The recent story about the fraud committed by Wells Fargo employees caught my eye.

According to the story over 2MM unauthorized credit card transactions and openings of checking and savings accounts occurred, all unbeknownst to its customers.

Wells Fargo's criminal activity does not interest me. Fraud in the financial services industry today is like mass shootings: both are so frequent, it is hard not to become inured.

The woman who headed the unit responsible for the fraud, Ms Carrie Tolstedt, recently announced her retirement and is walking away with a package estimated to be close to $125MM.

That doesn't interest me either. CEOs committing crimes, defrauding investors, mismanaging resources and walking away with millions...prosaic actually.

I'm a management consultant. What caught my eye is the statements issued by Wells Fargo and made by their CEO, John Stumpf, indicating that the problem rested solely with the employees involved in the illegal activity ("bad actors" in the vernacular) and further stating, categorically, that they do not have a culture problem at Wells Fargo.

Uh, Mr. Stumpf...yes you do.

When thousands of employees cheat hundreds of thousands of customers and make millions of dollars doing it, you have a culture problem.

When the leader of the unit responsible for these illegal activities 1) receives roughly $9MM...in annual pay...for the five years that preceded the public news of the fraud, 2) is cited in public documents for her "high cross-selling ratios" and 3) is held up as "a standard bearer of our culture" and a "champion for our customers," you have a culture problem.

When a separate class action law suit from some of the former 5000 employees who were fired over the last five years alleges they were fired not for illegal activity, but for not meeting cross-selling goals and for not going along with the "aggressive sales tactics," you have a culture problem.

When a company is caught in flagrante delicto...with its britches around its ankles for the last five years...and issues public statements stating that they do not have a culture problem and that its "entire culture is centered on doing what is right for our customers," you don't have a culture problem, you have a serious culture problem. And the CEO's very response hangs Christmas lights on the underlying reality.

Like the snow coming down the mountain...That landed on Wounded Knee. Nobody wants to take the weight... the responsibility. Prince (2002) From the song Avalanche onOne Nite Alone Solo Piano and Voice [CD]

My friend Diana Chapman has co-authored a book called The 15 Commitments of Conscious Leadership. If you are interested in leadership, high performing teams, and organizational development/effectiveness, it would be impossible to recommend her book highly enough.

One of the 15 principles is Taking Radical Responsibility. According to Diana, the entire game changes for individuals, couples, teams, and companies when they take...not accept...take responsibility for the situations they find themselves in.

No snowflake in an avalanche is responsible. When a large number of snowflakes land on steep and slippery slopes, avalanches are likely to occur along with the concomitant potential for great destruction. And the steep and slippery slope that caused the avalanche at Wells Fargo is...unequivocally...their corporate culture.

How do you define/create culture? Larry Bossidy the former General Electric executive and former Chairman and CEO of Allied Signal gave the most parsimonious definition of culture I have ever heard: "Culture is the behavior of leaders." Period.

I am sure there is still a lot to sort out about the Wells Fargo story. But five years ago, employees started to get fired for either cheating grandpas and grandmas out of their money (bad news for Wells Fargo...because it means that the management team knew about the behavior for a long time) or for not cheating grandpas and grandmas out of their money (also bad news for Wells Fargo...because that means the management team was essentially incentivizing fraudulent behavior).

You know what happened six years ago...one year before Wells Fargo employees started to get fired? John Stumpf became CEO. Coincidence? I say, smart money is on the sidelines.

As night follows day, corporate settlements follow corporate crimes. In this case, Wells Fargo settled for $185MM. Like the boards and management of many companies, they settled to avoid admitting wrong doing, to get the story behind them, and to perhaps avoid criminal prosecution and jail time. CEO Stumpf, so far, has skated away.

But if Mr. Stumpf does not accept responsibility for the culture he helped create...if he and his management team do not have blindingly candid dialogues about what they can learn and how they can grow and change from this...and if they don't use the insights from those conversations to fix what is broken about the culture at Wells Fargo, this will be Mr Stumpf's last management assignment. It may be his last assignment either way.

I'm someone who counsels leaders on how to take the steps needed to help their teams create and sustain long term excellence for all their constituencies. As such, I am a student of leadership behavior, both laudable and deplorable.

What Mr. Stumpf and his team do next...now that interests me.