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JPMORGAN CHASE WHALE TRADES: A CASE HISTORY OF DERIVATIVES RISKS AND ABUSES

JPMORGAN CHASE WHALE TRADES: A CASE HISTORY OF DERIVATIVES RISKS AND ABUSES

JPMORGAN CHASE WHALE TRADES: A CASE HISTORY OF DERIVATIVES RISKS AND ABUSES

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225<br />

risk personnel criticized the OCC’s findings and recommendations, 1256 and the meeting assumed<br />

a loud and “combative” tone. 1257 The OCC examiner recalled that Peter Weiland, the CIO’s<br />

Chief Market Risk Officer, agreed with the OCC’s suggestion on one point, which had the effect<br />

of quieting the executives in the room, but said it was the only issue on which anyone from the<br />

bank supported an OCC recommendation from that examination. 1258 After the meeting ended,<br />

he said that, despite the bank’s aggressive response, the OCC issued its Supervisory Letter<br />

largely in line with the original conclusions the examiner had presented. 1259<br />

Still another instance involved profit and loss reports. In either late January or early<br />

February 2012, the OCC said that the daily Investment Bank P&L report stopped arriving in<br />

OCC electronic inboxes. The OCC explained that when it brought up what it thought was<br />

simply a glitch in JPMorgan Chase’s email delivery, the bank informed it that Chief Executive<br />

Officer Jamie Dimon had ordered the bank to cease providing the Investment Bank’s daily P&L<br />

1260<br />

reports, because he believed it was too much information to provide to the OCC. The OCC<br />

said that the bank explained further that it had experienced a series of unauthorized data<br />

disclosures and the bank, not knowing who was leaking the data, sought to limit the information<br />

it provided to the OCC, even though OCC had not been responsible for the leaks. 1261 According<br />

to the OCC, when it requested resumption of the daily Investment Bank P&L reports, Douglas<br />

Braunstein, JPMorgan Chase’s Chief Financial Officer, agreed to the request, but had apparently<br />

not informed Mr. Dimon. At a meeting shortly thereafter in which both Mr. Braunstein and Mr.<br />

Dimon were present, according to the OCC, when Mr. Braunstein stated that he had ordered<br />

resumption of the reports, Mr. Dimon reportedly raised his voice in anger at Mr. Braunstein. 1262<br />

The OCC said that Mr. Dimon then disclosed that he was the one who had ordered a halt to the<br />

reports and expressed the opinion that the OCC did not need the daily P&L figures for the<br />

Investment Bank. 1263<br />

The OCC estimated that it was without the reports for less than a week<br />

altogether.<br />

(3) 2011: Missing SCP Red Flags<br />

In 2011, the SCP expanded dramatically, acquired a complex mix of credit derivatives,<br />

and bankrolled a high risk series of credit trades that produced substantial unexpected revenues.<br />

Along the way, several red flags highlighted risks associated with the growing SCP, which<br />

should have caught the OCC’s attention and led to a regulatory inquiry into the CIO’s growing<br />

synthetic credit trading, but the OCC missed those red flags.<br />

In 2011, the SCP expanded tenfold in size, from about $4 billion in notional positions at<br />

the beginning of the year to $51 billion at the end of the year. 1264<br />

As explained earlier, it<br />

1256 Id.<br />

1257<br />

Id.<br />

1258<br />

Id.<br />

1259<br />

See 3/9/2012 OCC Supervisory Letter JPM-2012-09 to JPMorgan Chase, “Examination of FSI Stress Testing<br />

Framework”; Subcommittee interview of Jaymin Berg, OCC (8/31/2012).<br />

1260<br />

Subcommittee interview of Scott Waterhouse, OCC (9/17/2012).<br />

1261<br />

Id.<br />

1262<br />

Id.<br />

1263<br />

Id.<br />

1264<br />

See “Summary of Positions by Type,” prepared by JPMorgan Chase in response to a Subcommittee request,<br />

JPM-CIO-PSI 0037609.

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