Two former Wells Fargo advisors are suing the firm for breach of contract, unfair business practices, and retaliation after they say they resisted pressure from their supervisors to secretly transfer sensitive client information from the advisor and brokerage side of the company to the private bank.
The advisors, Karen Keusayan and Richard Green, are also alleging that Wells Fargo improperly withheld deferred compensation after they resigned in 2021 and joined Morgan Stanley , where they are still registered.
In their complaint, filed in Los Angeles County Superior Court, the advisors describe themselves as high-producing employees who were loyal to the company even through the “nightmarish” years of 2015 to 2017, when Wells Fargo’s banking division was “publicly scorned” for the fake account scandal.
“This is not the ‘sour grapes’ case of a disgruntled employee(s) who sought a promotion and did not get one,” the advisors say in their complaint. “Neither Ms. Keusayan nor Mr. Green ever wanted to leave Wells Fargo. The goal for each had always been to retire at Wells Fargo.”
Wells Fargo declined to comment on the lawsuit.
The two advisors joined forces in 2015 to form a “production partnership,” according to the complaint, which says they grew their book of business to more than $1 billion by 2020.
In 2018, Wells Fargo introduced a new element to its advisor compensation plan, according to the complaint. Advisors were expected to complete forms called client discovery reviews, or CDRs, detailing information about advisory clients. The plaintiffs say they were directed by a compliance officer to keep the forms secret from the clients themselves.
Instead, the CDRs were intended for Wells Fargo’s private bank, “not the broker-dealer/financial services side where plaintiffs worked,” according to the complaint.
They contend that advisors were pressured to work with clients to complete CDRs, which would be secretly shared with Wells Fargo private bankers who could use them as sales leads.
Before submitting the forms to count toward a quota that resulted in additional compensation, the advisors had to check three boxes stating that they had discussed the information with the client, that the information was accurate, and that they had offered the client an opportunity to obtain a copy of the document. On that last item, the plaintiffs allege that Wells Fargo essentially instructed the advisors to lie, explaining that the document didn’t belong to the advisors, but the bank, even though the information came from their own clients.
“[H]igh-ranking compliance personnel at Wells Fargo Advisors repeatedly told plaintiffs to never deliver or present the CDR to the client since, as it was explained by compliance, the CDR was a bank document,” the complaint states. “Worse, plaintiffs were told not to inform the client that a CDR had been prepared.”
The plaintiffs say that these “dishonest instructions” put them in an “impossible position” and that they soon began raising concerns with their superiors. But each time they spoke out, they were told by their supervisors to continue submitting the forms as a requisite part of the company’s compensation plan.
The complaint describes the advisors’ growing unease with being pressured to falsify the CDR submission document, as well as concerns over the personal privacy of their clients, whose information was allegedly being shared internally without their knowledge or permission.
The advisors say that their bosses undertook a retaliatory campaign against them for continuing to raise objections to the CDR program, “including by failing to provide the banking support that plaintiffs and their clients had come to expect as a benefit of being associated with a large, full-service, retail bank,” according to the complaint.
They also say that the advisors felt their jobs were at risk, offering examples of a hostile or coercive work environment. “Mr. Green was berated by a yelling supervisor in front of fellow employees, and Ms. Keusayan was informed that the bank would not issue a routine credit card to her sister (a customer) if a CDR was not on file,” according to the complaint.
The advisors say the deteriorating work environment ultimately led them to resign around July 2021, after which they were informed that they were ineligible for large sums of deferred compensation—$662,000 for Keusayan and nearly $814,000 for Green.
The advisors are seeking to recoup the deferred comp they say they are owed, and are asking the court for additional damages, as well as an injunction barring Wells Fargo from engaging in the conduct alleged in the complaint, among other relief.
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The lunar flyby would be the deepest humans have traveled in space in decades.
It’s go time for the highest-stakes mission at NASA in more than 50 years.
On April 1, the agency is set to launch four astronauts around the moon, the deepest human spaceflight since the final Apollo lunar landing in 1972.
The launch window for Artemis II , as the mission is called, opens at 6:24 p.m. ET.
National Aeronautics and Space Administration teams have been preparing the vehicles to depart from Florida’s Kennedy Space Center on the planned roughly 10-day trip. Crew members have trained for years for this moment.
Reid Wiseman, the NASA astronaut serving as mission commander, said he doesn’t fear taking the voyage. A widower, he does worry at times about what he is putting his daughters through.
“I could have a very comfortable life for them,” Wiseman said in an interview last September.
“But I’m also a human, and I see the spirit in their eyes that is burning in my soul too. And so we’ve just got to never stop going.”
Wiseman’s crewmates on Artemis II are NASA’s Victor Glover and Christina Koch, as well as Canadian Space Agency astronaut Jeremy Hansen.

What are the goals for Artemis II?
The biggest one: Safely fly the crew on vehicles that have never carried astronauts before.
The towering Space Launch System rocket has the job of lofting a vehicle called Orion into space and on its way to the moon.
Orion is designed to carry the crew around the moon and back. Myriad systems on the ship—life support, communications, navigation—will be tested with the astronauts on board.
SLS and Orion don’t have much flight experience. The vehicles last flew in 2022, when the agency completed its uncrewed Artemis I mission .
How is the mission expected to unfold?
Artemis II will begin when SLS takes off from a launchpad in Florida with Orion stacked on top of it.
The so-called upper stage of SLS will later separate from the main part of the rocket with Orion attached, and use its engine to set up the latter vehicle for a push to the moon.
After Orion separates from the upper stage, it will conduct what is called a translunar injection—the engine firing that commits Orion to soaring out to the moon. It will fly to the moon over the course of a few days and travel around its far side.
Orion will face a tough return home after speeding through space. As it hits Earth’s atmosphere, Orion will be flying at 25,000 miles an hour and face temperatures of 5,000 degrees as it slows down. The capsule is designed to land under parachutes in the Pacific Ocean, not far from San Diego.

Is it possible Artemis II will be delayed?
Yes.
For safety reasons, the agency won’t launch if certain tough weather conditions roll through the Cape Canaveral, Fla., area. Delays caused by technical problems are possible, too. NASA has other dates identified for the mission if it doesn’t begin April 1.
Who are the astronauts flying on Artemis II?
The crew will be led by Wiseman, a retired Navy pilot who completed military deployments before joining NASA’s astronaut corps. He traveled to the International Space Station in 2014.
Two other astronauts will represent NASA during the mission: Glover, an experienced Navy pilot, and Koch, who began her career as an electrical engineer for the agency and once spent a year at a research station in the South Pole. Both have traveled to the space station before.
Hansen is a military pilot who joined Canada’s astronaut corps in 2009. He will be making his first trip to space.
Koch’s participation in Artemis II will mark the first time a woman has flown beyond orbits near Earth. Glover and Hansen will be the first African-American and non-American astronauts, respectively, to do the same.
What will the astronauts do during the flight?
The astronauts will evaluate how Orion flies, practice emergency procedures and capture images of the far side of the moon for scientific and exploration purposes (they may become the first humans to see parts of the far side of the lunar surface). Health-tracking projects of the astronauts are designed to inform future missions.
Those efforts will play out in Orion’s crew module, which has about two minivans worth of living area.
On board, the astronauts will spend about 30 minutes a day exercising, using a device that allows them to do dead lifts, rowing and more. Sleep will come in eight-hour stretches in hammocks.
There is a custom-made warmer for meals, with beef brisket and veggie quiche on the menu.
Each astronaut is permitted two flavored beverages a day, including coffee. The crew will hold one hourlong shared meal each day.
The Universal Waste Management System—that’s the toilet—uses air flow to pull fluid and solid waste away into containers.
What happens after Artemis II?
Assuming it goes well, NASA will march on to Artemis III, scheduled for next year. During that operation, NASA plans to launch Orion with crew members on board and have the ship practice docking with lunar-lander vehicles that Elon Musk’s SpaceX and Jeff Bezos’ Blue Origin have been developing. The rendezvous operations will occur relatively close to Earth.
NASA hopes that its contractors and the agency itself are ready to attempt one or more lunar landing missions in 2028. Many current and former spaceflight officials are skeptical that timeline is feasible.
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