The committee’s announcement stated, “The Memorandum shows that the CFPB estimated that the bank was potentially liable for a statutory monetary penalty exceeding $10 billion. This penalty could potentially be increased further, CFPB enforcement attorneys noted, if CFPB determined whether the fraudulent behavior was reckless or knowing, as opposed to negligent, or if the CFPB discovered additional fraudulent behavior not yet reported or violations of other statutes.”
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The Recommendation Memorandum, found here, offers much more information on what Wells Fargo’s penalty should be and what Cordray was advised.