"Mr. Hartzman does not identify any specific reporting practice by Wells Fargo with respect tho these "secret" loans

Sent: Wednesday, February 22, 2012 10:37 AM

from: george.hartzman@wellsfargoadvisors.com to: aaron.l.landry@wellsfargoadvisors.com, danny.ludeman@wellsfargoadvisors.com, john.g.stumpf@wellsfargo.com, d.carroll@wellsfargo.com, stacey.mitchell@wellsfargoadvisors.com, don.geczi@wellsfargoadvisors.com, baconmij@wellsfargo.com, bill.rogers@wellsfargoadvisors.com, doug.lowe@wellsfargoadvisors.com, BoardCommunications@wellsfargo.com, karl.f.riem@wellsfargo.com, Grant.Carlson@wellsfargo.com, Bruce.J.Berrol@wellsfargo.com

Attachments; 10k.doc
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“LIQUIDITY AND FUNDING

Asset liquidity is further enhanced by our ability to sell or securitize loans in secondary markets and to pledge loans to access secured borrowing facilities through the Federal Home Loan Banks, the Federal Reserve Board, or the U.S. Treasury.

[Ability doesn't mean borrowed]

Short-term borrowings averaged $65.8 billion in 2008 and $25.9 billion in 2007, an increase of $39.9 billion due to business funding needs.”

Wells Fargo 2008 10k

[no mention of FED TAF loans or Discount Window borrowing]
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Falsification of any company…information that you provide is prohibited.

Falsification refers to knowingly misstating, altering, adding information to, or omitting or deleting information …which results in something that is untrue, fraudulent, or misleading.

Wells Fargo’s Code of Ethics and Business Conduct
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“Asset liquidity is further enhanced by our ability to sell or securitize loans in secondary markets and to pledge loans to access secured borrowing facilities through the Federal Home Loan Banks, the FRB, or the U.S. Treasury.

Short-term borrowings averaged $52.0 billion in 2009 and $65.8 billion in 2008.

We reduced short-term borrowings due to the continued liquidation of previously identified non-strategic and liquidating loan portfolios, soft loan demand and strong deposit growth.”

2009 10k

[no mention of FED TAF loans or Discount Window borrowing]
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Short-Term Borrowings

2007: 53,255.0

2008: 108,074.0

2009: 38,966.0

2010: 55,401.0

[no mention of FED TAF loans or Discount Window borrowing]
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Sarbanes–Oxley Act

...mandates that senior executives take individual responsibility for the accuracy and completeness of corporate financial reports.

...Section 302 requires that the company's "principal officers" (typically the Chief Executive Officer and Chief Financial Officer) certify and approve the integrity of their company financial reports quarterly.

Title IV ...requires timely reporting of material changes in financial condition...

Sarbanes-Oxley required the disclosure of all material off-balance sheet items.

It ...specifies the responsibility of corporate officers for the accuracy and validity of corporate financial reports.

...The CEO and CFO are now required to unequivocally take ownership for their financial statements under Section 302…

Title IV ...requires timely reporting of material changes in financial condition...

Sarbanes-Oxley required the disclosure of all material off-balance sheet items.

Wikipedia