative to some of the changes that other folks did, I think some of your bigger competitors started a little bit earlier in branch rationalization. And obviously, consumer behavior has changed a lot, as you pointed out. So where do you think you are in that journey? And also, how is the branch model sort of tweaking as it adapts to the emergence of the digital as a more important element than before?

Mary Mack

executive
#30

Sure. So when I came into this role in 2016, we had something -- we had over 6,000, maybe 6,100, 6,200, 6,300 branches, and now we're below 4,700. So we've made a tremendous amount of progress. Some of that in the early days of it was -- I hate to say this out, but relatively easy to do. And I had branches across the street from each other. The migration wasn't hard. The retention was really good, and we needed to consolidate those. We just had a lot of -- we had more footprint than we needed, and more density than we needed. And to your point, then you've got consumer behaviors that are changing at the same time. That first was our work, now as we think about rightsizing the footprint to the behaviors and what our customers need. We've got more density in some markets and less in others than we need, and so we've got to reposition some of those things. There's a branch refresh when you think about the way we present to the communities. There's a ton going on in that space right now. How do I think about the way they're used? I think increasingly, when you can do most of your transactions on the -- on your phone, the need in the branches is around advice and guidance and introduction to -- in an affluent branch, introduction to a financial adviser who can give you other alternatives. And so that's really the pivot in terms of skills in the branch, what we call premier bankers, the licensed bankers who are working with financial advisors and affluent customers, that's really the transition. On the other end, we just last week or the week before, did a big launch of what we called HOPE Inside. About 30% -- slightly less than 30% of our branches are in low to moderate income communities. And we have a huge opportunity to serve those communities, also really in an advice and guidance sort of way when we think about what are the opportunities we have. In this case, we partnered with Operation HOPE. And John O'Brien joined us in Stone Mountain, Georgia to launch one of these HOPE Inside centers focused on low to moderate income customers, but also banking inclusion and reaching out to the unbanked. So it's that whole -- it's sort of the whole place, Matt, and combination of those branches across the country.

Unknown Analyst

analyst
#31

If I could branch off from the premier relationship side, and your experience running the wealth side probably plays in here. But could you talk a little bit about the opportunity there as you sort of segment the deposit base or the customer base. Just what are your aspirations perhaps with that product? And where do you think it could go?

Mary Mack

executive
#32

Yes. So it's really kind of a fun position we're in. I used to run the brokerage firm; Barry Sommers, who runs Wealth and Investment Management used to run the retail bank at a previous institution. So there's this mutual engagement and excitement around what we can do together, which is very different than anything that I had experienced before. And there is a huge opportunity. We've got premier bankers and relationship bankers. They're all licensed in one way or another that are out in our footprint and financial advisors who sit in our branches and serve those branches. We invest more in licensed bankers. Barry is investing more in financial advisors who are in those branches, but there's a huge opportunity as we think about the customers who bank with us and didn't -- haven't had access to someone who could advise them on the investment side, but we had to start with getting the product right. So we launched our Premier product, which is our premier checking product with the kind of limits, the digital experience -- a unique digital experience for Premier all this summer. And there's a lot of momentum. We're getting good feedback from the bankers. They feel like they've got something good to work with now that recognizes the customers for who they are and the financial advisors who realize that we get it in terms of the opportunity to work together.

Unknown Analyst

analyst
#33

So going back to -- we were talking about the rationalization of the branches, 6,000 down to 4,700. Could you talk just a little bit about the overall efficiency sort of goals of the organization? Sort of what role do you guys play in that, sort of have you done your part at this point? Or is there more to go in terms of like getting a little bit more efficiency out of the branches?

Mary Mack

executive
#34

We've done a lot because we had not only -- not only were we rationalizing the footprint in a number of places, but we had more people than our customers needed in the branches with their behavior change through COVID, et cetera. We just had more than we needed. So we've done a lot of that. That said, we still have an opportunity. We rolled out our new mobile app, which has been really well received earlier this year, and we've been focused on engaging our customers and helping them understand the safety, convenience, protection that they've got. And sometimes they just need a little bit of help. We've got our branches that are focused on, hey, I'm happy to take your deposit. But if you have a minute, I'll show you how to do it on mobile. And oftentimes, customers just need us to show them once. And so there's still a lot of opportunity for that. And from our standpoint, it's transaction migration. From a customer standpoint, it's really convenience and a better experience, honestly. As wonderful as our people are, if you could do it from home, why wouldn't you? And -- but we had to get the availability right, the limits right. It needs to be as good or better in mobile as it would be when you go into the branch. So we've done that work. Now we've got more customer engagement work to do.

Unknown Analyst

analyst
#35

Great. So let's talk a little bit about the small business side. What are you doing for the small business owner? You've refreshed a lot of technology and product for -- on the retail side. What's going on with the small business side?

Mary Mack

executive
#36

So we're really leveraging that same -- some of those same investments we made in consumer, if you think about digital. There's the opportunity to leverage a lot of that across the small business. A lot of our small business customers are consumers or are also our consumer customers. But there's opportunity to transition some of that technology to the small business customer. We've invested a lot through not only PPP and the investments that we put back in through open-for-business and partnerships with CDFIs because a lot of the smallest small business customers that we serve also need access to capital. And we can enable that capital, whether it be in partnerships with CDFIs or MDIs in the marketplace, et cetera, who can serve those customers as well, or better. So there's been a big focus there. And I mentioned the opportunity for leverage in digital. There's also an opportunity for us in value proposition. We're hearing -- we've got that small customers, a lot of whom start in our branch network, but not all, who are served by bankers in our branches. Then we've got virtual bankers. They're sitting in 2 or 3 locations across the country. They are partnered with some of the larger customers on a more of a relationship basis so that we can lean in, we partner a lot with Kyle Hranicky's commercial team. There's a lot of need, overlap with the smaller and emerging middle market side of his business and the opportunity to not only get better but more efficient at how we share across those groups to deliver its value proposition.

Unknown Analyst

analyst
#37

Great. We have a little bit of time left over. We'll turn it over and see if Julian has any questions. Actually, we have a mic coming, if you don't mind.

Mary Mack

executive
#38

I can hear you but nobody else can.

Unknown Analyst

analyst
#39

Yes, I can hear you.

Unknown Analyst

analyst
#40

Mary, can I ask about the mobile app. I think you have round numbers, 30 million active mobile users. JPMorgan is now at close to 50 million. A few years ago, you were kind of neck and neck with JPMorgan and Bank of America. So why is that gap opened up? And how can you close it?

Mary Mack

executive
#41

Well, what we -- the first step really needed to close it was to deliver what we've delivered in terms of the mobile app. So we hired new talent in, we delivered on a mobile-native app in a year or less, which is what we launched in the spring. So that was a big first part of it. And the next part is for new customers, to have them mobile active day 1. And in our branches now, we've got the majority of customers, 70 percentage of those customers are mobile-active day 1. So that's actually a really good start to begin to close that too with new accounts. And then we've got the customers kind of the ones that I was talking about a minute ago, who have not yet been introduced to it, that we've just got to go back in and be really deliberate. It's not -- again, sort of like overdraft, it's not one approach. We've got to really understand those customers who are not yet engaged, now that we have the tools. We're rolling out something new, new capabilities like every quarter in the mobile app to continue to invest in the capabilities. While others were investing in the capabilities, honestly, we were getting our other act in order that we've been talking about. So now it's the time to continue the risk and control work but lean into some of the investments that we're making.

Unknown Analyst

analyst
#42

Betsy? You guys could share.

Unknown Analyst

analyst
#43

The other way leaning in on branches. So we talked about branch efficiencies and improving that piece of it. But I'm wondering, what are you doing with regard to new branches? I hear from other folks that, that is a significant driver of deposit growth. And just wanted to understand where you are there.

Mary Mack

executive
#44

So our focus has been on, as you know, on some of our branch rationalization; we just had too many. Well, now we've gotten to look at where are those markets where we may have a small presence but they're great markets, and we really need to build out, not a massive presence, but we've got to have the appropriate density in the market. Nashville is a good example of that. We opened, I don't know, 5-6 branches in Nashville, strategically placed because we had a very small presence but not the kind of coverage. We're going into markets like that now and beginning. Again, that's the part of where we can then pivot to both continue to get the work done and lean in a little bit more to some of the forward-looking activities that would get that right.

Unknown Analyst

analyst
#45

[indiscernible]

Mary Mack

executive
#46

Not necessarily. It's kind of the combination of where we're rightsizing in markets where we are still too dense and then how we redeploy that into not really new markets. Again, our first focus is on getting the markets we're in right, and you'll see some opens in those kind of markets.

Unknown Analyst

analyst
#47

Great. And we have another question here from Charlie.

Unknown Analyst

analyst
#48

I was wondering if you could provide some color around some of your 10-Q disclosures relating to the work you're doing with the CFPB. I know it's around autos and mortgages and retail banking. Does that relate to 1 consent order? Or are there several consent orders involved in there?

Mary Mack

executive
#49

Again, I don't think I'd have anything to add to it that Charlie or Mike hadn't already talked about. So we're doing the work that we need to do, but I think they've addressed it in their comments.

Unknown Analyst

analyst
#50

Multiple consent orders or is it 1 consent order?

Mary Mack

executive
#51

Like, I don't think I'd have anything to add. I mean I really don't -- I wouldn't comment on that, anything beyond what they have already talked about.

Unknown Analyst

analyst
#52

I assume that's public information what the consent orders are. So I'm just trying to get a clarification as to whether it's 1 or 2 or...

Mary Mack

executive
#53

Really, I mean I just -- I really have nothing to add to what Charlie and Mike have already talked about.

Unknown Analyst

analyst
#54

All right. Well, let me ask a different -- you took a $2 billion charge in this third quarter, but your range of possible losses went up, I think, to $3.7 billion. Is -- that's kind of unusual isn't it to take a big charge and still see losses go higher?

Mary Mack

executive
#55

I'm not the one to ask. I've got, John Campbell is in the back. John would be a person to follow up with; would direct you there. But I don't think I'm the person to help you.

Unknown Analyst

analyst
#56

Yes. Let's take that off-line. Are there other questions? Yes. I'll come back to you.

Unknown Analyst

analyst
#57

When you and the management team are kind of having your healthy debates about the future of the business, what are the 1 or 2 areas that you're having the most active healthy debates right now about?

Mary Mack

executive
#58

The most active healthy debate is the fact that our biggest priority is to get the risk control work right. Everybody is super clear on the fact that that's the most important thing we can do. And in doing that, what are the right kind of investments that we can make that are the most important to move the organization forward. We're making investments in retail. That's the beauty for me, honestly, selfishly of having somebody like Charlie, who knows this business really well and the value and the leverage of the retail franchise. But also how can we lean into this mobile-first approach, not just because our customers want it, but what can it do also to help us leverage technology in the branches, for instance. How do we start there and really get further by following the lead of our -- the mobile team. And then I can promise you my wholesale buddies, we have a whole group of things that they are focused on, but you'd have to ask them.

Unknown Analyst

analyst
#59

Next, here.

Unknown Analyst

analyst
#60

Coming back to your lending to low- and moderate-income communities. I mean it's 100% the right thing to do, but can I ask about profitability because -- coming back to the point about overdrafts, again, 100% the right thing to do to [ custom ] but it then makes it harder or reduces the profitability of that kind of business.

Mary Mack

executive
#61

Well, it is a place though with all communities, low to moderate income is certainly one of them, but all communities, when we think about options like digital and digital active customers, that gives us the ability to serve more communities at scale more efficiently. So it's -- and the good news about that one is the customers also like it. And it's not -- we're not -- we're taking customers to where they want to go, which is convenience. Now the one that I was talking about where we were in Stone Mountain, Georgia, outside of Atlanta, last week and the week before, there is a part of -- we've taken a large branch, retrofitted it for almost like a community center, where we can do some counseling engagement, third-party coaches, et cetera. But a big part of it is digital education and engagement. And that's a big part of how we can serve them well and more efficiently, which I think is -- plays a big role in this community.

Unknown Analyst

analyst
#62

If I can ask a couple of follow-ups. Firstly, you mentioned that 30% of branches are in LMI typically. So for the Community Reinvestment Act, what's the minimum percentage you would have had to have to meet the CRA requirements? And actually, given what you said about serving digitally, I mean, is the CRA even fit the purpose anymore given that you can actually serve them digitally maybe cheaper and better?

Mary Mack

executive
#63

Well, as you know, the CRA is being reevaluated at the regulatory level now. And so that will evolve, certainly, I think, in recognition of the way the landscape has evolved. So branches serve a purpose. Branches serve a purpose for all communities. Do we need as many as we used to be? No. And that also really applies, I think, to all communities. But we've got to think about not just CRA or about communities but really all of the customers differently, starting from what do they really want and need and what do they really want and need branches for, advice, guidance. Everybody needs a plan. Your plan just might be different from somebody whose plan is to buy their first car to get to their first job.

Unknown Analyst

analyst
#64

And what's the minimum you would have needed to meet CRA?

Mary Mack

executive
#65

Oh, gosh, I don't know off the top of my head. Sorry. I know we've more than met it, but I don't know what the minimum is.

Unknown Analyst

analyst
#66

So Mary, when the sales practice sort of situation unveiled itself and you...

Mary Mack

executive
#67

Situation, I like that.

Unknown Analyst

analyst
#68

You like that -- and you came into this position, I think that you changed or stopped the incentives for selling different products. I think the P&L for a given branch was sort of deemphasized as a way of just sort of cooling off the situation and so forth. How are you managing now? Like is it -- there's a set of behaviors. I mean you've got a whole new product set. You've got all this digital technology. You want the people in the branches to be doing some of these -- putting some of this change into the hands of the customer. How do you make that happen? Can you incentivize them on the right behaviors that you're looking for now? Or is there a different way of doing it to encourage that behavior? And then there's the sort of P&L of the branch. Is that something that you look at now? Does the branch manager sort of see what's going on? Does it change how you incentivize them?

Mary Mack

executive
#69

Yes. Yes. Yes. I probably answered all your questions. So let me start with like how do we even start to get back into that. One was, we had to invest in the governance and oversight. And that was a lot of the early work, was making sure we had governance, oversight, monitoring. I've got a system of monitoring now that I won't liken it to brokerage -- well, I will liken it to brokerage. It's not exactly like people want trade monitoring, but it has elements. That's why I came from brokerage to do this, was what's our real-time supervision that we've put in place. So that's in place now. With that, you can feel a lot more confident about the ability to monitor behaviors or patterns or out-of-pattern sorts of things to see. With that then, we could begin introducing things like P&Ls. We rolled out P&Ls to our branch managers. Behavior. You used the word behavior several times. It's all in the context of a behavior framework. So what is the behavior we're looking for? How do we measure and monitor it? What does the branch manager look at from a P&L standpoint at the branches? We've got to get behavior right before we then start incenting on it, but we're on that journey, right, and the branch managers have been using them with business reviews, at the branch level on a regular basis so we can review the performance of that branch. We've got some bankers like our licensed bankers because we also rely on the oversight from Barry's Wealth Investment Management team, where they are paid for referrals, the -- for closed referrals to the brokerage side of the house. So we've got not only our oversight, but Barry's oversight as well. So you can do it in some places like that. And we'll lean in and test in. We'll want to test things to make sure. But now it's a balance of customer experience and growth. I think you'll always see the customer experience element of it, but you can perhaps get more targeted around growth as we test into those controls. We just got to do it in the right order at the right time.

Unknown Analyst

analyst
#70

Right. Right. That's great. Very informative. Thank you very much for your time.

Mary Mack

executive
#71

Sure. Happy to be here.

Unknown Analyst

analyst
#72

Great. Thank you.

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