In the 15 years I’ve been writing for Compliance Week, never have I covered a company that has evoked as much anger and palpable relief from so many current and former employees as USAA—anger toward its senior executives and management, and relief someone finally had the courage to come forward publicly.

Since Compliance Week published its three-part series on USAA’s “catastrophically mismanaged” compliance culture, more current and former USAA employees (nearly two dozen, to date) have shared with me their own experiences about reporting alleged violations of law internally to USAA’s management—some on numerous occasions and in documented emails—only to be retaliated against or let go in response.

For the sake of this specific column, Compliance Week has chosen to leave all names anonymous, including the allegedly culpable management. But what I will share is all the employees who came forward to me either worked or currently work in various departments at various levels of the organization—from the lower ranks to upper management. In any organization, that’s typically a sign of a systemically unhealthy culture.

In their collective state, the shared experiences of these employees highlighted the following themes regarding USAA’s culture:

Bullying intimidation tactics: Among employees who came forward to me, the tie that bound all their experiences were the alleged intimidation tactics used against those who raised their hands about potential violations of law. Several employees commented they unintentionally put a target on their back for raising red flags. Some reported facing sudden accusations—for example, creating a “hostile” work environment—only after they came forward with concerns.

According to one USAA attorney, many of the alleged law violations that were reported by employees exist within the company’s employee job satisfaction (EJS) board, an internal mechanism for employees to provide feedback. In December 2021, USAA discontinued its EJS board, at a time when most employees reported in a company survey they were “either ‘unhappy’ or ‘extremely unhappy’ with their jobs,” the attorney said.

A culture of favoritism: Other employees described an “old boys club” culture within USAA at the vice president level and above. As one employee shared, executives at the top often promote one another, “with executives coming to lead teams of over thousands who have never had any leadership experience.” Rather than make hires within departments that really need it, “USAA continues to hire high-ranking executives with no experience.”

Other employees corroborated allegations that USAA’s management continues to shift personnel around and, in some cases, even promoted certain individuals to higher level leadership positions merely to appease the Office of the Comptroller of the Currency (OCC).

One current USAA employee commented, “The executives are running around like chickens with their heads cut off. They keep missing consent order deadlines and have no clue as how to fix the bank. When OCC comes back to check the progress, it’s not going to be good. They still haven’t improved with the Reg E violations, and let’s not even start with AML (anti-money laundering) and sales practices.”

Risk and compliance systems inefficient and not risk-based: Another common concern expressed was how inefficient USAA’s risk, compliance, and internal audit processes are. One employee commented USAA’s risk and compliance self-assessment has “many problems,” with “no ability to identify or accurately rate risk. System issues remain a huge problem.”

Another USAA employee said, “They [USAA] generate tons of data with little to no intrinsic value in improving their compliance posture. The culture is averse to tools and approaches that could give the management a comprehensive view of compliance and risk. The culture must change for success to be possible. The outside consultants have not had a positive impact.”

No desire by management to improve risk and compliance: Overall, several current USAA employees described risk and compliance at the company as little more than window dressing. Said one employee, “Management doesn’t want to hear how bad it is. They have no clue what anyone does.”

In other areas, some employees shared management is the problem. For example, testers within USAA’s Enterprise Compliance and Operational Risk Testing (ECORT) team were allegedly instructed by management to not find any issues.

“When we’d find issues, ECORT management, along with USAA legal counsel, would whitewash our results,” alleged one employee. “Nothing of substance was allowed to be fully noted.”

Lack of accountability: Other comments I received noted the direct role certain chief compliance officers, general counsel, and chief risk executives played in contributing to USAA’s toxic culture but who allegedly were never held accountable. One USAA employee commented some “retired with very generous compensation packages—although they should have been held accountable for the compliance failures—and have moved onto high-profile positions elsewhere.”

USAA’s response

In answering questions posed to the business regarding the concerns mentioned above, Roger Wildermuth, director of communications at USAA, responded:

USAA is committed to holding ourselves accountable to the highest standards of ethical conduct and compliance. It’s difficult to comment on anonymous, unconfirmed complaints that Compliance Week has not shared with us. However, the allegations are not consistent with our practices or values.

We have widely acknowledged that we previously did not sufficiently invest in the people, systems, and processes that would allow us to serve members in a consistently compliant manner.

We have since made progress in many critical areas and have communicated transparently with our regulators as we have worked to build a solid risk and compliance program. That progress includes creating a culture where every employee is encouraged and empowered to report concerns, including anonymously and with the confidence of a zero-tolerance retaliation policy.

The limited descriptions of unconfirmed complaints Compliance Week has provided are not at all representative of that culture, and we regret if any employees felt that their feedback was not heard. We flatly reject the suggestion of a pattern of retaliation.

Employee feedback and concerns, particularly about compliance issues, are treated with the utmost importance. While EJS was intended as an employee comment tool—but ultimately produced mostly vague, unverifiable comments—employees have several tools available to provide feedback or express concerns. That includes our ‘See Something, Say Something’ resource, our revised employee comment board, our speak-up and open-door policies, and our human resources and ethics offices.

The work we’re doing to build a risk and compliance program befitting a company of our size and complexity requires time and the flexibility to change. These changes have included personnel changes, as we brought in experienced leaders and employees with the proper expertise to join the committed teammates who are working to strengthen this program.

We are confident in the talent we have, the progress we’ve made, and our culture. USAA is simply not the company depicted by these stories.


I feel it important to end this column with one important point all organizations should realize about adverse media reports regarding allegations of corporate wrongdoing: When employees want their concerns heard—when employees want to feel validated—the media is typically their last resort, not their first. Adopting a “shoot the messenger” mentality won’t make a toxic internal culture disappear.

Collectively, the allegations raised by USAA’s own employees—lack of moral and effective leadership, an overall lack of desire or inability to fix systemic risk and compliance issues, management by intimidation and retaliation, and appeasing regulators through false pretenses—will only continue to make things worse for the company, as it would any organization, if it refuses to listen to those who matter most: its employees and customers.

As one USAA employee concluded, “There needs to be a total scrapping of what exists and rebuilt with a strong infrastructure. It’s too bad, because USAA could be a great place—but it isn’t.”

June 20 will mark USAA’s centennial. While it might not be a great time in the company’s history for a celebration, it is certainly an opportune time for reflection.