SEC Company Response from WELLS FARGO & (WFC) — Apr 2, 2010
WELLS FARGO & COMPANY/MN (WFC, WFCNP, WFC-PA, WFC-PC, WFC-PD, WFC-PL, WFC-PY, WFC-PZ) (CIK 0000072971)
Date: April 2, 2010 · CIK: 0000072971 · Accession: 0000950123-10-031837
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-2979
Referenced dates: March 29, 2010
Letter
VIA EDGAR AND ELECTRONIC MAIL Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549 Re: Wells Fargo & Company File No. 001-2979
Dear Mr. Nolan:
In response to the questions in your letter dated March 29, 2010 to Wells Fargo & Company (“Wells Fargo”) regarding our accounting for certain repurchase agreements, we are providing the information set forth below.
Wells Fargo accounted for all of its repurchase agreements as collateralized financing transactions in the consolidated financial statements included in its Annual Report filed on Form 10-K for the fiscal year ended December 31, 2009 (the “2009 Annual Report”). Wells Fargo did not account for any repurchase agreements as sales transactions for accounting purposes in its consolidated financial statements included in its 2009 Annual Report.
With respect to repurchase agreements, included in Note 12 (Short-Term Borrowings) of Wells Fargo’s 2009 Annual Report, below are the average quarterly balances for each of the past three years, the period end balances for each of those quarters, and the maximum balance at any month-end. The increase from Q3 2008 to Q4 2008, as well as the increase in the largest monthly balance from 2007 to 2008, is associated with Wells Fargo’s acquisition of Wachovia Corporation at the end of 2008.
(in millions)
Average Quarterly Balance
Q4
Q3
Q2
Q1
$ 19,293
$ 15,901
$ 17,410
$ 20,271
11,413
6,198
6,827
8,264
8,603
8,618
8,383
7,559
John P. Nolan
April 2, 2010
Page 2
Ending Quarterly Balance
Q4
Q3
Q2
Q1
$ 24,572
$ 16,853
$ 16,565
$ 15,158
20,264
6,962
6,433
7,452
8,435
8,887
9,054
7,912
Largest Monthly Balance
Amount
Month
$ 24,572
December
20,264
December
9,257
August
Wells Fargo further confirms that it does not have any other transactions involving the transfer of financial assets with an obligation to repurchase the transferred assets, similar to repurchase or securities lending transactions, accounted for as sales transactions in its consolidated financial statements in its 2009 Annual Report.
Wells Fargo has not offset financial assets and financial liabilities in its consolidated balance sheet where a right of setoff does not exist.
* * * * *
Questions concerning the information set forth in this letter may be directed to me at (415) 222-3119.
Very truly yours,
/s/ Richard D. Levy
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CORRESP
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Richard D. Levy
Executive Vice President & Controller
MAC A0163.039
343 Sansome Street, 3rd Floor
San Francisco, CA 94104
415 222- 3119
415 975-6871 Fax
richard.d.levy@wellsfargo.com
April 2, 2010
VIA EDGAR AND ELECTRONIC MAIL
John P. Nolan
Senior Assistant Chief Accountant
Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 4720
Washington, D.C. 20549
Re:
Wells Fargo & Company
File No. 001-2979
Dear Mr. Nolan:
In response to the questions in your letter dated March 29, 2010 to Wells Fargo & Company (“Wells
Fargo”) regarding our accounting for certain repurchase agreements, we are providing the
information set forth below.
Wells Fargo accounted for all of its repurchase agreements as collateralized financing transactions
in the consolidated financial statements included in its Annual Report filed on Form 10-K for the
fiscal year ended December 31, 2009 (the “2009 Annual Report”). Wells Fargo did not account for
any repurchase agreements as sales transactions for accounting purposes in its consolidated
financial statements included in its 2009 Annual Report.
With respect to repurchase agreements, included in Note 12 (Short-Term Borrowings) of Wells Fargo’s
2009 Annual Report, below are the average quarterly balances for each of the past three years, the
period end balances for each of those quarters, and the maximum balance at any month-end. The
increase from Q3 2008 to Q4 2008, as well as the increase in the largest monthly balance from 2007
to 2008, is associated with Wells Fargo’s acquisition of Wachovia Corporation at the end of 2008.
(in millions)
Average Quarterly Balance
Q4
Q3
Q2
Q1
2009
$
19,293
$
15,901
$
17,410
$
20,271
2008
11,413
6,198
6,827
8,264
2007
8,603
8,618
8,383
7,559
John P. Nolan
April 2, 2010
Page 2
Ending Quarterly Balance
Q4
Q3
Q2
Q1
2009
$
24,572
$
16,853
$
16,565
$
15,158
2008
20,264
6,962
6,433
7,452
2007
8,435
8,887
9,054
7,912
Largest Monthly Balance
Amount
Month
2009
$
24,572
December
2008
20,264
December
2007
9,257
August
Wells Fargo further confirms that it does not have any other transactions involving the
transfer of financial assets with an obligation to repurchase the transferred assets, similar to
repurchase or securities lending transactions, accounted for as sales transactions in its
consolidated financial statements in its 2009 Annual Report.
Wells Fargo has not offset financial assets and financial liabilities in its consolidated balance
sheet where a right of setoff does not exist.
* * * * *
Questions
concerning the information set forth in this letter may be directed to me at (415) 222-3119.
Very truly yours,
/s/ Richard D. Levy
Richard D. Levy
Executive Vice President and Controller
(Principal Accounting Officer)
cc:
Mike Volley, Staff Accountant, Division of Corporation Finance
John G. Stumpf, Chairman, President and Chief Executive Officer
Howard I. Atkins, Senior Executive Vice President and Chief Financial Officer