Wells Fargo & Co. could recoup about $17 million in unvested shares from retiring executive Carrie Tolstedt, a fraction of the compensation the former head of community banking has received over her 27-year career, according to figures compiled from regulatory filings.

Tolstedt, whose departure was announced in July, was singled out Monday in a note to clients by Mike Mayo, an analyst at CLSA Ltd., as someone whose pay should be clawed back following $185 million in fines tied to the creation of unauthorized customer accounts. Former Federal Deposit Insurance Corp. Chairwoman Sheila Bair and some investors are also calling for the company to rescind pay.

In situations where misconduct “might reasonably be expected to have reputational or other harm to” Wells Fargo, unvested stock awards can be recouped, said the San Francisco-based bank’s March proxy statement. A spokesman for the firm declined to comment on Bloomberg’s calculations. Tolstedt didn’t return messages seeking comment.

The $17 million represents unvested stock awards to Tolstedt, 56, if the company hits certain financial targets. Wells Fargo typically grants such awards in February, but doesn’t disclose them until the next year, meaning she likely has another tranche of shares granted in 2016 that could increase the figure. The cash and stock she already owns wouldn’t be eligible to be recouped.

Decisions about clawbacks will be made by Wells Fargo’s board, CEO John Stumpf, 62, said.

Like most U.S. companies, Wells Fargo’s broadest recoupment options are reserved for situations where it must “restate all or a significant portion of its financial statements,” according to the proxy filing. In those situations, any bonus or incentive pay that was received based on financial results that are restated downward are available to be recovered. The phony account practice yielded only $2.4 million in fees for Wells Fargo, which generated $86 billion in revenue last year, and is unlikely to trigger a material restatement.

Tolstedt is to receive $3.07 million in retirement benefits, data compiled by Bloomberg show. That doesn’t include previously vested stock options that would be worth $36 million if exercised at Tuesday’s stock-market close. Tolstedt also holds about $51 million of shares amassed during her career.