This month marks the one-year anniversary of the Wells Fargo fake account scandal, a debacle that resulted in the bank’s CEO stepping down, a nearly $200 million payout to regulators and an ongoing public relations nightmare. Even as of last week, Wells Fargo had admitted to turning up more than a million additional accounts that customers did not authorize according to the New York Times. While some observers were quick to attribute the problem to a sales compensation program gone awry, in fact, Wells Fargo’s compensation model worked precisely as it was designed. The sales behavior the company was driving was to get associates to cross-sell at least eight accounts per customer. The only problem, of course, was that at least 3.5 million (at latest count) of those bank and credit card accounts were not authorized. Wells Fargo wasn’t the first or last high-profile example of a large organization creating quotas that are so aggressive and unrealistic that salespeople felt compelled to lie or fake results to keep their jobs. Last year alone we saw high profile cases at the Harvard University endowment fund and the National Guard. What is concerning about many of these cases, however, is just how high up the corporate ladder the scandals went. Culture, not compensation was to blame. In the case of Wells Fargo, the cultural anomalies that led to that situation likely ran wide and deep. Too often companies approach sales compensation in far too insular a way. It’s one leader determining what the goal should be and often that person has little background in sales compensation planning. With Wells Fargo, it was publicly noted to be the CEO himself that came up with the mantra that “Eight is Great.” But did that plan align with the values of the company? Was it in the best interest of employees and customers? Clearly not. When designing sales plans, companies need to engage multiple points of view – sales ops, finance, HR, etc. – to ensure plans are both achievable, but also in line with the broader corporate goals. At the same time, it’s critical that people throughout the process are empowered to call a “time out” if an overzealous executive pushes an agenda that seems misaligned with company values. But equally as important, the right checks and balances have to be in place, and someone has to be analyzing the outcomes. I have long wondered if anyone at Wells Fargo was taking an in-depth look under the covers to see if all the new accounts being opened were even active. They would have found that they weren’t - a huge red flag. In my two decades in sales compensation, I thought I had seen just about everything – but never a case that has run quite so wide and deep as this. I wonder how many more similar scandals are lurking out there just waiting to explode. One thing is for certain, the floodgates are open and no executive team can afford to turn a blind eye. Their brand reputation and quite frankly, jobs are at stake. There is nothing illegal about having an aggressive sales compensation program – it’s one of the key strategic levers helping companies effectively compete and win in their respective markets. But I implore you to think about what behaviors you are trying to drive and ask yourself, “does this program align with who we are as a company and what we stand for?” If the answer is no, it’s time to go back to the drawing board.