Wells Fargo Lessons -

The recently released independent investigative report of the Wells Fargo sales model controversy provides a surprising number of important oversight, structural and reporting lessons for the corporate leadership of health care industry companies.

Primary among these is the potential for performance targets and "sales" goals to incentivize employee behavior that is inconsistent with law or corporate culture. Another important lesson relates to the risk and compliance oversight challenges associated with a decentralized corporate structure. Associated concerns include the effectiveness with which risk is identified, the ability to recognize the materiality of such risk, and the timing and sufficiency of risk reporting to the board.