SecProbe.io

July 28, 2010

By U.S. Mail and Facsimile to: (415) 975-6871
 Richard D. Levy
Executive Vice President and Controller Wells Fargo & Company 420 Montgomery Street San Francisco, CA 94163
Re: Wells Fargo & Company
  Form 10-K for Fiscal Year Ended December 31, 2009   Form 10-Q for Fiscal Quarter Ended March 31, 2010
Filed February 26, 2010 File No. 001-02979
 Dear Mr. Levy:
 We have reviewed your letter filed on July 1, 2010 and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter within te n business days by providing the requested
information, including a draft of your proposed disclosures to be made in future filings, or by
advising us when you will provide the requested  response.  If you do not believe our comments
apply to your facts and circumstances or do not believe future revisions are appropriate, please
tell us why in your response.
 After reviewing the information you provide in response to these comments, including
the draft of your proposed disclosures, we may have additional comments.
            December 31, 2009 Form 10-K

 Note 7. Securitizations and Variab le Interest Entities, page 77

1. We note your response to prior comment 7 in you r letter dated July 1, 2010.  We continue
to consider your response and may ha ve future comments in this area.

 Richard D. Levy Wells Fargo & Company July 28, 2010 Page 2

March 31, 2010 Form 10-Q

Reserve for Mortgage Loan Repurchase Losses, page 40

2. We note your response to prior comment 11 in your letter dated May 11, 2010 and your
disclosure on pages 40-41 in your March 31, 2010 Form 10-Q.  Please respond to the
following:

a. Revise your future filings to disclose whether there is a time period that you have to respond to a repurchase request and what occurs if you do not respond in that time
period.

b. Revise your future filings to disclose the level of unresolved claims existing at each balance sheet date by claimant (GSE, monoline insurer, mortga ge insurer, etc).  If the
amount for any claimant has a negative tre nd, please discuss the qualitative factors
that you consider in your methodology to account for this fact.

c. Revise your future filings to disclose which representation and warranty provisions
have resulted in the most repurchases/reimbursements and discuss any trends in terms
of the losses associated with the various types of defects.

d. Revise your future filings to discuss your review process to determine whether to
reject or accept a repurchase demand (e.g. lo an by loan review, pool level analysis,
etc).

e. Revise your future filings to explain in gr eater detail your recourse to correspondent
and other third party originator s and disclose the percentage  and any trends related to
repurchase demands from external sources  (overall or by particular source).

f. You disclose that there may be a range of reasonably possible losses in excess of the
estimated liability that cannot be estimated. Pl ease revise future filings and tell us in
greater detail why the range of reasonab ly possible losses cannot be estimated.

You may contact Michael Volley, Staff Acc ountant, at (202) 551- 3437 or me at (202)
551-3494 if you have questions regarding our comments.

Sincerely,    Kevin W. Vaughn Accounting Branch Chief