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December 12, 2007

Paul Cline, Senior Accountant

Division of Corporation Finance

Securities and Exchange Commission

Mail Stop 4561

Washington, DC 20549

    Re:

    Wells Fargo & Company

    Form 10-K for the Fiscal Year Ended December 31, 2006

    Form 10-Q for the Fiscal Quarter Ended September 30, 2007

    Forms 8-K filed May 31, 2007, June 7, 2007, July 9, 2007 and November 7, 2007

    File No. 001-02979

Dear Mr. Cline:

In response to the comments by the Commission’s staff contained in your letter dated November 15,
2007 to Wells Fargo & Company (“Wells Fargo” or the “Company”), we submit the following
information.

SEC Request

Form 10-K for the fiscal year ended December 31, 2006

Risk Management

    1.

    Please tell us and disclose in future filings the degree of your exposure to sub
prime loans in both your held for investment portfolio and through securitizations.
Specifically address the credit quality trends within this product type and the impact of
these trends on your loan loss provision.

Wells Fargo Response

There is no consistent, uniform definition across the financial services industry as to what
constitutes a sub prime borrower. The Company’s multiple business groups, for legal and
underwriting purposes, consider a variety of factors including credit ratings (FICO scores),
loan-to-value ratios, existence of government insurance and other considerations to determine
whether a particular loan is sub prime. The aggregation of such data may not necessarily provide
meaningful information regarding the Company’s sub prime exposure, much less comparability among
registrants across the industry, and could be subject to misinterpretation.

Paul Cline, Senior Accountant

December 12, 2007

Page 2

However, in order to aggregate company-wide sub prime information for purposes of this response,
the amounts provided below are based upon loans with FICO scores less than or equal to 580 that
were not otherwise government insured. The sub prime amounts included in the next paragraph are not
material. Given the above noted concerns, we question the usefulness of this information to users
of the Company’s financial statements. However, based on information at September 30, 2007, we
observe that the following information could be considered for inclusion in the Risk Management
section of the Company’s Management’s Discussion and Analysis:

Sub prime loans held for investment were approximately $8.5 billion, or 3.9% of total consumer
loans, at September 30, 2007, and approximately $8.7 billion, or 4.6%, at December 31, 2006. Based
on the Company’s total loan portfolio, sub prime loans were less than 3% of total loans for both
periods. Mortgages held for sale, which are either sold or securitized, included sub prime
mortgages of approximately $0.2 billion, or 0.6% of total mortgages held for sale, at September 30,
2007, and approximately $0.7 billion, or 2.0%, at December 31, 2006. Additionally, the Company has
not retained any significant credit risk in securitizations of sub prime loans.

Based on the level of sub prime loans, the Company considers credit quality trends for its sub
prime loans as part of its overall monitoring of ongoing trends in credit quality on a portfolio
basis, including real estate 1-4 family first mortgages, real estate 1-4 family junior lien
mortgages, automobile loans (included in other revolving and installment loans) and credit cards.
The credit quality trends associated with these portfolios are disclosed in Note 6, Loans and
Allowance for Credit Losses, to the consolidated financial statements and in Management’s
Discussion and Analysis, Risk Management — Credit Risk Management included in the Company’s 2006
Form 10-K.

SEC Request

Consolidated Financial Statements

Consolidated Statement of Cash Flows, page 71

    2.

    You disclose in your Consolidated Statement of Cash Flows that you have transferred a
significant amount of loans originated for investment to held-for-sale. Please revise to
disclose the following information related to your sales of loans originally designated as
held-for-investment:

    •

    Please disclose what types of loans are included in the amounts
transferred from the held for investment portfolio;

Paul Cline, Senior Accountant

December 12, 2007

Page 3

Wells Fargo Response

We determine whether loans will be held for investment or held for sale at the time of commitment.
Loans we intend to hold for the foreseeable future are classified as held for investment. From time
to time, we originated adjustable rate mortgages (ARMs) in our loan portfolio as an investment for
our growing base of core deposits. These ARM loans are periodically evaluated to determine, based
on current market conditions, if the yields on these loans continue to meet our investment
objectives. We may subsequently change our intent to hold these ARMs for investment and sell ARMs,
in response to the Company’s Asset/Liability Management Committee directives to reposition our
balance sheet for changes in interest rates (such as the higher interest rate environment that
emerged in 2005 and 2006) or in the shape of the yield curve. Such Asset/Liability Management
directives identify both the type of ARMs (3/1, 5/1, or 10/1) to be sold and the weighted average
coupon (WAC) required for ARMs to meet the Company’s investment criteria. All ARMs at or below that
WAC are then transferred from held for investment to held for sale and subsequently sold.

The following disclosure will be included in Note 1, Summary of Significant Accounting Policies, to
our consolidated financial statements to be included in our 2007 Form 10-K:

Mortgages held for sale (MHFS) include commercial and residential mortgages originated for sale and
securitization in the secondary market, which is our principal market, or for sale as whole loans.
From time to time, we hold adjustable rate mortgages (ARMs) in our held for investment portfolio.
Based on future market conditions, interest rates and asset/liability management investment
objectives and guidance, we may subsequently change our intent to hold such ARMs for the
foreseeable future, resulting in an immediate transfer of these loans to the MHFS portfolio.

SEC Request

    •

    Given your significant sales of originated ARM loans, please disclose how
you consider paragraph 8(a) of SOP 01-6 in your original classification of these
loans;

Wells Fargo Response

The ARMs that were sold during this period were initially originated with positive net interest
margin spreads in excess of 300 basis points over the Company’s funding costs. Because of their
attractive spread, these ARMs were considered significantly preferable to the purchase of
securities and were designated at the time of commitment as held for investment, with the intent to
hold them for the foreseeable future or until maturity or payoff, in accordance with paragraph 8(a)
of SOP 01-6. As the Federal Reserve raised interest rates multiple times during 2005 and 2006, with
the expectation of continuing future interest rate

Paul Cline, Senior Accountant

December 12, 2007

Page 4

increases, the spread over our funding costs associated with these ARMs deteriorated to less than
100 basis points. As a result, the Company’s Asset/Liability Management Committee decided to sell
all ARMs below specified yields in order to reposition our balance sheet for the new (and higher)
interest rate environment, which is consistent with our core banking business of managing the
spread between the yield on our assets and the costs of our funding.

The following disclosure will be included in Note 1, Summary of Significant Accounting Policies, to
our consolidated financial statements to be included in our 2007 Form 10-K:

Mortgages held for sale (MHFS) include commercial and residential mortgages originated for sale and
securitization in the secondary market, which is our principal market, or for sale as whole loans.
From time to time, we hold adjustable rate mortgages (ARMs) in our held for investment portfolio.
Based on future market conditions, interest rates and asset/liability management investment
objectives and guidance, we may subsequently change our intent to hold such ARMs for the
foreseeable future, resulting in an immediate transfer of these loans to the MHFS portfolio.

SEC Request

    •

    Please clarify the nature of the line item “Proceeds from sales
(including participations) of loans by banking subsidiaries” included on your
statement of cash flows, and clarify whether these loans were designated as held for
investment or held for sale upon origination; and,

Wells Fargo Response

Substantially all of the amounts included in the line item “Proceeds from sales (including
participations) of loans by banking subsidiaries” relates to ARMs which were designated as held for
investment upon origination. The Company will revise the line item to read “Proceeds from sales
(including participations) of loans originated for investment by banking subsidiaries” in the 2007
Form 10-K.

SEC Request

    •

    Please clarify what you mean when you disclose that you include “certain
mortgages originated initially for investment and not underwritten to secondary market
standards” in the balance of mortgage loans held for sale. Disclose the amount and
type of these loans, and clarify whether they are reflected as operating or investing
cash flows.

Paul Cline, Senior Accountant

December 12, 2007

Page 5

Wells Fargo Response

We offer a portfolio product known as relationship ARMs that provides select borrowers with
interest rate reductions to reward eligible banking customers who have an existing relationship or
establish a new relationship with Wells Fargo. The amount of the interest rate reduction is based
on the borrower’s eligible account balances and other bank products maintained with Wells Fargo.
Relationship ARMs help solidify the customer’s relationship with Wells Fargo or establish
meaningful new relationships (including checking, savings, credit cards, investment accounts,
etc.), increasing the Company’s household cross-sell with opportunities to provide additional
products and services, which contributes to improved customer retention. Accordingly, this product
offering is generally underwritten to certain Company guidelines rather than secondary market
standards and is typically originated for investment. At December 31, 2006, we had $3.4 billion of
relationship ARMs in loans held for investment and $0.2 billion in mortgages held for sale.
Originations, net of collections and proceeds from the sale of these loans are reflected as
investing cash flows consistent with their original classification.

The following disclosure will be included in Note 1, Summary of Significant Accounting Policies, to
our consolidated financial statements to be included in our 2007 Form 10-K:

We offer a portfolio product known as relationship ARMs that provides interest rate reductions to
reward eligible banking customers who have an existing relationship or establish a new relationship
with Wells Fargo. Accordingly, this product offering is generally underwritten to certain Company
guidelines rather than secondary market standards and is typically originated for investment. At
December 31, 2007 and 2006, we had $x.x billion and $3.4 billion, respectively, of relationship
ARMs in loans held for investment and $x.x billion and $0.2 billion, respectively, in mortgages
held for sale. Originations, net of collections and proceeds from the sale of these loans are
reflected as investing cash flows consistent with their original classification.

SEC Request

    3.

    Please clarify the nature of the line item “Other changes in MSRs” in your
Consolidated Statement of Cash Flows, and disclose why they are investing, rather than
operating, cash flows.

Wells Fargo Response

Other changes in MSRs reflected in cash flows from investing activities in the Consolidated
Statement of Cash Flows, include changes other than fair value changes, such as purchases and
servicing retained from securitizations or asset transfers under FASB Statement No. 140, Accounting
for Transfers and Servicing of Financial Assets and Extinguishments of Liabilities and sales of
servicing. Wells Fargo’s mortgage servicing rights (MSRs) represent an investment made in its
mortgage servicing portfolio that it intends to hold and earn a

Paul Cline, Senior Accountant

December 12, 2007

Page 6

return over the life of the underlying portfolio. As required by FASB Statement No. 95, Statement
of Cash Flows (as amended), in accordance with their nature and purpose, such investments in the
mortgage servicing portfolio have been recorded as investing, rather than operating, cash flows.
The Company will clarify the line item “Other changes in MSRs” to “Changes in MSRs from purchases,
securitizations/transfers and sales” in the 2007 Form 10-K.

SEC Request

Note 26: Derivatives, page 115

    4.

    For each type of hedging relationship entered into during the periods presented that
you disclose in your footnote, please revise to disclose the following:

    •

    For each type of long-haul hedging relationship entered into during the
periods presented, please disclose the quantitative and qualitative measures you use
to assess effectiveness both at inception and on an ongoing basis. Specifically
reference the appropriate sections of SFAS 133, including any applicable DIG Issues,
which support the use of each test.

    •

    For each type of hedging relationship entered into during the periods
presented for which you utilize paragraph 65 or 68 of SFAS 133, please disclose how
each relationship met the requirements to use that method.

Wells Fargo Response

Wells Fargo will revise its Derivative Note disclosure in its 2007 Form 10-K as indicated in
Exhibit 1. We have presented Exhibit 1, which is based upon our 2006 Form 10-K Derivatives Note
disclosure and marked for planned revisions, to include further discussion on the methods used to
assess hedge effectiveness. We have also presented in Exhibit 2 a table of the specific FASB
Statement 133, Accounting for Derivative Instruments and Hedging Activities (SFAS 133), and DIG
issue guidance applicable to the assessment of hedge effectiveness (both at inception and on an
ongoing basis) for each type of hedging relationship entered into during the periods presented.

Wells Fargo no longer uses the short-cut method under paragraph 68 of FAS 133, Accounting for
Derivative Instruments and Hedging Activities. Effective January 1, 2006, we began using the
long-haul method to assess hedge effectiveness for all new hedging relationships involving U.S.
dollar denominated fixed-rate long-term debt and certificates of deposit. Prior to June 1, 2006, we
used the short-cut method of assessing hedge effectiveness for certain fair value hedging
relationships of U.S. dollar denominated fixed-rate long-term debt and certificates of deposits. By
June 1, 2006, we ceased use of the short-cut method by dedesignating the remaining short-cut method
hedging relationship and redesignating them in a new hedging relationship which uses the long-haul
method to assess hedge effectiveness.

Paul Cline, Senior Accountant

December 12, 2007

Page 7

For periods prior to June 1, 2006, the Company concluded that each short-cut hedging relationship
involving U.S. dollar denominated fixed-rate long term debt and certificates of deposit met the
requirements of paragraph 68 as follows:

    1.

    The notional amount of the swap matched the principal amount of the interest-bearing
liability being hedged.

    2.

    The fair value of the swaps was zero at inception of the hedging relationship.

    3.

    The formula for computing net settlements under each interest rate swap was the same
for each net settlement.

    4.

    The liabilities were not prepayable.

    5.

    The in