The more you learn about Wells Fargo’s culture problems, the more difficult the problems become. But you have to start somewhere, and assuming that Wells Fargo really is committed to addressing the serious problems they face, this will take a long time and a lot of work.

Wells Fargo is really at the early stages of a massive remediation project. The board has essentially taken the matter over. Some would say that the board should have acted a long time ago, and was too trusting of senior management. That may very well be true and further investigation will reveal some answers to this important question.

As an initial step, like in life, Wells Fargo has to acknowledge the company had (and continues to have) a problem. Under the prior leadership- of CEO Stumpf, Wells Fargo tried to deny the problem and limit the extent of the problem.

Notwithstanding internal prior notices, line manager complaints, and complaints from whistleblowers, Wells Fargo denied the full extent of the problem. Just to refresh your recollection, under a Wells Fargo sales incentive program, local managers and bank officers were required to meet stringent sales targets built on the assumption of eight accounts (e.g. checking, credit card, cds) for each customer. As a result, Wells Fargo personnel created nearly 2 million (yes, two million) fake accounts to meet these ridiculous sales targets.

As a consequence, Wells Fargo is now facing major investigations from the Justice Department, the Department of Labor and the Securities and Exchange Commission. Previously, Wells Fargo settled with the CFPB, banking agencies and the City of Los Angeles for $185 million in penalties.

After much hand-wringing and delays, Wells Fargo’s board launched a major internal investigation of the incident, including serious issues raised about its handling of whistleblowers, several of whom were fired after raising concerns about the program. Whether Wells Fargo is able to conduct a serious internal investigation to uncover all of the facts and the reasons for the collapse of any corporate governance framework remains to be seen. As always, time will tell.

To be sure, Wells Fargo has some real difficult questions to answer, starting with the board itself for its wholesale lack of supervision over senior management. Former CEO Stumpf who has denied knowing about the problems with the sales program has to answer for internal documents which show he was notified about the problem but failed to act. It is not clear whether former CEO Stumpf read the internal documents but there are real issues surrounding his knowledge and failure to act.

Furthermore, former CEO Stumpf has to answer for something he definitely did do – he allowed Carrie Tolstedt, the senior executive responsible for overseeing the sales incentive program, to retire and collect a measly bonus of $124 million. Former CEO Stumpf has never answered for allowing this to occur after the scandal broke.

Recently, Wells Fargo fired four executives as it uncovered more information about the scandal and Wells Fargo’s failures. I am sure more heads will role but the question boils down to how Wells Fargo can ever recover and how long it will take.

Judging from comparable cases in the past, the question really is whether Wells Fargo will ever recover any positive reputation. The stain of this scandal is major and expected to continue for several years as it tries to put the matter behind it.

A major investigation is only one step. The question is whether Wells Fargo is ready to take the following steps that may require significant changes, including at the board level. Even with the commitment of a new senior leadership team, Wells Fargo’s cultural damage has occurred at every level of its operations – from branches to mid-level managers and to the C-Suite. Acknowledging a problem is one step, but committing to wholesale change is another.

Financial institutions are not known for being nimble. Wells Fargo needs to bring about structural and operational changes. To do so, Wells Fargo will have to make a major commitment to a separate and independent ethics function, as well as a wholesale expansion of its compliance office with resources.

Building a new culture can only be done with the commitment of the board and senior management. To implement such a new approach, the board and senior management have to empower and unleash independent ethics and compliance functions to follow through on their commitment. Such a process will take years of hard work, acceptance and commitment. Whether Wells Fargo can accomplish such a task remains to be seen.