Envision "price modeling is not included in Envision's default setting becuase:"

"(a) there are no products represented in Envision, only asset classes which are not associated with fees;

(b) most plans include external assets which are held at other institutions such that the fees for those assets cannot be accurately included..."

Gregory C. Keating
Littler Mendelson
Boston, MA
617.378.6003 direct
gkeating@littler.com
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Mr. Keating's above statements are factually incorrect, and misleading.
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"(a) there are no products represented in Envision, only asset classes which are not associated with fees;"

When most of Wells Fargo's Envision financial plans were created, client's individual investments were automatically included into the plan software and then classified into asset classes.

If an advisor chose to, he/she could print a total listing of the client's individual investments within the client Envision report presentation.

By converting client individual investments into asset classes, the software gives the advisor the ability to not include what clients are being charged.
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"most plans include external assets which are held at other institutions such that the fees for those assets cannot be accurately included..."

I believe most plans do not include external assets.

The fees for external assets can be pretty easily included if necessary.

"cannot be accurately included."

Bullshit.

Any financial planner with experience knows how to do it right.

Those financial planners who don't include the fees are misleading their client/prospects.
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Many Wells Fargo Envision Plans created to earn 4front bonuses did not include investment fees. On September 7, 2012, in front of 25 to 40 financial advisors at the Hyatt Regency St. Louis at The Arch, Greg Shiveley, Envision Sales Manager at Wells Fargo Advisors, said “There are 441,942 households with Envision Plans of Record.” and “The overwhelming majority of Envision Plans do not include investment costs."

The above "internal use only" document shows Wells Fargo purposefully changing what was called "Annual Investment Fee" to "Return Discount Rate".

How is a client supposed to know what a "Return Discount Rate" is?

Envision
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FINRA Rule 2210 states "All member communications must be based on principles of fair dealing and good faith, must be fair and balanced, and must provide a sound basis for evaluating the facts in regard to any particular...service. No member may omit any material fact or qualification if the omission, in light of the context of the material presented, would cause the communications to be misleading. No member may make any false, exaggerated, unwarranted, promissory or misleading statement or claim in any communication. No member may publish, circulate or distribute any communication that the member knows or has reason to know contains any untrue statement of a material fact or is otherwise false or misleading.”

“Information may be placed in a legend or footnote only in the event that such placement would not inhibit an investor's understanding of the communication. Members must ensure that statements are clear and not misleading within the context in which they are made, and that they provide balanced treatment of risks and potential benefits. ...Members must consider the nature of the audience to which the communication will be directed and must provide details and explanations appropriate to the audience. Communications may not predict or project performance, ...or make any exaggerated or unwarranted claim, opinion or forecast... Any comparison in retail communications between investments or services must disclose all material differences between them, including (as applicable) investment objectives, costs and expenses..."
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There are most likely more than 400,000 Wells Fargo households that are being misled on their monthly statements, and FINRA/SEC/DOJ didn't/won't do anything about it.