At the outset of the cap, neither the bank nor Fed expected the process would take as long as it has, people familiar with the situation have said. In September, Wells Fargo submitted a new proposal for completing its overhaul after the Fed rejected an earlier version drafted under Scharf’s predecessor. The Fed has yet to approve the new plan, the people said. If that happens, the third-party review could take months longer. Finally, the full Fed board would have to agree to lift the cap.

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