By forcing the cost of severance down from "top of house" to the division/unit level Scharf is deliberately incentivizing managers to give unwarranted poor reviews to good people so that they can be fired "for cause" with no severance, no cost to the bank. While callous, cold and calculating, it's perfectly legal.
Scharf knows that Secretary of Treasury Bessent and President Trump are pushing hard to deregulate banking which directly impacts staffing at all banks. By eliminating the CFPB and loosening regulatory oversight, employees whose duties include this funciton are no longer needed because the people they answer to in the government agencies are gone.
WF is removing coordination roles in a way that purposefully avoids the visibility that normally accompanies large layoffs. WF distributes reductions in smaller groups across several sites — for example, eliminating roles in increments of 40 or 45 across different regions over several months. None of these individual events reaches the WARN Act threshold that would require public disclosure. Challenger, Gray & Christmas refers to this as the pattern of "forever layoffs" — ongoing workforce optimization rather than discrete restructuring.
The weakening of worker protection enforcement — reduced CFPB oversight of employment-related financial products, reduced NLRB enforcement capacity, weakened EEOC investigation resources — makes this quiet, distributed layoff approach less legally risky for banks. The institutional deterrent against conducting large-scale reductions in ways that might constitute systematic discrimination or age-based targeting has weakened alongside the broader regulatory rollback.