Using the 2017 COSO ERM Framework to Examine Risks at Wells Fargo

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Abstract In this assignment, students identify how an organization's culture can affect its strategies, objective setting, performance, and communication in ways that allow risk management and ethics failures to occur. The aggressive sales tactics and toxic environment at Wells Fargo bank documented in the business press from approximately 2009 to 2016 provide the setting. Students use the Enterprise Risk Management Framework of the Committee of Sponsoring Organizations of the Treadway Commission (COSO, 2017) to identify specific risk management failures at Wells Fargo. Students also describe how these failures might violate the ethics code of a professional accounting organization. Students conclude with recommendations for improving overall risk management at Wells Fargo. I report evidence that the assignment increases students’ knowledge about and ability to use a risk management framework and a code of professional ethics. The findings also show that students can write detailed, actionable guidance for improving risk management in a realistic setting.