Millions of Accounts Were Opened Without Customers' Knowledge

More than two million bank and credit card accounts were opened without customers' knowledge. Thousands of employees lost their jobs. Senior executives resigned. Billions of dollars in fines and settlements followed, and one of America's largest banks spent years rebuilding its reputation.

From the outside, the response appeared decisive. Employees were terminated, executives stepped down, sales incentive programs were eliminated, and new oversight was introduced. It looked like an organization confronting a major failure and taking meaningful action.

That is where many discussions of the scandal end. An investigation begins somewhere different.

Before deciding whether the response solved the problem, we first need to understand what problem the evidence says the organization was trying to solve.

The available evidence establishes several facts with reasonable confidence. Leadership introduced aggressive cross-selling goals intended to increase the number of products each customer used. Performance was measured against those goals, and employees understood that meeting those expectations was central to their success. Over time, unauthorized accounts, forged signatures, and transfers between customer accounts became increasingly common. Internal complaints, employee reports, and warning signs accumulated long before regulators intervened.

Those facts tell us what happened. They do not, by themselves, explain why the behavior became widespread or why it continued for years. Observable events and underlying causes are not the same thing, and an investigation should resist filling that gap with assumptions. Instead, it should continue asking what the evidence actually supports.

One observation stands out. The fraudulent behavior did not emerge overnight. It developed over many years while sales results continued to meet or exceed expectations. The organization was receiving exactly the outcomes it was measuring.

That observation naturally leads to another question.

How were those results being achieved?

The evidence shows that concerns were raised. Employees reported unrealistic expectations. Individual employees were disciplined or dismissed for misconduct. Internal reports described aggressive sales practices. Yet the broader pattern continued to expand until regulators uncovered a systemic problem.

Those observations suggest there were opportunities to investigate not only what employees were accomplishing, but how they were accomplishing it. The available evidence clearly demonstrates a thorough investigation after the scandal became public. It is less clear whether the organization investigated the methods producing unusually successful results before the scandal emerged.

The evidence suggests the organization focused on measuring results without giving the same attention to understanding how those results were produced. That distinction matters because unusual success deserves the same level of investigation as obvious failure.

That matters because organizations rarely fail without leaving signals first. The evidence shows the signals were present. The unanswered question is whether enough attention was given to understanding what those signals meant.

Once the misconduct became public, the organization responded aggressively. Employees were terminated. Executives resigned. Incentive systems were redesigned. Oversight increased. These actions addressed the visible consequences of the scandal and demonstrated accountability.

The investigation, however, raises a different question.

Which part of the problem did those actions actually address?

Correcting visible failures and understanding how those failures developed are related, but they are not the same. One responds to the consequences. The other investigates the conditions that allowed those consequences to become normal. Without understanding those conditions, it is difficult to know whether the intervention addressed the underlying problem or only its most visible effects.

This distinction matters because organizations often become focused on restoring order after a crisis. While that work is necessary, it should not replace the effort to understand how the crisis became possible. Evidence should guide both the correction and the investigation.

The investigation suggests a different opportunity may have existed long before the scandal became public.

As sales numbers continued to improve, leaders understandably focused on the outcomes they were seeing. The available evidence shows considerable attention was given to whether targets were being achieved. What is less evident is whether the organization consistently investigated how those targets were being achieved.

If the evidence points to a gap between the expected outcome and the methods producing it, the next step is not another assumption. It's a conversation.

"Walk me through how these results are being achieved."

That question does not accuse anyone of wrongdoing, nor does it assume a problem exists. Instead, it invites people to explain their work. It surfaces the practices, assumptions, and decisions behind the numbers. It creates an opportunity to compare expected methods with actual methods before those differences become normalized.

Organizations routinely investigate poor performance. Fewer investigate exceptional performance with the same level of curiosity. Yet unusual success can be just as revealing as obvious failure. When leaders become curious about how exceptional results are produced, they are more likely to discover hidden workarounds, unintended incentives, and emerging coordination problems while they are still small enough to address.

This pattern extends well beyond banking. Organizations often become highly skilled at measuring outcomes while investing far less attention in understanding how those outcomes are produced. As long as the numbers continue to improve, success can conceal the very behaviors that eventually create failure.

The challenge is not unique to sales. It appears anywhere performance is rewarded, assumptions go untested, and unusual success escapes careful examination. Whether the setting is business, healthcare, government, education, or a family, the investigation begins with the same question:

How are these results actually being achieved?

Effective interventions distinguish between correcting what happened and understanding what allowed it to happen. Corrective actions restore order. Understanding helps prevent the same pattern from emerging in a different form.

Evidence should drive the diagnosis. Understanding should drive the intervention.