富國銀行 (WFC) 2019 Q4 法說會逐字稿

Good morning. My name is Regina, and I will be your conference operator today. At this time, I would like to welcome everyone to the Wells Fargo Fourth Quarter Earnings Conference Call. (Operator Instructions)

I would now like to turn the call over to John Campbell, Director of Investor Relations. Sir, you may begin the conference.

Thank you, Regina. Good morning, everyone. Thank you for joining our call today where our CEO and President, Charlie Scharf; and our CFO, John Shrewsberry, will discuss fourth quarter results and answer your questions. This call is being recorded.

Before we get started, I would like to remind you that our fourth quarter earnings release and quarterly supplement are available on our website at wellsfargo.com.

I'd also like to caution you that we may make forward-looking statements during today's call that are subject to risks and uncertainties. Factors that may cause actual results to differ materially from expectations are detailed in our SEC filings, including the Form 8-K filed today containing our earnings release and quarterly supplement.

Information about any non-GAAP financial measures referenced, including a reconciliation of those measures to GAAP measures, can also be found in our SEC filings, in the earnings release and in the quarterly supplement available on our website.

I will now turn the call over to Charlie Scharf.

Thank you, John, and good morning, everyone.

It's good to be with you on my first earnings call. As I go through my remarks, I'd ask that you remember that I just joined Wells Fargo less than 3 months ago. It's been a busy time as I've been working to get to know the company, our opportunities and challenges, and I've learned a lot. But as I discuss my observations, please recognize that it is still early days. I don't have all the answers yet, but I will share more as I learn more and as the year progresses.

John is going to cover the quarter in detail in a few minutes, and we'll answer your questions. But you can see that a series of legacy issues meaningfully impacted our results in the quarter. Even excluding these significant items, our results are not as strong as we aspire to, but the strength of the franchise is still evident. There are certainly some areas of success, but the opportunity to improve our results is significant and attainable.

Let me first share some of my observations and thoughts before turning it over to John. First, I was honored to be chosen to lead Wells Fargo because I believe this is an extraordinary company that plays an important role in this country. We came out of the financial crisis as the most valuable and most respected bank in the U.S. But as you know, we made some terrible mistakes and have not effectively addressed our shortcomings. These circumstances have led to financial underperformance, but we have one of the most enviable financial services franchises in the world and employees that want to do what's necessary to again be one of the most respected and successful banks in the U.S.

To fully capture this opportunity, we must have a strong foundation and move with an extreme sense of urgency to remediate our historical issues. We still have much more work to do to put these issues behind us, and our future depends on us doing this successfully so we can regain trust with all stakeholders, including our clients, regulators, lawmakers as well as the broader American population. Ultimately, our actions will dictate when that trust is completely regained, not our words.

Given the importance of these issues, I want to say a few more words about our situation, particularly about the challenges that stand in the way of our success and, importantly, the different approach we're taking to address these issues. Providing an honest assessment and clear priorities is critical, and I've given a clear message inside the company that we have not yet met our own expectations or the expectations of others. We must do what's necessary to put these issues behind us. Our ability to maximize the value of this great franchise is dependent on us running the company with the highest standards of operational excellence and integrity beyond what we've done to date.

We are appropriately a highly regulated institution. And while we need to fulfill regulatory expectations, we recognize that what we want and what regulators want are not different. We are responsible for our actions, and they're responsible for ensuring our actions are consistent with clearly defined standards. It's our job to run the company such that we fulfill their expectations and those of the American public and other countries where we operate. Respect was earned in the past, and we will earn it again.

As such, since joining, I've been spending almost all of my time on these issues. I will say this several times, but you should know there is still much work to do. Many have focused on the Fed consent order. But remember, we have 12 public enforcement actions that require significant resource commitment. While I certainly wish more of this work was behind us, what's required of us is clear, and we will get it done. It's work that other banks have done already, so there's a clear road map for what we need to achieve.

We're making significant changes to our management, structure and processes to accomplish our work, changes that will make us more effective. Like any other problem, recognition of the importance and severity is a necessary first step, but this by itself is inadequate. We will take whatever actions are necessary. Our future success depends on resolving these issues, so we will act accordingly.

The management team will be judged and held accountable for resolving these issues. To set us up for success, we will ensure we have the right people in place to both resolve these issues and be the stewards of this great company.

Importantly, I want to acknowledge that we have so many wonderful people at Wells Fargo that have done an amazing job serving our clients and customers in the face of adversity for several years now. They've been through so much and have helped us sustain such a great franchise. So I do want to say thank you to them for all they've done. The warmth and support I've been greeted with, as I've discussed our shortcomings and work in front of us, tells a great deal about the character of many at the company. They understand our lack of progress makes their jobs far more difficult, and they're looking to management to do more to move the company forward.

To get the work done, we must ensure that we have the right team. To that end, we've made some important changes to the senior team to complement the talent that's here at Wells. Scott Powell joined us as Chief Operating Officer. When I arrived at the company, many on the senior management team made clear to me that they believed we needed stronger execution skills. After just several weeks at the company, I came to quickly agree. Scott will lead a transformation across the company where high-quality execution, clear accountability and operational excellence becomes part of our culture.

Bill Daley joined as Head of Public Affairs. He has a strong and experienced voice and brings perspectives from the public sector that we in business do not generally have but are critical for us as we make decisions.

Allen Parker, who served both as General Counsel and interim CEO, announced he will be leaving Wells in March. We are well into a search for the new General Counsel and excited about the quality of the candidates we've met.

Avid Modjtabai has announced that she will be retiring after 26 years at Wells Fargo in March. We will be announcing a new organizational structure for these activities shortly.

Ray Fischer has also joined us to run our Card and Merchant Services businesses. Our Card business is important to our franchise, and we have an opportunity to make it even more significant. Ray is an experienced card and merchant services executive who brings deep knowledge and a fresh perspective to our business.

These changes are in addition to many other senior people who have joined the company over the past few years in important roles such as heads of risk, HR, internal audit and technology. These new additions complement the strong talent at the company, and I will continue to look at the structure and roles to ensure we are best positioned for success. We need and will have the best talent and strong leadership at the company.

We're also introducing a new set of disciplines in how we run the company, which I'm confident will improve our performance. These changes are not only structural and procedural but also cultural. To that point, parts of our culture are wonderful and would take decades to recreate. People who work here love it. It really is like a second family. We focus on teamwork, not on the individual. People want to be successful and do what's right, though we recognize we've fallen short of this goal. But our lack of progress and underperformance point to shortcomings.

Going forward, we will operate as one company, not a series of decentralized businesses. We will continue to foster a culture of partnership, but we will move past the need for consensus and have open and direct fact-based discussions where we emerge with decisions. We will have a different level of management discipline than we've had in the past, and we'll value and expect high-quality execution. There will be clear responsibility and accountability. We will judge ourselves based upon our outcomes, not our words. And we will ultimately judge ourselves versus the best as we believe that we should be the best.

As we've begun to implement this new culture, the response has been overwhelmingly supportive. But I understand it's different and is a significant change for many. We will be respectful of our past and of those who have built this great franchise, which includes so many still at the company today, but we must move forward. I'm confident these changes will be highly impactful.

And though I understand you would like time frames around resolution, I cannot provide that today. Our job is to do the work that's necessary. Regulators and other stakeholders will determine when it's done to their satisfaction. My experience is that our regulators are clear, direct, tough but fair. The work is on us at this point.

Let me now turn to our medium- and longer-term opportunities. Our franchises are world-class and are in the sweet spot of providing necessary financial services for consumers, small businesses and middle-market and large corporate companies. And importantly, we play an important role in helping our customers and clients prosper as well as being an important enabler for U.S. economic growth.

While I've spoken at length of our mistakes and our commitments to fix them, the underlying franchise itself is as valuable as ever, and our opportunities are greater than ever. The success of our business model is proven, assuming we run the company with the appropriate controls and work as one company with the goal of delivering for all stakeholders.

All of our business segments, Community Banking, Wealth and Investment Management and Wholesale, have the breadth and scale that gives us significant competitive advantage and allow us to deliver truly differentiated products and experiences for our customers and clients.

Our opportunity to use technology to drive both automation and new solutions will only grow in importance. Our franchises, both individually and collectively, are the envy of many. So while our resources and attention today are appropriately preoccupied with historical issues, as we move forward, we will be in a position to leverage our unique franchise and generate stronger financial results.

And just to be clear, we are well aware that our expense levels are significantly too high. Part of this is driven by significant project expense related to historical issues. Part is due to the necessary investments in technology. Part is due to significant inefficiencies that exist across the organization. But there is no reason why we shouldn't have best-in-class efficiency with these businesses at this scale, and that ultimately will be our goal.

And though we've had pockets of strong performance, we're also well aware that our rate of customer and revenue growth is too low. Given what we've been through, this isn't surprising. There is certainly an opportunity cost due to the asset cap. Management time and resources have not been as focused on growth as they otherwise would have been. And we have an opportunity to think differently with a different level of rigor about how to grow the franchise. All of this points to great opportunity.

So again, I know you will want to know time frames and targets, but please understand that it's too early after less than 3 months at the company. That said, we have just begun the process to rethink our plans for 2020 and beyond in a different level of detail.

While the opportunities for improvement are clear at the macro level, we need business-by-business plans. Accordingly, we have just begun conducting what are really both budget and broader business reviews where we look in detail at our plans. We will be reviewing over 10 businesses in detail as well as all of our enterprise functions.

As you can imagine, technology is an important theme. This isn't merely a review of the numbers but one where we use the facts to form a basis to discuss strategy and potential actions. We are asking each business leader to show us what best-in-class efficiency looks like and what our path to achieve it is. We're reviewing revenue and return performance as well and what a path to best class looks like here as well. We're discussing our competitors, large and small, and we're thinking through our unique options given our special franchise. These are analytical and strategic discussions that I don't think have occurred consistently across the company in some time given what's occurred.

The output of this work will provide us road maps to not only improve our performance within each business but also position us to understand our opportunities across the company and prioritize accordingly. First and foremost, this includes clarity around ensuring we're spending appropriately on historical issues.

It's still very early in our process, but I will say that every session thus far has reinforced that our opportunities are meaningful. We intend to be detailed, thoughtful and complete. To do this properly and given our priorities, it will take time, much of this year, to complete our work. But in the interim, we will devote all necessary resources to risk control and spend what's necessary. We will be as diligent as ever to drive efficiencies and control expenses, and we will begin to work through the business opportunities we have in front of us.

I'm confident in our ability to realize our potential, one that again puts us at the top of the respected financial institution list with a far more efficient organization and higher revenue growth than you see today. While there is much to do and I know the path to success will be bumpy, I'm optimistic about our future and excited to be at a place with so many great people and such strong franchises doing incredibly important work.

John, over to you.

Thanks, Charlie. Good morning, everyone.

We had a number of significant items in the fourth quarter that impacted our results, which we highlight on Page 2 of our supplement. We had $1.9 billion of operating losses, including $1.5 billion of litigation accruals for a variety of matters, including previously disclosed retail sales practice matters. The litigation accruals reduced EPS by $0.33 per share, and a majority of them were not tax deductible.

We had a $362 million gain from the sale of our commercial real estate brokerage business, Eastdil Secured. We had $166 million of expenses related to the strategic reassessment of technology projects in Wealth and Investment Management. We had a $153 million linked-quarter decrease in low-income housing tax credit investment income, reflecting a timing change of expected tax benefit recognition. We had a $134 million gain on loan sales, predominantly junior lien mortgages. And we had a $125 million loan loss reserve release.

While our financial results in the fourth quarter were impacted by these items, as we show on Page 3, we continue to have positive business momentum with strong customer activity, which I'll highlight throughout the call.

On Page 4, we summarize the full year results. Compared with 2018, revenue declined as 4% growth in noninterest income was more than offset by a 6% decline in net interest income driven by lower interest rates. Our expenses remain too high and increased 4% from a year ago driven by higher personnel expense, which included $981 million of higher deferred comp expense, which is P&L neutral, and higher operating losses. Loans grew 1%, and deposits increased 3% from a year ago. Our net charge-off rate remained near historic lows, and we returned a total of $30 billion to shareholders in 2019 through common stock dividends and net share repurchases, reducing common shares outstanding by 10%.

I'll be highlighting most of the balance sheet drivers on Page 5 throughout the call, but I will note here that we were $20 billion below the asset cap at the end of the fourth quarter.

Turning to Page 6. I'll be covering the income statement drivers throughout the call. But I want to highlight that our effective income tax rate was 19.1% in the fourth quarter, which included a net discrete income tax expense of $303 million, predominantly related to the nontax-deductible treatment of certain litigation accruals.

Turning to Page 7. Average loans increased linked quarter and year-over-year with growth in both consumer and commercial loans. Period-end loans increased $9.2 billion from a year ago even as we sold or moved to held for sale a total of $5.8 billion of consumer loans over the past year.

I'll highlight the drivers of the linked-quarter growth in loans, starting on Page 9. Commercial loans increased $3.4 billion from the third quarter driven by broad-based C&I growth in Corporate and Investment Banking.

As we show on Page 10, consumer loans grew $4 billion from the third quarter. The first mortgage loan portfolio increased $3.2 billion from the prior quarter driven by $17.8 billion of held-for-investment mortgage loan originations and the purchase of $2.3 billion of loans as a result of exercising servicer cleanup calls. We're now substantially done with our cleanup call program for pre-2008 securitizations.

Junior lien mortgage loans were down $1.3 billion from the third quarter as paydowns continue to outpace new originations.

Credit card loans increased $1.4 billion primarily due to seasonality.

Our auto portfolio continued to grow with balances up $1.1 billion from the third quarter. Originations were down 1% linked quarter on seasonality but increased 45% from a year ago, reflecting a renewed emphasis on growing auto loans following the restructuring of the business.

Turning to deposits on Page 11. Average deposit costs increased 2% from the third quarter and 4% from a year ago. Our average deposit cost of 62 basis points increased 7 basis points from a year ago, reflecting promotional pricing in Retail Banking for new deposits earlier in the year and the mix shift to higher-cost deposit -- higher-cost products across our consumer and commercial businesses. Our average deposit costs declined 9 basis points from the third quarter, reflecting lower rates in Wholesale Banking and WIM.

We did not run any broad-based Retail Banking marketing promotions for deposits during the fourth quarter. However, Retail Banking deposits increased 2 basis points due to the continued impact from previous promotional campaigns and deposit gathering strategies over the past year when interest rates were higher. While we continue to offer our customers competitive promotional savings and CD rates within our branches, Retail Banking deposit costs are expected to start to decline in the first quarter as higher promotional rates expire.

On Page 12, we provide details on period-end deposits, which grew 3% from a year ago and 1% from the third quarter. Wholesale Banking deposits were up $15.9 billion from the third quarter driven by seasonality and growth in existing and new customer balances. Consumer and small business banking deposits increased $16 billion from the third quarter driven by higher Retail Banking deposits, including growth in high-yield savings and interest-bearing checking. Wealth and Investment Management deposits grew as brokerage clients' reallocation of cash into higher-yielding liquid alternatives moderated during the quarter. These increases were partially offset by lower corporate treasury and mortgage escrow deposits.

Net interest income declined $425 million from the third quarter primarily due to balance sheet repricing driven by the impact of the lower interest rate environment, $104 million of lower hedge ineffectiveness accounting results as well as $74 million of higher MBS premium amortization costs due to higher prepayment rates. We had $445 million of MBS premium amortization in the fourth quarter. And based on the current interest rate environment, we expect MBS premium amortization to be relatively stable in the first quarter and then start to decline, although we expect it to be higher in full year 2020 compared with full year 2019.

As expected, net interest income was down 6% in 2019 compared with 2018. And we continue to expect net interest income to decline in the low to mid-single digits in 2020. However, as always, net interest income will be influenced by a number of factors, including loan and deposit growth rates, pricing spreads, the level of interest rates and the shape of the yield curve.

Turning to Page 14. Noninterest income declined $1.7 billion from the third quarter, which included a $1.1 billion gain from the sale of our institutional retirement and trust business.

Let me highlight a few of the other linked-quarter trends. We completed the sale of Eastdil Secured on October 1, resulting in a $362 million gain that was reflected in other noninterest income. This sale reduced commercial real estate brokerage commissions by $168 million from the third quarter. We provide a breakout of the revenue and direct expense related to this business on Page 27 in the appendix.

We're assessing all of our businesses as part of the reviews we're having since Charlie joined Wells Fargo, and there may be additional pruning going forward as we assess our strategic priorities.

Mortgage banking revenue increased $317 million from the third quarter. Servicing income was up $165 million due to a negative MSR valuation adjustment in the third quarter, reflecting higher prepayment rates. Net gains on mortgage originations increased $152 million due to a $4 billion increase in residential held-for-sale mortgage loan originations, while the production margin was flat at 121 basis points. Net gains on mortgage loan originations also increased from higher gains associated with exercising servicer cleanup calls in the fourth quarter. We expect mortgage originations to be lower in the first quarter due to normal seasonality.

Net gains from equity securities were down $505 million from the third quarter as lower gains from our affiliated venture capital and private equity partnerships were partially offset by a $240 million increase in deferred comp plan investment results, which again, are largely P&L neutral.

Turning to expenses on Page 15. Our expenses were too high, and becoming more efficient remains a top priority. I will explain the drivers of the linked quarter and year-over-year increases in more detail starting on Page 16.

Expenses increased $415 million from the third quarter driven by higher personnel and equipment expense. The $320 million increase in compensation and benefits was driven by $258 million of higher deferred comp plan expense. We also had higher salaries expense primarily due to changes in staffing mix, which was partially offset by lower FTE.

As a reminder, we will have seasonally higher personnel expenses in the first quarter, reflecting incentive compensation and employee benefits expense.

Infrastructure expense increased due to higher equipment expense driven by the strategic reassessment of technology projects in WIM. Our operating losses remained elevated but were stable linked quarter.

As we show on Page 17, expenses increased $2.3 billion from a year ago driven by higher personnel expense and operating losses. Comp and benefits expense increased $1.1 billion, which included $691 million of higher deferred comp expense as well as higher salaries expense primarily due to staffing mix changes and an annual salary increase.

"Running the Business" nondiscretionary expense increased by $1.5 billion of higher operating losses partially offset by lower core deposit and other intangibles amortization expense.

On the earnings call last quarter, we said we expected our 2019 expenses to be approximately $53 billion, which was at the high end of our $52 billion to $53 billion target range. As we showed on Page 18, we came in above that as fourth quarter expenses were higher than expected primarily in 3 areas. First, we had higher-than-forecasted outside professional services expense. These expenses were primarily related to legal, technology and risk management. Second, we had higher impairments and other write-downs, including the strategic reassessment of technology projects in WIM that I previously mentioned as well as impairments on railcars. Finally, we had higher personnel-related accruals, including severance.

Turning to our business segments, starting on Page 19. Community Banking earnings declined $570 million from the third quarter primarily driven by lower net interest income and lower net gains from equity securities.

On Page 20, we provide our Community Banking metrics. We had 30.3 million digital active customers in the fourth quarter, up 4% from a year ago, including 7% growth in mobile active customers from a year ago. Primary consuming checking customers -- consumer checking customers grew 2% from a year ago, the ninth consecutive quarter of year-over-year growth.

Branch customer experience survey scores in December increased from a year ago, reflecting the fundamental changes we've made to improve the customer experience. The decline in branch customer experience survey scores from the third quarter was most likely due to changes in branch staffing levels.

We're pleased that the progress we've been making to improve customer satisfaction was reflected in the J.D. Power 2019 National Banking Satisfaction Study released in December. Our customer satisfaction scores improved by 9 points from last year's study, the largest increase among our large bank peers.

Improving the customer experience across Wells Fargo remains a priority. And as part of this focus, we're implementing the Net Promoter System to allow even more dynamic customer feedback and benchmarking. As a result of this implementation, we'll no longer be reporting branch customer experience survey scores. However, we will continue to share key business drivers that reflect the progress we're making to improve the customer experience and to drive loyalty.

Turning to Page 21. Teller and ATM transactions declined 6% from a year ago. As a result of our customers continuing to migrate to digital channels, we consolidated 174 branches in 2019. We had 5,352 branches at the end of 2019, down 12% over the past 3 years. We also continue to have strong card usage with linked-quarter and year-over-year growth in both credit and debit card purchase volume.

Turning to Page 22. Wholesale Banking earnings declined $151 million from the third quarter driven by lower revenue. We're an industry leader in businesses that support low-income housing and renewable energy investments, which both generate income tax credits. These income tax benefits do not get included in revenue. So as you can see in the table on this page, we're reporting both our consistent wholesale efficiency ratio, and we're also providing our efficiency ratio adjusted for income tax credits in order to make this ratio more reflective of how we evaluate the business.

Wealth and Investment Management earnings declined $1 billion from the third quarter, which included a $1.1 billion pretax gain from the sale of our Institutional Retirement and Trust business. For the first time since the first quarter of 2017, WIM had linked-quarter growth in average deposits, up 2% from the third quarter, and total client assets increased 10% from a year ago on higher market valuations, including 18% growth in retail brokerage advisory assets. Closed referred investment assets resulting from the partnership between WIM and Community Banking were up 18% in the fourth quarter compared with a year ago, with December having over $1 billion in closed referrals, our strongest month since June of 2017.

Turning to Page 24. We continue to have strong credit results with 32 basis points of net charge-offs in the fourth quarter. Commercial losses were 16 basis points, up 5 basis points from the third quarter, driven by lower recoveries and higher losses in lease financing primarily related to railcars. Overall credit quality indicators in our commercial portfolio remain strong with our fourth quarter internal credit grades at their strongest levels in 2 years.

Consumer losses were 51 basis points, also up 5 basis points from the third quarter. Both of our consumer real estate portfolios were in a net recovery position in the fourth quarter. Our other consumer portfolios had slight increases in losses from the third quarter primarily driven by seasonality. Both our credit card and auto portfolios had lower loss rates than a year ago.

Nonaccrual loans declined $199 million from the third quarter with lower nonaccruals in both the commercial and consumer portfolios. Nonaccrual loans were 56 basis points of total loans in the fourth quarter, their lowest level in over 10 years.

We adopted CECL on January 1 of this year and expect to recognize a $1.3 billion reduction in our allowance and a corresponding increase in retained earnings. This reduction predominantly reflects an expected $2.9 billion reduction in the allowance for commercial credit losses under CECL, reflecting shorter contractual maturities and the benign credit environment, while the allowance for consumer credit losses is expected to be $1.5 billion higher under CECL, reflecting longer or indeterminate maturities, net of recoveries in collateral value predominantly related to residential mortgage loans, which had been written down significantly below current recovery value during the last credit cycle.

As we've noted in prior quarters, we anticipate more volatility under CECL due to economically sensitive forecasts and the impact of changes in the credit cycle.

Turning to capital on Page 25. Our CET1 ratio decreased to 11.1% driven by returning $9 billion to shareholders through common stock dividends and net share repurchases in the fourth quarter. Our ratio was still well above both the regulatory minimum of 9% and our current internal target of 10%. As a reminder, we used approximately 65% of the gross repurchase capacity under our most recent capital plan in the second half of 2019, so repurchases will be lower during the first 2 quarters of 2020.

In summary, while we had a number of significant items that impacted our fourth quarter financial results and our expenses remain too high, we continue to have positive underlying business fundamentals, including growth in loans and deposits, increased customer activity and strong credit performance. We also had high capital returns.

I'm excited about the opportunities ahead as we continue to do the work necessary to transform Wells Fargo. And Charlie and I will now take your questions.

(Operator Instructions) Our first question will come from the line of John McDonald with Autonomous Research.

Charlie, I wanted to ask you maybe for some high-level takeaways on Wells Fargo's technology. Where do you see it being up to par and best-in-class? And what areas do you see the technology as behind and needing more investment?

Thanks, John. It's a great question. Again, I'm certainly not in a position to be definitive across the board given how I've been spending my time. I will say that in the time that I spent with Saul Van Beurden, who is our Head of Technology at the company, we have a really clear list of the work that we have to do to both improve the underlying infrastructure of the institution, which will benefit our ability to grow at some point because it really contributes to our ability to servicing all of our clients across all of our different segments as well as we possibly can. And so it's a robust list. There's a lot to do on it. And Saul clearly is working through with his team all the right prioritization and putting time frames around it.

At the same time, it's clear when I spend time with all of our folks that we are thinking about where we go next and how we use technology to create different experiences. And we see it in terms of some of the things that we've done in the digital space on the consumer side.

And so again, I'm not in a position to be extremely specific business by business of exactly where we're positioned and how we think about it other than it's really clear that it has been a top priority inside the company. And certainly, all of the business leaders understand the importance that technology will play going forward. Hope that's helped, John.

Okay. And then wanted to ask John Shrewsberry. In terms of expenses, totally getting Charlie's point about being too early to talk about expense improvement. But when we think about the jumping-off point as we put our models for 2020 expenses, John, should we think about this $53.7 billion adjusted expenses that you did for '19, is that a good starting point to think about 2020 expenses? The last, you kind of said you'd try to be flat in 2020. Is that the right ballpark we should be thinking about for the adjusted number?

Yes. So early on here, while we're still going through this planning process, I wouldn't expect that much to change other than the -- some of the adjustments that we all make for deferred comp, for excess operating losses, et cetera. And then we'll -- as this process ensues, we'll come back with some more details.

But for now, we're kind of thinking flattish to that number or that's the right ballpark to start off with?

I would just take it period by period. Not that much is going to change between Q4 and Q1, the same because of the shortness of the time frame. And as we get more clarity as a result of our process, we'll provide more clarity.

Okay. And then just one just quick follow-up on that. In terms of the $600 million of operating losses that you talked about, it really hasn't been that in many years. It's really average. It seems like more like $2 billion a year. And I know it's hard to predict, but do worry about us anchoring too low on that $600 million, should we kind of budget something higher than that just as we go forward?

That's a good point. So the -- when we originally talked about the $600 million, it reflected the $150 million per quarter of fraud-related losses and other run rate operating losses without regard for what's been elevated over the last couple of years. I do think that the $600 million has probably grown to be something a little bit more like could be $700 million or $800 million. We'll try and give better guidance than that. But the higher run rate or the higher realized rate that we've had over the last 2 years reflects more of a combination of episodic things that are anticipated to be -- to recur at the same level.

And let me give you, just on your first question, a little bit more clarity because I'm reminded that the first quarter is the first quarter. I said this in my remarks, but there are seasonally elevated expenses in the first quarter that cause -- that stand out year after year as FICA resets, as retirement eligibility resets and a few other things that will cause that to stand out in any year.

Your next question comes from the line of Ken Usdin with Jefferies.

Charlie, to your points about just going after all of the things to put the company on the right foot forward, how do we -- how do you start to assess just if the right things are happening underneath?

And coming back to the point just on related expenses, you've obviously had this build over time of compliance and risk and those functions. Are we even at the point yet where the hiring is done in that regard, right, where you're actually just -- you've got the people in place and it's more just about execution? How do you give us a sense of just kind of where you think you are on that story arc?

Sure. So on the first question, listen, I think when you're on the inside of the company, and we're managing the work that has to get done the way that we are, we have clear reporting, we have clear goals item by item by item. And so it's very, very easy for us to understand whether we're tracking to milestones and, having reviewed the entire plan, believe that those milestones will get us to eventual closure on issues.

Quite honestly, from the outside, you obviously don't have the ability to do that. That's not something that we can provide to you. So ultimately, what you're going to have to look for are closure of these issues. And as time goes on, that is what we hope to accomplish, and that ultimately will be success as well.

On your second question about where are we, I guess, in terms of the build of expenses necessary to accomplish the work, again, I would say on that one, we're -- it's -- we can't sit here today and say -- I can't sit here today and say that the amount that we're spending and the people that we have is totally appropriate. And by the way, don't take that to mean it's too high. It's area by area. We've added a lot of resources. We need to understand whether we've added the right resources, whether we have people working together as well as we possibly can, understanding things that we've built manually to understand where we can go to automate those items, which will make us not only just far more efficient but far more effective. And so again, when I say it's really too early to be definitive about where we think about the level of expenses and what's appropriate, I put this into the same bucket.

But again, I just want to be really clear about this. We don't sit here and believe that we have carte blanche to spend whatever we possibly want on any issue. We are going to spend what's necessary on these historical issues. And you should assume that we will be extremely vigilant about ensuring that we're not only thinking about our future, but thinking about our shareholders in terms of where it all nets out ultimately.

Understood, Charlie. And just one follow-up on your point that a couple of months in, you're going to -- you said you got a look at, like, all 10 business lines and just see where you should think about things from a bottom up. From what you at least see now, is the company what it needs to look like going forward? The company has been trimming out of some areas over the course of time. Do you think that all the businesses the company has today deserve to be inside the company from a go-forward basis?

Yes. Sure. I would say, as far as the big pieces of the company, absolutely. When we look at the benefits that our clients get from having the combination of consumer businesses, wealth businesses and wholesale businesses under one roof are significant today. And as we look to the future, we believe they should be even more significant. And so, at that level, I would say, absolutely.

As John did mention in his remarks, we have been pruning. And as we go through these reviews and talk about some of the smaller things that we do, it is a good opportunity to ask, do we need to continue to do all of these things, will they make a difference first to our clients and, ultimately, to us. And so I would expect to have some things come out of that, but I put them in the category of pruning at this point.

Your next question comes from the line of Erika Najarian with Bank of America.

I wanted to follow up on the line of questioning that Ken just had, Charlie. So it sounds like, as we think about what you mentioned during your prepared remarks, as you focus on remediation and investment, it sounds like you're also -- there's also room to focus on inefficiencies at the same time. In particular, a lot of your investors have pointed out that your headcount hasn't moved much over the past 10 years and your headcount is similar to another peer that is producing about $40 billion more in revenue than you. So just wanted -- I know that sounded more like a statement, but the question really is, is there room to also address some of the efficiencies as you think about remediation and investment?

Yes. I think, again, what I want to make sure that I'm at least being clear about is that I think that we have -- we want to be able to think with as clean a sheet as possible about how we should be spending our money. And so that goes to asking the question, are we spending appropriately on the historical issues. And that number will be whatever we think it should be. Absolutely, we will focus on efficiency.

And I want to give just -- I should've said -- I haven't said this in my remarks, but it is important. It's not as if it's not something the company is focused on. And so when we look at all the additional resources that had been added to support these activities, it's very difficult for you all to see what we have gained in terms of efficiency because you should just assume that our expenses would be substantially higher if we hadn't been generating efficiencies in the rest of the company over the last several years. But having said that, with fresh eyes, I get to show up and take a look and ask a whole series of questions as do some of the other new folks that have come in. And there are still big parts of the company where we are extraordinarily inefficient. And to be fair, it's not just my eyes and the new folks' eyes, but it's what the existing management team talks about as well. So we do believe there are significant opportunities. And while the first priority is fixing the issues of the past, we should be able to continue to work towards both.

And I do want to throw in the last category, which is important, which is we are thinking about the future. And while time and conscious are weighted more times the past -- are weighted more towards the past, we're not ignoring the future. And so if we do see there are opportunities, which are meaningful, we want to have the latitude to think about how we can spend wisely on that.

And so that's why we're just being very, very careful about leading you to a specific number because we're not sure where that all nets itself out. And we want the time to be thoughtful about how to put it all together in a way that we certainly believe is the right long-term thing for the company, again, very conscious of the fact that we're stewards of the company, and there are owners out there and other stakeholders that we have to answer to.

Understood. And my second question is you mentioned that you'll be announcing a new org structure shortly. Does that include the hires that you highlighted during your prepared remarks? Or could we anticipate more changes to the operating committee from here?

I think what I said is what I said, which is Avid's retiring. She is responsible for a whole series of things, from deposits to treasury services, to card, to innovation, digital marketing, a very, very wide range of things. And we're actively working through what the right way to structure the company is with her retirement. And when we've completed that, we will certainly make sure that you all know about what it looks like.

Got it. And just if I could squeeze in a third question. Hear you loud and clear that the closure of the issues is one way your investors and other the stakeholders could measure progress at the company. As we think about the end of the year, what other measures of progress would you suggest your current and prospective shareholders could use to measure progress? Or is 1 year simply too short of a time given the transformation that you believe the company will go through?

Yes. I guess, let me say a couple of words, and John could add anything that he'd like. Again, I think it's important. We have a lot going on, and I've been here for a short time. And so we feel extremely optimistic about that medium and long term, but we have a lot to figure out. And as I pointed out, some of it takes months, and some of it will take a little bit longer than that. So I think answering the question of what that all looks like by the end of the year at this point is even premature, but just know that we're focused on outcomes here.

I think that -- I think we'll be talking about realized results and what drove them over the course of the year, including closure of issues to the extent that those are public items, and then how we set ourselves up and our stakeholders up for what comes next. So as this process goes on and concludes, and we have a better line of sight on what happens end of year, next year, et cetera, then we'll begin to share that. That will be progress.

And I just -- I don't want to dwell on it, but I just want to be clear. I'm not suggesting here that any of these public issues will be closed this year. What I'm suggesting is that we're going to do all the work that's required. The time frames will be driven by when we accomplish that work and when the regulators are satisfied -- are satisfied by it. There's -- as I said, there's a great deal of it. Some have a certain level of complexity to them, and we're focused on the work at this point.

Your next question comes from the line of Brian Kleinhanzl with KBW.

Still another question on the regulatory side. I think one of the things regulators always had said is they wanted to see a change in the culture at the bank as a sign that things are improving. I mean, is that still an outstanding item that needs to be addressed? Or has that been addressed already?

Well, listen, I think I addressed some of this in my remarks that we're prepared. And I think as the -- as an outsider coming in, I do have the opportunity to make some observations of some of the things that we do versus some of the things that I've seen that could help make a company successful going through issues that are somewhat like this. And so I do think that these changes that I spoke about are important to helping us be more successful at closing these issues in a way that has alluded us to this point.

Okay. And then the second question just on the numbers themselves. I mean if you look at, John, maybe on the commercial loans, you've seen decent growth now or, I would say, some growth year-over-year. And that portfolio looks like pieces of it are coming from the non-U.S., also coming from this credit investment portfolio. Can you guys give us an update on the C&I lending side of it? What's this growth in the non-U.S.? Where is that coming from? And then how do you see these loan CLOs? Is that -- and what's the total CLO exposure at this time?

Sure. So on the second part first, the total CLO exposure is about $38 billion, I think, at this point, which hasn't changed much. This approach of investing in them in loan form is really just -- it's a more accounting-friendly approach. It's the same risk/reward otherwise. And so we've made the shift for a part of our incremental investment. Still an asset class that we feel comfortable with the risk/reward in, in spite of where we are in the cycle and for other reasons.

The bulk of the C&I loan growth overall did come from commercial -- or corporate investment banking-related activities. So some of it is in the asset-backed finance area, things like CLOs, and then also with major corporate customers put on probably not permanent funding. Things -- we'll fund an activity, a strategic activity that ultimately would likely to get taken out in the capital markets subsequently. So it's not so much coming from the funded term loan segment of Commercial Banking, for example.

And I wouldn't agree too much of the growth in non-U.S. loans that's -- that will ebb and flow a little bit, but it's not likely to be a big driver of loan growth one way or the other in the foreseeable future.

Your next question comes from the line of Marty Mosby with Vining Sparks.

John, I want to ask you first. This $1.5 billion is a big number for this particular quarter. You've been addressing these issues. You can't talk specifically, but generally, was there some event? What was the catalyst for, all of a sudden, recognizing another significant or meaningful slug of onetime extraordinary cost?

Sure. I mean I can't talk too much about specific active litigation. But in general, these amounts get recorded when the items become both probable and estimable. So we've had elevated costs in this area for the last 2 quarters as a result of greater estimability of what the outcomes might be.

And then, Charlie, when you're coming over now and your statement that you went through initially kind of forwardly said we haven't addressed or Wells Fargo hasn't addressed these issues at the pace or in the way that they should have in order to make the progress. Kind of how do you look at assessing where some of these things went wrong, I mean, again, just generally, and maybe not specifically? But you would have thought over these years, there would have been a lot of attention and a lot of progress, and it just doesn't seem like that's been the case. So your assessment of it seems pretty critical. So I was just trying to figure out how to put some context around that.

Yes. I guess -- so the way I would -- the way I think about it is that I've -- when I had the opportunity to come in and look at where we are, my judgments are based upon where we actually are. I haven't -- I don't think there's a whole lot of value in terms of when I have to figure out how to spend my time in going back and figuring out if I was here, what I might have done differently. I'm not sure I would have done anything necessarily differently. I wasn't in the seat. I don't know what the priorities were. I don't know what else was going on. That is a very, very difficult thing to do and, generally, something that's very, very unfair to do.

So again, I think what's relevant is that I've been able to come in with this fresh set of eyes, believe that we have an opportunity to manage these blocks of work differently with both a different set of processes, some different people and a great deal of my time and attention as well as the rest of the senior management team. And based upon the experience that I've had in executing operational things as well as the other members of the team that we have in place now, and understanding the work that we have to do, I do feel confident that we can get it done. And that's been the focus.

And I guess maybe a different way to think about it is we've seen these things happen in the past. Would you couch it as that maybe there is a new standard in which Wells Fargo is going to be held accountable to kind of develop toward in order to set the new standard for the industry? So in other words, when the regulators get in on a bank, they then really begin to kind of figure out where they want everybody else to kind of head to. So it's not like you're just catching up with everybody else. Maybe there's surpassing and creating a more forward kind of model that they're wanting to get to. So I didn't know. Is there that part of it as well? Or is this just still catching up with everybody else?

Listen, I think I've got a lot to do to speak on behalf of Wells Fargo. And so it certainly wouldn't be right of me to speak for regulators. But I do think that we have the opportunity to raise the standard by which we view the importance of the work, the manner in which we go about doing it and the way we hold each other accountable for getting it done. And so again, that is my focus.

Your next question comes from the line of Saul Martinez with UBS.

Speaking of things you need to do to get closure on some of these issues, I think in the past, you -- you've talked about close to 10,000 processes. I think, John, you mentioned high single-digit thousands of processes where you're identifying individual risk controls and, where needed, remediating those risk and control functions. Can you just give us a sense of where you are in that process, what kind of progress you've made more recently? And I guess, importantly, how is your relationship with your regulators evolving as you kind of go through this and work through a lot of these individual processes?

Yes. On the first part, so not all 9,000-plus processes are created equally, their risk score and importance of score for their impact. And we're ahead of where we anticipated being by the end of the year. I don't have the exact number in front of me. But the -- of those that are most impactful, they will have been, as we've described, mapped risk ID, control ID, controls developed where controls didn't previously exist, testing over those controls put in place in the first half -- by the end of the first half of this year. That's how that looks right now, and I think it's to the satisfaction of people who are watching us do it.

Okay, okay. So -- okay. That's helpful. And so it feels like you're making good progress on the major -- on the more significant processes.

Right.

So just changing gears a little bit, you took, I think, $166 million charge for reassessing technology projects in Wealth and Investment Management. Can you just give a sense what drove that decision and whether we should be thinking that there could be other IT projects that you're looking at reassessing and cutting going forward?

Sure. So Jon Weiss has substantially reconstituted the leadership team in WIM. And they've set their strategic priorities and direction, and they -- and they're different than what had been under development in terms of the technology to support different parts of the business over the last few years, which is what resulted in the impairment to the capitalized software development costs. I wouldn't anticipate seeing a lot more of that. And to be honest, we don't have an extraordinary amount of capitalized software development costs. So the risk isn't that great from an accounting perspective.

Okay. Got it. If I could just squeeze one more quick one in, John, on -- just on fees. The core fee lines [time] deposit, trust, card, mortgages, in general, it seems like the momentum has improved a bit in recent quarters. And -- but can you give us a sense -- and I'm not asking for specific guidance, but can you just talk directionally about whether there's any reason to think you can't grow from fourth quarter levels, obviously, recognizing there's seasonality in a lot of these businesses? But is this -- are these like good core run rates to use? And is there -- and do you feel good about your ability to grow some of these line items?

Well, the trust and investment fee should step off at a high level because they price off of the opening tech, which, for the S&P, looks good for the coming quarter. That leverage, it creates cyclicality that works for us and against us.

Mortgage, as we said, is probably going to be a lighter quarter in the first quarter just because of seasonality. It was stronger in the fourth quarter than it would have seasonally been expected to be. But the pipeline suggests that it'll be somewhat smaller on the origination side in the first quarter.

Card fees tick up because there's more consumer spending going on in the fourth quarter, so I'd expect that to be more seasonally appropriate in the first quarter.

And then it's hard to forecast trading activity. It certainly was stronger year-over-year in the fourth quarter because of the blood bath in the fourth quarter of 2018, but it was weaker third quarter to fourth quarter in 2019. And historically, the first quarter is a stronger quarter as a result of asset managers reallocating and people getting invested in the first quarter. So we'll see what happens there. That's tougher to predict, but those are the types of things that are likely to influence. Things that are a little bit more ratable, like deposit service charges or loan fees, et cetera, I would anticipate -- I don't think there'll be much change from quarter-to-quarter.

Your next question comes from the line of Gerard Cassidy with RBC.

John, can you share with us -- I think you mentioned in your prepared remarks that you expected the net interest income to be down low to mid-single digits for 2020 over 2019. Can you compare for us what's the driver of that, vis-?-vis what drove the decline in 2019? Is it more having less higher yielding assets, like the Pick-a-Pay loans on the books in 2020? Or is it a margin compression issue? Can you give us some color there?

Yes. So it's a handful of things. But it was a bigger drop in 2019 because of, I would say, the original uptick in the -- in premium amortization on the MBS portfolio that -- and I'm not giving this to you in order of priority, but just in terms of inputs. The big -- the leg down in LIBOR, obviously, had a big impact in 2019. That's expected to be a little flatter at this point as we're looking into 2020.

The -- we talked about retail deposits -- or pardon me, retail deposit pricing and how as rates were increasing, we had put in place some promotions that have a little bit of a tail to them. That tail was fully in place during 2019, and it will abate during 2020, all of those things. But as -- and it's rates, right? It's -- they dropped in 2019. They're at least at the front end expected to be relatively flattish in 2020.

I see. And I think the?

And just to be -- just quick. The number of variables and the range of potential outcomes around those variables that goes into giving the low to mid-single digits is a lot can move. As we've talked about, we were -- I think we were quite close on our estimation for 2019, but we'll keep you updated as we roll along in 2020 on what it's looking like based on what changes.

You mentioned Pick-a-Pay. I guess I should also point out that, that was -- on a full year basis, it's probably $400 million worth of interest income coming off of the sold Pick-a-Pay loans. And that's worthy of a mention, too, that we don't have this year.

Great. Could you also share with us -- you pointed out that you grew the primary consumer checking account deposit 2% year-over-year. What's -- what are you using as the hook to get customers to come in? Is there some incentives, whether it's a higher upfront cash deposit or -- that you give them? Or is there gifts? Or how are you guys driving that growth?

Yes. So that metric is the number of accounts, not the deposits associated with the accounts, which we've talked about separately. Still, it's the branch network, it's the digital acquisition, the combination of those 2 things. I wouldn't say that it's specifically -- there's nothing that's compelling people. The offers that we use are more around dollars for additional -- capturing additional deposits from customers. But these account openings reflect the sort of everyday business model of Community Banking, both in the branches and through digital activity.

Okay. And then just real quickly. You mentioned lower gains in the quarter from your venture capital, private equity area. What's left in unrealized gains in those 2 categories for you folks?

Yes. So unrealized gains are harder to come by these days because we tend to realize them on a faster basis since the accounting change, I guess, now 1.5 years ago. It used to be the case that we'd have to actually realize something to recognize the benefit. Something had to be sold or go public in order for us to take a gain. And these days, even with private companies doing subsequent private capital raises, if they set a higher level of valuation, we recognize the gain from that as it goes along. And so when the ultimate realization occurs that there's less of a pop because we've ratcheted up, that we've taken gains along the way.

So that's led to more of, I'll call it, front-end loading over the last several quarters of benefit from that portfolio. And it will increase the volatility if people have down capital raise rounds or things don't go as well when companies are actually sold or taken public. So it's been a great business. The returns are solid, but the accounting change has caused the revenue recognition to be a little bit more choppy. Although in the early quarters, it's actually been very strong.

Your next question comes from the line of Scott Siefers with Piper Sandler.

I was hoping to try to drill down into the cost side once again. I guess if we're looking at an uptick in core expenses in the first quarter, it implies a pretty substantial downdraft through the remainder of the year just to keep us in the ballpark of this year's adjusted $53.7 billion. I mean, does the plan indeed call for such an absolute improvement in costs? And what's sort of the path to get there, especially at a time when there's so much discussion on investments? Just curious to hear your thoughts there.

Yes. Right. So we're not going to be that specific about the year as a whole. My comment earlier about the first quarter is like every first quarter, it tends to be the high tick for expenses because of the way personnel costs have a first quarter uptick. And so like any other year, on an adjusted basis, you'd expect them to be higher in the first quarter and gravitate down over the course of the year. But we're -- as Charlie mentioned, we're going through a second look at our planning process for the year and so there's no fixed number at this point to point to. Since we are in the first quarter, it's -- as this just happens every first quarter, I'm calling out the fact that those personnel costs will be higher. But we -- there won't be much more specificity around that until we've completed this process and made some conclusions, made some choices and come back and update people later in the year.

Okay. All right. So then rather than -- so even though the -- I guess, the $53.7 billion is a sort of place to start, it's not -- we shouldn't anticipate any sort of like flat trend or anything. It's basically TBD completely on what the expectation is for the full year. Is that correct?

I think that's appropriate, so that we don't mislead you, yes.

Your next question comes from the line of Betsy Graseck with Morgan Stanley.

Just wanted to understand on the planning process that Charlie announced at the beginning. I know, Charlie, you're not talking about time frames, but you've seen a lot of different types of institutions and a lot of different types of scenarios. And I'm wondering, is this something that we should consider as a get to best-in-class on a 3- to 5-year time frame? Or is this more of a 1 to 3? Just trying to understand, broad strokes, your thought process there.

Listen, I wish I could answer the question at this point. But I -- for all the reasons that I've spoken about, I just am not in a position to do that. I think we -- I don't want to be repetitive, so I apologize. But we've got to do the work to understand whether we're appropriately resourced against the historical activities. And then, honestly, as we go through these discussions in terms of how you get to best in class, I'm sure business by business will be very, very different in terms of what the time frame is. Some of them will be structural. Some of them will require some significant technology investment. Others could be burdened by just inefficiencies that we can get to quicker. So I'm not trying to be evasive. I just -- I can see there being several different answers when we look at different parts of the company to what it will actually look like when we're done with the work.

And does the work potentially have a result of exiting some of the businesses? Or do you think that that's really not on the table at this stage?

Well, I think I'll repeat what I said before, Betsy. I think that from -- when you look at our big business segments, there is tremendous sense because of the benefits our customers and clients get from them being under one roof. But like any other company, we should sit and ask the question, do we need to be doing absolutely everything? And we have been pruning along the way, and there's probably still some more pruning that we should probably do.

Your next question comes from the line of Steven Chubak with Wolfe Research.

So John, I was hoping to drill into some of the fee trends that you had spoken to in response to an earlier question. Certainly appreciate the detail you guys gave in Slide 27, helping us isolate some of the impacts from gains and other related sale impacts. As we think about trying to evaluate the core fee income generation power, just of the franchise today, after adjusting for some of these sales, if I look at that $8.7 billion you guys produced this quarter, I adjust for about $600 million that you guys cited in the slide and then, on top of that, adjust for deferred comp, other investment income adjustments, we get to a run rate of roughly $8 billion a quarter in core fee income generation. I know you're going to have equity market tailwinds just from what happened in the fourth quarter as we enter the year in 2020, but I'm just hoping to frame whether that $32 billion annualized run rate is a reasonable jumping off point after adjusting for some of those factors. Or anything else that you would cite for that matter?

Well, so it's not unreasonable in the sense that it captures the seasonal volatility of some of these things that tend to ebb and flow throughout the course of the year. And we've -- if we've adjusted out things that we sold, both from a game perspective as well as the run rate perspective, and it captures that, we're -- we do have elements, as you'll note, that ebb and flow relatively meaningfully from -- not just from quarter-to-quarter, but from year-to-year. And so we have had equity market tailwinds, as you mentioned, and we might continue to, but that will come and go. I think we sort of tend to look at a slightly longer time horizon on some of those line items and think about what the average has been over 5 quarters or so. Since we report it in 5 quarters, it's easy enough to do. There's nothing unreasonable about that approach.

There are some of these that we believe that, even while we're doing our work, we should be driving and growing and then some that will reflect the cycle of the market that we're in. Mortgage comes to mind in terms of where we are in the rate cycle and things like that.

Got you. And just one more follow-up for me. Just wanted to clarify some of your capital guidance. So I know that the last update that I can recall, and I'm sorry if this is wrong or misguided, you alluded to a 10.25% to 10.5% CET1 target that you guys were managing to. That always felt quite conservative. And in the earnings release, you actually referred to an internal target of 10%. I'm just wondering, as we think about future buyback and capital return plans, has there been any change in the firm's internal capital targets that you guys are ultimately managing to? Or how are you guys trying to think about that as you start to implement some of these changes that Charlie was speaking to earlier?

Yes. It's a good question. We're -- what we've been waiting for -- and specifically, our internal guidelines is 10%, and that includes the buffer on top of the 9% regulatory requirement. We've been talking about something that could be 10.25% to 10.5% waiting for what -- to know what CECL looks like in stress and what the stress capital buffer guidelines actually look like once they're implemented. And there's a belief, certainly because we're getting more CCAR clarity over the coming weeks, that we'll start to know whether we're going to know the answer to that this year. And then it's likely that the combination of those 2 things leads us to a slightly higher level. It could be conservative, but we'll know for sure once we are operating in a stressed capital buffer world.

Your next question comes from the line of Matt O'Connor with Deutsche Bank.

I'm sure you're a little tired of all the expense questions kind of near term. I do want to ask though longer term on cost. Charlie, you said about being best-in-class efficiency. And I guess just how do you define that? And I think a lot of investors and analysts, think of your direct peers as being like Bank of America, JPMorgan, maybe a U.S. bank as well. But are you kind of being literal, like your efficiency ratio should be in the ballpark or better than theirs? And if it is, it's just a -- it's a bold comment given where you're coming from and obviously reflects, I assume, optimism on both costs and revenue, but maybe you could just elaborate on some of those themes.

Sure. We're going business by business and selecting the peer group that best represents the -- either the products or the segments that establish what best-in-class looks like. So it could be the component pieces of our larger peers. It could be the component pieces of regional banks. And it could be the component on what the business is. And then for the company as a whole, the weighted average, the mix adjusted average of what those inputs are results in the outcome. That's part of this review process that Charlie had alluded to earlier. And it's definitely aspirational, as we sit here today, but that is the direction that we're setting for ourselves.

And as Charlie mentioned, for every business that we're likely to be in over the long term, we've got all of the benefits of scale working for us and very mature in most of them. And we should -- there's -- there may be specific reasons, and we'll address them if we find them, why we can't compete effectively with the most efficient, but that's what we're setting our sights for.

Okay. And then without putting any specific numbers around it, like as you think about improving efficiency, there were comments just going to be both kind of revenue and expenses. Should we think about it being somewhat balanced or is the vast majority coming from expenses or too early to know right now?

Too early to know. We know there's work to do on expenses, but it's too early to start attributing percentage driver, for example.

Matt, it's Charlie. Let me just add one thing because I do think it's important. This isn't something that I would say that John and I sit here in a room and believe, and then we get in the room with others and they argue with us. There's a clear understanding from our business leaders that this opportunity exists.

And I would say, quite frankly, there's very little conversation internally about the need to use revenue to improve the efficiency rate because we do understand that there are series of things that we do that are highly inefficient. That's not to say to get the best-in-class that we won't need some revenue growth to get there. But I just find it very encouraging the way people internally are thinking about it and what they're talking about as -- will -- as the types of things that will be in the line of sight.

Your final question will come from the line of John Pancari with Evercore.

On the spread income guidance of down low to mid-single digits, I know you reiterated that, but you also indicated that you are still pruning. Does that guidance factor in the pruning? And accordingly, any additional adjustments to your business base would not be all that meaningful to impact that guidance? Or would that guidance change if you did continue to prune?

If we continue to prune in ways that caused us to shed either loans or deposits, then we would adjust the guidance. It contemplates the company as it exists today.

Okay. All right. I just want to verify. And then in terms of CECL day 2 impact, I just want to get your thoughts on the appetite to lend in certain longer duration consumer areas. Has that been impacted at all by the implications of the new methodology?

That's a good question. We've done the work product by product to consider what the return characteristics are. And at this point, it's not likely that we change our appetite for longer duration consumer loans. It definitely -- depending on where you are in the cycle can cause you to think differently about what your returns are. But it hasn't caused anything to drop below hurdle level that says to us we need to either meaningfully reprice it or we think whether we're in the business.

Okay. And then lastly, just back to the expense expectations. Again, I know it's too early to give a more accurate expense expectation, but I know you're going through your planning process. So what's the timing? When should we think we will get a more precise expectation when it comes to full year expenses, Charlie?

Yes. I guess there's nothing more that I can say that I haven't already said. I think what I've said is that we've got this process to go through. There's a lot to do. And when we know something, we'll tell you. I wish I could be more specific, I really do, but we have a lot to do to get to what we think the right answer should be.

All right. Listen, thank you very much for your patience and joining us this morning. I do hope that you just walk away with just a couple of important thoughts.

We have work to do. It's clear what we have to do. We're committed to getting it done, and we will get it done. The quality of the franchise is still extraordinary. We have thousands and thousands of dedicated people across the company that come in every day to serve their clients. They're doing an extraordinary job. And we're going to do our part to help them do their job even better as time goes on.

And we think our future is very bright. And so we appreciate again the patience that you have and look forward to more conversations in the future.

Ladies and gentlemen, this concludes today's conference. Thank you all for participating. You may now disconnect.