FINRA has issued a very public notice asking former Wells Fargo employees whose securities registrations were terminated to get in touch if they think that the bank gave false or misleading information on their FINRA termination forms.

FINRA proposes to investigate allegations that it says surfaced in the media that some employees were fired "for reporting or refusing to engage in allegedly fraudulent account-opening activities. "

Others have, FINRA says, said that the dismissed employees either did not receive their "Form U5" within the required 30 days and that others say " that their Form U5 contained inaccurate or incomplete comments related to the reason for the termination."

FINRA is concerned about the regulatory aspects of the termination notices but that's not really big issue.

If it is right that Wells Fargo has so institutionalised the opening and operation of false or fraudulent accounts (and that has not been investigated, much less proved) that it is comfortable firing staff who object, that calls into question at the most fundamental level the financial crime, especially money laundering and terrorist financing, risks of doing business with them. That means that their risk rating must increase.

That's a serious problem for a bank which, after all, has no real assets except its reputation.