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    Howard I. Atkins

Senior Executive Vice President

Chief Financial Officer

    420 Montgomery Street

12th Floor

San Francisco, CA 94104

December 16, 2008

VIA EDGAR AND FACSIMILE

Todd K. Schiffman, Assistant Director

Division of Corporation Finance

Securities and Exchange Commission

Mail Stop 4561

Washington, D.C. 20549

    Re:

    Wells Fargo & Company

December 31, 2007 Annual Report on Form 10-K

September 30, 2008 Quarterly Report on Form 10-Q

Dear Mr. Schiffman:

Set forth below are supplemental responses by Wells Fargo & Company (“Wells Fargo”) to comments of
the Staff of the Division of Corporation Finance that were included in Wells Fargo’s November 17,
2008 response to the Staff’s comments included in correspondence dated November 12, 2008. In
dialogue with the Staff, Wells Fargo agreed to provide additional information, including proposed
disclosures to be included in Wells Fargo’s December 31, 2008 Annual Report on Form 10-K, with
respect to certain enumerated items. Such items are detailed below, and include, for your
reference, the Staff’s comments, Wells Fargo’s prior response and current supplemental response.

Wells Fargo Form 10-K for the year ended December 31, 2007

General

36. We note you proposed additional disclosure related to your sub-prime exposure in your
response to comment #1 in your letter dated December 12, 2007. We could not locate
disclosure in your December 31, 2007 Form 10-K or subsequent Forms 10-Q which provide
similar information. Considering the significant focus on sub-prime and alt-A exposure in
the current environment, please tell us in detail and revise your future filings to
quantitatively disclose in one section of your document your total company-wide exposure to
sub-prime and alt-A credit or other risk.

Todd Schiffman, Assistant Director

December 16, 2008

Page 2

November 17, 2008, response:

Consistent with our response to comment 34 above, we do not believe that the identification of
higher risk loans as either prime or non-prime is meaningful information in the context of how
Wells Fargo manages its business. We believe that a more focused presentation of specific loan
concentrations, such as our National Home Equity Group Portfolio table, is a more informative
disclosure and is indicative of the type of data we use in day-to-day management operations. We
stand ready to work with the Staff to aid investor understanding by developing additional
appropriate disclosures relating to higher risk loan portfolios.

Supplemental response:

Our two higher risk portfolios are the National Home Equity Group liquidating portfolio and the
“Pick-a-Payment” residential loan portfolio acquired from Wachovia. With respect to Wells Fargo’s
2008 Annual Report on Form 10-K, we will augment our discussion of specific loan concentrations and
include in one section of our report details related to those portfolios with higher risk loan
characteristics. We will include details with respect to our National Home Equity Group portfolio,
comparable to information presented in Table 13 on page 55 of Wells Fargo’s 2007 Annual Report. We
expect to further augment these disclosures with the following discussion of the “Pick-a-Payment”
portfolio as part of the pending transaction with Wachovia Corporation:

Our Pick-a-Payment loan portfolio, which we acquired as part of the Wachovia merger,
totaled $[ ] billion in unpaid balances and had a carrying value of $[ ] billion
at December 31, 2008. Pick-a-Payment loans are home mortgages on which the customer
has the option each month to select from among four payment options: (1) a minimum
payment as described below, (2) an interest-only payment, (3) a fully amortizing
15-year payment, or (4) a fully amortizing 30-year payment. Approximately [ ]% of
the Pick-a-Payment portfolio has payment options calculated using a monthly
adjustable interest rate; the rest of the portfolio is fixed rate.

Approximately 85% of the December 31, 2008, Pick-a-Payment loan portfolio was
originated under Wachovia’s “Quick Qualifier” program where the level of
documentation obtained from a prospective customer relative to income and assets was
determined based on data provided by the customer in their loan application. As a
result, loans in the “Quick Qualifier” program may have varying levels of income and
asset verification. The remaining 15% was originated with full documentation
(verified assets and verified income).

The minimum monthly payment for substantially all of our Pick-a-Payment loans is
reset annually. The new minimum monthly payment amount generally cannot exceed the
prior year’s payment amount by more than 7.5%. The minimum payment may not be
sufficient to pay the monthly interest due, and in those situations, a loan on which
the customer has made

Todd Schiffman, Assistant Director

December 16, 2008

Page 3

a minimum payment is subject to “negative amortization” where
unpaid interest is added to the principal balance of the loan. The amount of
interest
that has been added to a loan balance is referred to as “deferred interest.” Our
Pick-a-Payment customers have been fairly constant in their utilization of the
minimum payment option. Of our Pick-a-Payment customers, approximately [ ]% at
December 31, 2008, based on number of loans, had elected this option. At December
31, 2008, approximately [ ]% of Pick-a-Payment customers had elected the minimum
payment option in each of the past six months.

Deferral of interest on a Pick-a-Payment loan may continue as long as the loan
balance remains below a pre-defined principal cap, which is based on the percentage
that the current loan balance represents to the original loan balance. Loans with an
original loan-to-value (LTV) ratio equal to or below 85% have a cap of 125% and
these loans represent substantially all our Pick-a-Payment portfolio. Loans with an
original LTV ratio above 85% have a cap of 110 %. Pick-a-Payment loans on which
there is a deferred interest balance re-amortize (the monthly payment amount is
reset or “recast”) on the earlier of the date when the loan balance reaches its cap,
or the 10-year anniversary of origination. After the recast, the customer’s new
payment terms require that the loan be fully repaid by the end of the original loan
term. Based on assumptions of a flat rate environment, election of the minimum
payment option 100% of the time by all eligible customers and no prepayment of
balances, we would expect the following balance of loans to recast based on reaching
the cap, $[ ] million in 2009, $[ ] million in 2010, $[ ] million in 2011 and $[
] million in 2012. In addition, we would expect the following balance of ARM loans
having a payment change based on the contractual terms of the loan to recast: $[ ]
million in 2009, $[ ] million in 2010, $[ ] million in 2011 and $[ ] million in
2012.

Included in the Pick-a-Payment portfolio are loans accounted for under SOP 03-3 with
total unpaid principal balance of $[ ] million and a carrying value of $[ ]
million. Loans that we acquired from Wachovia with evidence of credit quality
deterioration since origination and for which it was probable at
acquisition that we will be unable to collect all contractually required payments were accounted
for under SOP 03-3. SOP 03-3 requires acquired impaired loans be recorded at fair
value and prohibits “carrying over” of valuation allowances in the initial
accounting for loans acquired in a transfer.

In stressed housing markets with declining home prices and increasing delinquencies,
the LTV ratio is a key metric in predicting future loan performance. Because SOP
03-3 accounting takes into account the estimated life of loan losses, we have also
included the ratio of the carrying amount to the current value of the loans.

Todd Schiffman, Assistant Director

December 16, 2008

Page 4

The following table provides information regarding the Pick-a-Payment portfolio at
December 31, 2008.

    December 31, 2008

    Non-SOP 03-3 loans

    SOP 03-3 loans

    Unpaid

    Carrying

    Outstanding

    principal

    Carrying

    amount

    balance (1)

    Current

    balance

    Current

    amount (1)

    to current

    Pick-a-Payment Portfolio

    (in millions)

    LTV ratio

    (in millions)

    LTV ratio

    (in millions)

    value ratio

    California

    $

    %

    $

    %

    $

    %

    Florida

    New Jersey

    Arizona

    Texas

    Other states

    Total Pick-A-Payment loans

    $

    $

    $

    (1)

    These amounts are included in loans on the balance sheet.

To maximize return and allow flexibility for customers to avoid foreclosure, we have
in place several loss mitigation strategies for our Pick-a-Payment loan portfolio. We
contact customers who are experiencing difficulty and may in certain circumstances
modify the terms of a loan to meet their needs while at the same time maximizing the
cash payments expected to be received on the loan. In circumstances where we make an
economic concession to a customer who is experiencing financial difficulty, which
would include reducing the interest rate to a below market rate for the loan, we
classify the restructured loans as a troubled debt restructuring (TDR).

We also have in place proactive steps to work with customers to refinance or
restructure their Pick-a-Payment loans into other loan products. Based on a
customer’s individual situation, we will customize an approach to refinance or
restructure their loan. The offers may include rate buy-downs and/or conversions into
FHA-insured loans, conversion into other conventional loans with no negative
amortization features, or origination of zero percent interest second lien loans. If
we believe these customers are experiencing financial difficulty and we make an
economic concession through the modification, we report these restructurings as TDRs.

We expect to continually reassess our loss mitigation strategies and may adopt
additional strategies in the future. To the extent that these strategies involve
making an economic concession to a customer experiencing financial difficulty, they
will be accounted for and reported as TDRs.

Pick-a-Payment loans in a delinquent status that have been modified are considered
nonperforming until six consecutive months of payments have been made, at which time
the loan moves to accruing status.

Todd Schiffman, Assistant Director

December 16, 2008

Page 5

Critical Accounting Policies

Process to Determine the Adequacy of the Allowance for Credit Losses, page 39

     41. Please revise your future filings to provide additional information regarding your
forecasting models used to measure losses inherent in consumer loans and some commercial small
business loans. Please describe your forecasting models in a level of detail sufficient to explain
and describe the systematic analysis and procedural discipline applied.

November 17, 2008, response:

In response to the Staff’s comment, we will revise our future filings to include the requested
information.

Supplemental response:

With respect to Wells Fargo’s 2008 Annual Report on Form 10-K, we expect to include the following
disclosure in Critical Accounting Policies — Process to Determine the Adequacy of the Allowance
for Credit Losses:

To measure losses inherent in consumer loans and some commercial small business
loans, we use loss models and other quantitative, mathematical techniques to
forecast losses. Each business group forecasts losses for loans as of the balance
sheet date over the estimated loss emergence period.

Each business group determines the model type and/or segmentation method that fits
the loss characteristics of its portfolios and provides the greatest level of
forecasting accuracy. We use both internally developed and vendor supplied roll
rate/net flow models. Roll rate/net flow models, vintage base-models and behavior
score models are often used for near-term loss projections as well as time
series/statistical trend models for longer term projections. As appropriate, the
business groups may attempt to achieve greater accuracy through segmentation by
sub-product, origination channel, vintage, loss type, geography, and other
predictive characteristics.

Models are independently validated and are reviewed by corporate credit personnel to
ensure that the model theory, assumptions, data, computational processes, reporting,
and end-user controls of the model are appropriate and well documented. In addition,
regulatory examiners review and perform detailed tests of our allowance processes.

Forecasted losses are compared with actual losses and this information is used by
management in order to develop an allowance that management believes adequate to
cover losses inherent in the loan portfolio as of the reporting date.

Todd Schiffman, Assistant Director

December 16, 2008

Page 6

     42. Please revise your future filings to quantify the portion of the allowance for credit
losses calculated for each of the three identified elements:

    A.

    pooled consumer and some commercial small business loans;

    B.

    non-impaired commercial loans, commercial real estate loans
and lease financing; and

    C.

    impaired commercial and commercial real estate loans that are
over $3 million and certain consumer, commercial and commercial real estate
loans whose terms have been modified in a troubled debt restructuring.

November 17, 2008, response:

In response to the Staff’s comment, we will revise our future filings to include the requested
information.

Supplemental response:

Due to the acquisition of Wachovia, we plan to increase the threshold for evaluation impairment for
certain nonaccrual commercial loans and commercial real estate loans from $3 million to $5 million,
at December 31, 2008.

With respect to Wells Fargo’s 2008 Annual Report on Form 10-K, we expect to include the following
disclosures in Critical Accounting Policies — Process to Determine the Adequacy of the Allowance
for Credit Losses:

At December 31, 2008, the portion of the allowance for credit losses estimated at a
pooled level for consumer loans and some segments of commercial small business loans
was $[ ] billion.

The portion of the allowance for commercial loans, commercial real estate loans and
lease financing was $[ ] billion at December 31, 2008.

We assess and account for as impaired certain nonaccrual commercial and commercial
real estate loans that are over $5 million and certain consumer, commercial and
commercial real estate loans whose terms have been modified in a troubled debt
restructuring. At December 31, 2008, we included $[ ] billion in the allowance
related to impaired loans.

     43. For any loans that are pooled to determine the allowance for credit losses, please revise
to disclose the basis for your groupings. Specifically, revise to disclose how you grouped
sub-prime, alt-A or any other relatively higher risk loans. If you group these loans with other
relatively lower risk loans, please tell us why you believe this policy is consistent with the
guidance in SAB 102 which states that loans with similar characteristics should be grouped
together in determining and measuring impairment under SFAS 5.

Todd Schiffman, Assistant Director

December 16, 2008

Page 7

November 17, 2008, response:

For those loans that are pooled to determine the allowance for credit losses, the basis for this
grouping is by product and/or business unit. As discussed with the Staff on
November 13, 2008, and consistent with our response to comments 34 and 36, we do not have a
consistent Company-wide definition of sub-prime or alt-A loans, nor do we manage our businesses in
accordance with these definitions. We believe that our basis for grouping loans is disaggregated to
a level that allows us to adequately determine and measure impairment under SFAS 5. We will
disclose in future filings this basis for our groupings.

W