Key takeaways

• In the aftermath of the Wells Fargo settlement, regulators have shifted their scrutiny to the sales practices of banking institutions: The Office of the Comptroller of the Currency has embarked on a large-scale review of banks’ sales practices; the Consumer Financial Protection Bureau recently suggested that sales practices of other banking institutions would be investigated aggressively; and the New York Department of Financial Services also weighed in, issuing public guidance on incentive compensation. 
• Banking institutions should expect close scrutiny of their sales and related compensation practices going forward, and such concerns may spread outside the banking sector as well. Accordingly, institutions should begin reviewing their sales practices and control processes around them.