The purpose of the Notice is to inform you about: (i) this Action, (ii) the terms of the proposed Settlement, and (iii) your rights in connection with a hearing to be held before the United States District Court, Northern District of California on August 17, 2023, at 10:00 a.m., to consider the fairness, reasonableness, and adequacy of the Settlement and related matters. The Notice also describes the steps to be taken by those who wish to seek to be potentially eligible to share in the distribution of the Net Settlement Fund in the event the Settlement is approved by the Court.

A class action is a type of lawsuit in which the claims of a number of individuals are resolved together, thus providing the class members with both consistency and efficiency. In a class action lawsuit, the Court selects one or more people, known as class representatives, to sue on behalf of all people with similar claims, commonly known as the class or the class members. In the Action, the Court has certified the Class and appointed Lead Plaintiff Construction Laborers Pension Trust for Southern California as the representative of the Class and Lead Counsel as Class Counsel.

The Court in charge of this case is the United States District Court for the Northern District of California, and the case is known as Purple Mountain Tr. v. Wells Fargo & Co., et al., No. 3:18-cv-03948-JD (N.D. Cal.). The judge presiding over this case is the Honorable James Donato, United States District Judge. The institution which is suing is called Lead Plaintiff, and those who are being sued are called Defendants. In this case, the Defendants are Wells Fargo and Timothy J. Sloan.

The Notice explains the lawsuit, the Settlement, your legal rights, what benefits are available, who is eligible for them, and how to get them. The purpose of the Notice is to inform you of this case, that it is a class action, and how you might be affected. It also informs you of the terms of the proposed Settlement, and of a hearing to be held by the Court to consider the fairness, reasonableness, and adequacy of the proposed Settlement, the proposed Plan of Allocation, and the application by Lead Counsel for attorneys’ fees and litigation expenses (the “Settlement Hearing”).

The Settlement Hearing will be held on August 17, 2023, at 10:00 a.m., before the Honorable James Donato, at the United States District Court, Northern District of California, Courtroom 11 – 19th Floor, 450 Golden Gate Avenue, San Francisco, CA 94102, for the following purposes: (a) to determine whether the proposed Settlement on the terms and conditions provided for in the Stipulation is fair, reasonable, and adequate and should be approved by the Court; (b) to determine whether the Judgment as provided for under the Stipulation of Settlement dated February 6, 2023 should be entered; (c) to determine whether the proposed Plan of Allocation for the net proceeds of the Settlement is fair and reasonable and should be approved by the Court; (d) to determine whether the application by Lead Counsel for an award of attorneys’ fees and litigation expenses should be approved; and (e) to rule upon such other matters as the Court may deem appropriate.

The Notice does not express any opinion by the Court concerning the merits of any claim in the Action, and the Court still has to decide whether to approve the Settlement. If the Court approves the Settlement, payments to Authorized Claimants will be made after any appeals are resolved, and after the completion of all claims processing. This process takes time. Please be patient.

A brief background of this case is provided on pages 3-4 of the Notice, and is also summarized on the case website. We do not have any more information regarding the background of this case beyond what is provided in the Notice and posted case documents.

If you are a member of the Class, you are subject to the Settlement unless you timely requested to be excluded. The Class consists of all Persons and entities who purchased or otherwise acquired the common stock of Wells Fargo during the period from November 3, 2016 through August 3, 2017, inclusive, and were damaged thereby. Excluded from the Class are Defendants, present or former executive officers of Wells Fargo and their immediate family members (as defined in 17 C.F.R. §229.404, Instructions (1)(a)(iii) and (1)(b)(ii)). Notwithstanding the foregoing exclusions, no Investment Vehicle shall be excluded from the Settlement Class.

Receipt of the Notice does not necessarily mean that you are a Class Member or that you are entitled to receive proceeds from the Settlement. If you wish to be potentially eligible to receive a distribution of the Settlement proceeds, you must complete, sign, and submit the Claim Form postmarked no later than August 21, 2023. You may also submit a Claim Form through this website by August 21, 2023.

We are unable to advise regarding claim eligibility prior to receiving and processing a Claim Form submission. We cannot be more specific than the information which has been included in the Notice and cannot interpret how the Notice or Plan of Allocation may apply to a specific claim prior to processing.

Please read the Notice and Class definition carefully and decide whether or not you wish to submit a Claim Form. If you are still not certain of eligibility and want for us to determine eligibility, you will need to submit a Proof of Claim Form along with supporting documentation for your transactions.

Email is not an acceptable submission method and claims submitted via email will not be reviewed for eligibility. As indicated in the general instructions for the Claim Form, you must either submit your claim via the online form on the File A Claim tab above or you can mail your completed and signed Claim Form to

Wells Fargo 2018 Securities Litigation
c/o Gilardi & Co. LLC
P.O. Box 8040
San Rafael, CA 94912-8040

If submitting via the online form, the link is found on the “File A Claim” tab above under the header “Submit Your Claim Form Online.”

Note that the link may be disabled at any time after the filing deadline and you will only be able to submit via mail to the address above.

If there were no Settlement and Lead Plaintiff failed to establish any essential legal or factual element of the alleged claims, neither Lead Plaintiff nor the Class would recover anything from Defendants. Also, if Defendants were successful in proving any of their defenses, the Class likely would recover substantially less than the amount provided in the Settlement, or nothing at all.

The Settlement provides that, in exchange for the release of the Released Claims (defined in the Notice) and dismissal of the Action, Wells Fargo has agreed to pay (or cause to be paid) $300 million in cash to be distributed after taxes, tax expenses, notice and claims administration expenses, and approved fees and expenses, pro rata, to Class Members who send in a valid Proof of Claim Form pursuant to the Court-approved Plan of Allocation. The Plan of Allocation is described in more detail in the Notice.

To be potentially eligible for a payment from the proceeds of the Settlement, you must be a member of the Class and must timely complete and return the Proof of Claim Form with adequate supporting documentation postmarked, if mailed, or received, if submitted online, no later than August 21, 2023.

Your share of the Net Settlement Fund will depend on several things, including the total dollar amount of claims represented by the valid Proof of Claim Forms that Class Members send in, compared to the dollar amount of your claim, all as calculated under the Plan of Allocation discussed on pages 5-8 of the Notice.

The Plan of Allocation explains how the Net Settlement Fund will be allocated among purchasers and/or acquirers of Wells Fargo common stock and how claimants’ “Recognized Claim” will be calculated. By following the instructions in the Plan of Allocation, you can calculate your Recognized Claim. However, the payment you receive will reflect your Recognized Loss Amount in relation to the Recognized Loss Amount of all persons submitting valid Claim Forms. Because the total of all Recognized Loss Amounts is expected to exceed the amount of the Net Settlement Fund, your Recognized Claim is not the amount of the payment that you will receive, but will (together with all other Class Members’ Recognized Loss Amounts) be used to calculate your (and other Authorized Claimants’) pro rata share of the Net Settlement Fund.

The Court ordered that the law firm of Robbins Geller Rudman & Dowd LLP represents the Class Members. These lawyers are called Lead Counsel. If you want to be represented by your own lawyer, you may hire one at your own expense.

The Settlement Hearing will be held on August 17, 2023, at 10:00 a.m., before the Honorable James Donato, at the United States District Court, Northern District of California, Phillip Burton Federal Building & United States Courthouse, Courtroom 11 – 19th Floor, 450 Golden Gate Avenue, San Francisco, CA 94102. The Court reserves the right to approve the Settlement or the Plan of Allocation, Lead Counsel’s motion for an award of attorneys’ fees and expenses, and/or any other matter related to the Settlement at or after the Settlement Hearing without further notice to the members of the Class.

If you do not wish to object in person to the proposed Settlement, the proposed Plan of Allocation, and/or the application for attorneys’ fees and litigation expenses, you do not need to attend the Settlement Hearing. You can object to or participate in the Settlement without attending the Settlement Hearing.

Unless the Court orders otherwise, any Class Member who does not object in the manner described in the Notice will be deemed to have waived any objection and shall be forever foreclosed from making any objection to the proposed Settlement, the proposed Plan of Allocation, or Lead Counsel’s request for an award of attorneys’ fees and litigation expenses. Class Members do not need to appear at the hearing or take any other action to indicate their approval.

Any Class Member who did not request exclusion such that it was received no later than January 26, 2023, may object to the Settlement, the Plan of Allocation, or Lead Counsel’s request for an award of attorneys’ fees and litigation expenses. You can ask the Court to deny approval by filing an objection. You cannot ask the Court to order a different settlement; the Court can only approve or reject the Settlement. If the Court denies approval, no settlement payments will be sent out and the lawsuit will continue. If that is what you want to happen, you must object.

Any objection to the proposed Settlement must be in writing. If you file a timely written objection, you may, but are not required to, appear at the Settlement Hearing, either in person or through your own attorney. If you appear through your own attorney, you are responsible for hiring and paying that attorney. All written objections and supporting papers must: (i) clearly identify the case name and number (Purple Mountain Tr. v. Wells Fargo & Co., et al., No. 3:18-cv-03948-JD (N.D. Cal.)); (ii) be submitted to the Court either by mailing them to the Clerk of the Court, United States District Court for the Northern District of California, 450 Golden Gate Avenue, San Francisco, CA 94102, or by filing them in person at any location of the United States District Court for the Northern District of California; and (iii) be filed or postmarked on or before July 27, 2023.

The notice of objection must include documentation establishing the objecting Person’s membership in the Class, including the number of shares of Wells Fargo common stock that the objecting Person: (i) owned as of the opening of trading on November 3, 2016; and (ii) purchased, acquired and/or sold during the Class Period, as well as the dates and prices for each such purchase, acquisition and sale, and contain a statement of reasons for the objection, copies of any papers, briefs, or other documents upon which the objection is based, a statement of whether the objector intends to appear at the Settlement Hearing, and the objector’s signature, even if represented by counsel. The objection must state whether it applies only to the objector, to a specific subset of the Class, or to the entire Class. In addition, the objector must identify all class action settlements to which the objector and his, her, or its counsel have previously objected. Documentation establishing membership in the Class must consist of copies of brokerage confirmation slips or monthly brokerage account statements, or an authorized statement from the objector’s broker containing the transactional and holding information found in a broker confirmation slip or account statement. Objectors who desire to present evidence at the Settlement Hearing in support of their objection must include in their written objection or notice of appearance the identity of any witnesses they may call to testify and any exhibits they intend to introduce into evidence at the hearing.

You may not object to the Settlement or any aspect of it, if you excluded yourself from the Class.

You may file a written objection without having to appear at the Settlement Hearing. You may not appear at the Settlement Hearing to present your objection, however, unless you have first filed a written objection in accordance with the procedures described above, unless the Court orders otherwise.

You are not required to hire an attorney to represent you in making written objections or in appearing at the Settlement Hearing. If you decide to hire an attorney, which will be at your own expense, however, he or she must file a notice of appearance with the Court by July 27, 2023.

The Settlement Hearing may be adjourned by the Court without further written notice to the Class, other than a posting of the adjournment on the this website. If you plan to attend the Settlement Hearing, you should confirm the date and time with Lead Counsel.

We do not hold stock records here. Gilardi & Company, LLC is a third-party administrator appointed by the Court to notify potential claimants. We are provided with names and addresses of potential claimants in order to notify individuals of settlements but do not have access for your investment records. We recommend you contact the institution where you held your shares and request proof or supporting documentation for your claim.

Separate Claim Forms should be submitted for each separate legal entity (e.g., a claim from joint owners should not include the transactions for an individual account, and an individual should not combine his or her IRA transactions with transactions made solely in the individual’s name).

However, a single Claim Form should be submitted on behalf of one legal entity that includes all transactions made by that entity, no matter how many separate accounts that entity has (e.g., an individual with multiple brokerage accounts should include all transactions made in all accounts on one Claim Form).

When filing on behalf of a deceased beneficial owner or their estate, you can submit a claim in the name of the individual, or, if an estate exists, you can submit on behalf of the estate. Note that any settlement proceeds will be made payable to the estate if that is how you submit that claim. The same rule applies for IRA's and other account types.

The claim submission should include a copy of the death certificate as well as proof of authority to file. As you are submitting a Claim Form as a representative on behalf of someone else (e.g., as an executor, administrator, trustee or other representative), you must document your authority to file on their (or their estate’s) behalf. Proof of authority can include a copy of the Last Will and Testament, Letters Testamentary, evidence of probate, proof of authority as executor or beneficiary and/or any other testamentary provisions of the deceased person. Do not send originals as any documents submitted with your claim will not be returned.

Depending on whether you submit on behalf of the individual on behalf of the estate, please provide the appropriate TIN or SSN. Then sign the Claim Form.

The claim must be submitted for the benefit of the actual beneficial owner/purchaser of the shares or their estate. Do not submit the claim in the name of the deceased person’s family or other heirs. We must issue the check to the actual beneficial owner/purchaser of the shares. We cannot issue any applicable check in the name of the deceased person’s family, beneficiaries or other heirs.

Sufficient documentation will provide all of the required transaction information. Typically, the required detail is transaction date, number of shares and total transaction price. Suggested forms of documentation are photocopies of stockbrokers' confirmation slips or stockbrokers' monthly statements reflecting your opening and closing balances for the months specified on the Claim Form, and in which transactions during the relevant period occurred.

Stock certificates are not considered a sufficient form of documentation as they do not provide the necessary trade date and transaction price information. We are also unable to accept handwritten documents, self-prepared tax forms or spreadsheets, or statements that are illegible due to document quality.

The Claims Administrator does not have the authority to grant extensions beyond the deadline. You are welcome to submit a Proof of Claim Form at this time understanding that it will be considered late. If you desire, you may also include a brief letter explaining why your claim is late.

We will process all late claims received, and as much as possible, include that information with our recommendations to Counsel. We generally recommend that late claims which are otherwise valid and eligible be considered for distribution, but it will be up to the Court and/or Counsel to determine whether or not late claims will receive consideration in this matter.

The Court will hold a Settlement Hearing on August 17, 2023, at 10:00 a.m., to decide whether to approve the Settlement. If the Court approves the Settlement, there might be appeals. It is always uncertain whether appeals can be resolved, and if so, how long it would take to resolve them. It also takes time for all the Claim Forms to be processed. Please be patient.

Processing time on our cases can take an average of 6 to 9 months from the August 21, 2023 filing deadline. Once processing is complete, we must then wait for authorization from Counsel and/or the Court before we can distribute the funds which can take several additional months.

Please understand that this is an estimated timeframe for processing based on our experience which does not guarantee that all case processing will be completed within nine months. Processing time varies from case to case and some cases may take more or less based on the specifics of that case settlement.

If your claim has been received and we have any questions or need additional information or documentation to assist in the processing of your claim, we will contact you by using one or more of the contact methods (phone, e-mail, mail) which you listed on your claim form submission.

We will not have the final claim payout amount available until we have processed all of the claims, calculated the total loss of claims filed and received approval from the Court and/or Counsel.

We appreciate your patience as accurate claims processing takes time.

Shares acquired via dividend reinvestment are purchases and are eligible if they occurred within the Class Period. Dividend reinvestments not related to the DRIP should be listed on the form. Cash dividends paid out of accounts, and not related to the purchase or acquisition of shares, are not eligible.

Purchases of partial shares related to a DRIP do not need to be listed on the claim submission but all claimed dividends must be fully documented. Simply enter the top holding, rounded to fit the spaces available if necessary, and enter a comment that purchases are related to the DRIP. Any purchases not related to the DRIP should be separately listed. If sales occurred, they should be documented, along with any end holding positions. The claimant must provide documentation of all claimed transactions and if the claimed transactions do not “balance” additional documentation will be requested.

If you do nothing, you will not receive any money from this Settlement. In addition, unless you excluded yourself, you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Defendants and their Related Persons about the Released Claims in this case.