Mind the GAP: Wells Fargo Faces New Charges
Wells Fargo has once again found itself under regulatory scrutiny following an internal review and external inquiry that may have uncovered funds owed to car buyers who purchased GAP and paid their loans off early.


San Francisco-based Wells Fargo may have added unpaid GAP refunds to its list of regulatory woes. Photo by Davide D’Amico
SAN FRANCISCO — On the heels of an announcement that Wells Fargo will begin issuing refunds to more than half a million customers affected by issues related to sales of collateral protection insurance (CPI), the company now faces charges of failing to properly compensate car buyers who purchased guaranteed asset protection (GAP) coverage through Wells Fargo Dealer Services and paid their loans off ahead of schedule.
The GAP issue appears to have been raised in the course of an external inquiry ordered by the Federal Reserve Bank of San Francisco, where Wells Fargo is based. In a statement sent to The New York Times, however, spokeswoman Jennifer Temple said the company “discovered issues related to a lack of oversight and controls” during an internal review.
“We are reviewing our practices and actively working with our dealers and have already begun making improvements to the GAP refund process,” Temple’s statement read, in part. “If we find customer impacts, we will make customers whole.”
Wells Fargo’s directors also mentioned the GAP issue in the company’s most recent quarterly financial statement, referring to “certain issues related to the unused portion of guaranteed auto protection waiver or insurance agreements … which may result in refunds to customers in certain states.” Nine states require insurance providers to return unused insurance funds to customers: Alabama, Colorado, Indiana, Iowa, Maryland, Massachusetts, Oklahoma, Oregon and South Carolina.
The company’s plans to remediate affected purchasers of CPI policies were announced last week. In a statement posted to Well Fargo’s website, Franklin Codel, the executive who leads the company’s consumer lending division and, by extension, Wells Fargo Dealer Services, alluded to a companywide culture change in announcing the CPI remediation plan.
“In the fall of last year, our CEO and our entire leadership team committed to build a better bank and be transparent about those efforts,” Codel said, explaining that the CPI issue was uncovered by the company's own analysts. “Our actions over the past year show we are acting on this commitment.”
After reviewing CPI policies sold between 2012 and 2017, Wells Fargo identified about 570,000 car buyers who “may have been impacted” and determined that $64 million in cash remediation and $16 million worth of account adjustments would have to be performed. It is not known whether or how many customers will be owed compensation as a result of the company’s review of its GAP program.
More F&I

Smaller Loans, Longer Terms
The youngest generation of car buyers is more likely to finance less expensive vehicles, more than half of generation Z consumers borrowing less than $25,000.
Read More →
New Lifetime Battery F&I Product Meant to Drive Dealer Traffic
EFG Cos. offering is intended to create lifetime auto dealer engagement with customers.
Read More →
The Psychology Behind Menus That Increase Add-On Sales
There is a science to crafting a menu that gives customers confidence in the choices presented, and moving the process outside the F&I office can further boost results.
Read More →
Why Your F&I PVR Is Misleading You
Here’s a handy checklist of the numbers to track in 2026 instead.
Read More →
Auto Consumer Anxiety Presents Opportunity
A survey of U.S. drivers found the majority are concerned about finances and the economy, but those fears make many ready to buy vehicle-protection products.
Read More →
Humble and Hungry: 12 Rules for an F&I Life
Dustin Gingerich, with a decade in the F&I business under his belt, shares his thoughts on leadership, building trust with customers, and the importance of learning and innovation.
Read More →
Focus on the Opening
F&I managers must learn as much as possible about their customers, starting before they walk into their offices. The bulk of today’s consumers expect that, and good results will follow.
Read More →
F&I Reaches for the Sky
The increasingly important profit center continued making gains in the first quarter, according to StoneEagle data, ancillary products proving more popular as consumers hold onto their buys longer.
Read More →
What Market Timing Mistakes Mean for Your Reinsurance Program
When volatility hits, dealer-owned reinsurance programs face a familiar temptation: pull back and wait for calmer waters. New data from BOK Financial shows why that instinct can quietly cost you years of surplus growth.
Read More →
The 90/10 Rule
In this video, Ryan Ruff explains the rule that elite sales professionals use to turn ordinary conversations into unforgettable customer experiences.
Read More →