Monday, May 27, 2013

Bankster Lobbyists Writing Regulatory 'Reform' Legislation

Nearly six years since massive financial fraud and speculative market manipulation drove the global capitalist economy off the rails, congressional grifters in both benighted political parties have turned over the legislative process to bankster lobbyists.

Talk about technocratic efficiency!

Last week, The New York Times revealed that "Bank lobbyists are not leaving it to lawmakers to draft legislation that softens financial regulations. Instead, the lobbyists are helping to write it themselves."

According to emails leaked to the Times, a bill that "sailed through the House Financial Services Committee this month--over the objections of the Treasury Department--was essentially Citigroup's."

Despite huge losses during the capitalist economic meltdown, which included heavy exposure to toxic collateralized debt obligations (CDOs) which cost shareholders some 85 percent of asset value by early 2009, by 2012 the bank had built up an enormous cash horde to the tune of $420 billion (£277.7bn), derived from selling some $500 billion (£330.6bn) of "special assets" placed in Citi holdings that were guaranteed from losses by the US Treasury Department; this included untaxed overseas profits of some $35.9 billion (£23.74bn) according to Bloomberg.

As I reported last month, Citigroup was handed some $45 billion (£29.78bn) in TARP funds while the Treasury Department and Federal Reserve secretly backstopped more than $300 billion (£197.31bn) in toxic assets on their books. In addition to receiving "$2.5 trillion [£1.64tn] of support from the American taxpayer through capital infusions, asset guarantees and low-cost loans," as Wall Street on Parade analyst Pam Martens pointed out, like other too-big-to-jail banks such as Wachovia and HSBC, the Citi brand has long been associated with washing dirty cash for drug cartels.

Hit with a toothless Consent Order by the Federal Reserve in March over "deficiencies in the Banks' BSA/AML [Bank Secrecy Act/Anti-Money Laundering] compliance programs," federal regulators charged that Citigroup and their affiliate Banamex "lacked effective systems of governance and internal controls to adequately oversee the activities of the Banks with respect to legal, compliance, and reputational risk related to the Banks' respective BSA/AML compliance programs."

The Federal Reserve "action" followed an anemic Consent Order last year by the Office of the Comptroller of the Currency (OCC) which also cited Citi's failure to "adopt and implement a compliance program that adequately covers the required BSA/AML program elements due to an inadequate system of internal controls." Additionally, the OCC charged that the "Bank did not develop adequate due diligence on foreign correspondent bank customers and failed to file Suspicious Activity Reports ('SARs') related to its remote deposit capture/international cash letter instrument activity in a timely manner."

Nevertheless, as with other criminogenic banks such as JPMorgan Chase, similarly hit with an equally toothless Consent Order by the Office of the Comptroller of the Currency in January, in their infinite wisdom the Federal Reserve averred that their Citigroup action was issued "without this Order constituting an admission or denial by Citigroup of any allegation made or implied by the Board of Governors in connection with this matter, and solely for the purpose of settling this matter without a formal proceeding being filed and without the necessity for protracted or extended hearings or testimony."

In other words, let's sweep this under the rug as quickly as possible and move on. But before we do, let's step back for a moment and wrap our heads around a few salient facts.

Here's a bank with a documented history as the GAO revealed in 1998, of laundering drug money for well-placed Juárez and Gulf Cartel crony Raúl Salinas de Gortari, the brother of former Mexican president Carlos Salinas, charged with amassing a multimillion dollar fortune from narcotics rackets and then squirreling it away in London, Switzerland and the Cayman Islands.

Does this evoke any memories?

According to GAO investigators, "Mr. Salinas was able to transfer $90 million to $100 million between 1992 and 1994 by using a private banking relationship formed by Citibank New York in 1992. The funds were transferred through Citibank Mexico and Citibank New York to private banking investment accounts in Citibank London and Citibank Switzerland."

Beginning in 1992, Citibank "assisted Mr. Salinas with these transfers and effectively disguised the funds' source and destination, thus breaking the funds' paper trail." And they did so by creating "an offshore private investment company named Trocca, to hold Mr. Salinas's assets, through Cititrust (Cayman) and investment accounts in Citibank London and Citibank Switzerland," and then failed to "prepare a financial profile on him or request a waiver for the profile, as required by then Citibank know your customer policy."

Keep in mind that when Swiss prosecutors completed their money laundering investigation, The New York Times disclosed that "Swiss police investigators have concluded that a brother of former President Carlos Salinas de Gortari played a central role in Mexico's cocaine trade, raking in huge bribes to protect the flow of drugs into the United States."

That Swiss report stated, "When Carlos Salinas de Gortari became President of Mexico in 1988, Raúl Salinas de Gortari assumed control over practically all drug shipments through Mexico. Through his influence and bribes paid with drug money, officials of the army and the police supported and protected the flourishing drug business."

Does the name of former Banamex CEO Roberto Hernández ring any bells?

Described as "the single biggest winner" of Mexican bank privatizations engineered by the Bush and Clinton regimes during the 1990s as Narco News disclosed, a subsequent investigation revealed that "Hernández had been accused--publicly and via a criminal complaint--by the daily newspaper Por Esto! of trafficking tons of Colombian cocaine through his Caribbean costa properties on that peninsula since 1997."

And when Citigroup acquired Banamex in 2001 for the then-princely sum of $12.5 billion (£8.27bn), it was described as the largest US-Mexican corporate merger in history. Should it surprise us that this Citi subsidiary was named alongside parent Citigroup by the OCC and Federal Reserve for repeated failures to adequately police dirty money flowing into their coffers?

Members of the House Financial Services Committee should examine why they would turn over the legislative process to a criminal financial cartel!

As Times' journalists Eric Lipton and Ben Protess reported, "Citigroup's recommendations were reflected in more than 70 lines of the House committee's 85-line bill. Two crucial paragraphs, prepared by Citigroup in conjunction with other Wall Street banks, were copied nearly word for word. (Lawmakers changed two words to make them plural.)"

Proving yet again, that Washington lawmakers are beholden to their Wall Street masters, MapLight, a nonpartisan research group that "reveals money's influence on politics in the US Congress," disclosed that legislators "serving" on the House Financial Services Committee "approved six bills that would roll back pieces of the Dodd-Frank Act designed to improve regulation of the derivatives market."

Lawmakers who voted "yes" on HR 992, the Orwellian-named Swaps Regulatory Improvement Act, "received, on average, 2.6 times more money from top banks than committee members" who voted "no." MapLight further disclosed that lawmakers who voted "yes" on this pernicious piece of legislative detritus "received, on average, 3 times more money from the Finance, Insurance, and Real Estate (FIRE) sector," than committee members who voted "no."

The $700 trillion derivatives market, 93.2 percent of which is controlled by the four largest too-big-to-fail-and-jail US banks, Bank of America, Goldman Sachs, JPMorgan Chase and Citigroup, is a cash cow and shadow market for crooked financial insiders. HR 992, which rolled-back a key provision of 2010's anemic Dodd-Frank financial "reform" legislation, Sec. 716, would have required banks to spin off their derivatives activities into separate units that would not have access to federal bank subsidies, i.e., taxpayer bailouts.

"In recent weeks, the Times reported, "Wall Street groups also held fund-raisers for lawmakers who co-sponsored the bills. At one dinner Wednesday night, corporate executives and lobbyists paid up to $2,500 to dine in a private room of a Greek restaurant just blocks from the Capitol with Representative Sean Patrick Maloney, Democrat of New York, a co-sponsor of the bill championed by Citigroup."

Responding to questions, Financial Services Committee member Jim Himes, a former Goldman Sachs banker, third-term Connecticut Democrat and one of the top recipients of Wall Street largess to the tune of $194,500 according to OpenSecrets told the Times: "It's appalling, it's disgusting, it's wasteful and it opens the possibility of conflicts of interest and corruption. It's unfortunately the world we live in."

No Mr. Himes, it's the world you live in.

While your colleague across the aisle, Stephen Fincher (R-TN), cites Bible verses to justify gutting federal nutritional assistance to 47 million hungry Americans while being the "the second largest recipient of farm subsidies in the United States Congress" according to Forbes, and received some $3.48 million (£2.3m) since 1999 in USDA farm subsidies while doing the "Lord's work" according to the Environmental Working Group, the US Congress, including "liberal" Obama Democrats have promoted every filthy piece of legislation that facilitates Wall Street's plundering of the American people.

Referencing the recent vote on HR 992, the Center for Responsive Politics reported that in the first quarter of 2013, members of the Financial Services Committee "received more than $1.3 million in donations to their campaigns and leadership PACs from the securities and investment industry and commercial banks."

According to OpenSecrets, "By far the largest source of cash from the two industries was the Investment Company Institute, a trade association representing Wall Street firms. The ICI gave at least $129,000 to members of the House Financial Services Committee. Other trade groups representing banks and investment firms, including the American Bankers Association and the Independent Community Bankers of America, were also major contributors."

OpenSecrets reported that "Banking industry companies increased their contributions in 2013 to $640,286, from $497,169 in early 2011. Citigroup, in particular, jumped from $19,500 in donations to committee members to $39,500. UBS went from $64,250 to $88,000. Wells Fargo also opened its checkbook a little wider this year, giving $80,000, compared with $31,250 in 2011."

Commenting on this latest gift to Wall Street criminals, the World Socialist Web Site observed: "Flush with the $85 billion in cash printed up and handed to the banks every month by the Federal Reserve, business at the Wall Street casino is booming. Stock values are at record levels and so are bank profits, amidst declining wages and mass poverty."

"Under these conditions," Marxist critic Andre Damon averred, "the banks have been pushing to rip up even the very modest restrictions on financial speculation, while broadening the scope of government bailout laws. The aim is simple: to give banks the maximum ability to speculate without constraint, while getting the maximum possible government assistance if and when the bubble collapses."

None of this should surprise anyone who has paid the least attention to the cronyism and financial parasitism of the Obama regime.

From get-out-of-jail-free-cards passed out to drug money laundering banks by Eric Holder's Justice Department, to the appointments of Citigroup alumnus and Cayman Islands tax-dodger Jacob Lew as Treasury Secretary, Debevoise & Plimpton partner Mary Jo White over at the Securities and Exchange Commission to the nomination of billionaire Hyatt Hotel heiress, subprime mortgage "pioneer" and union-buster Penny Pritzker to lead the Commerce Department, it's a bankster world, all the time.

How's that for Hope and Change™!

Sunday, May 19, 2013

New Sleaze Allegations Tarnish JPMorgan Chase's 'Teflon Don'

While Barack Obama's "favorite banker" continues to receive the royal treatment in Washington, new sleaze allegations threaten to further tarnish the golden boy image of "teflon don" Jamie Dimon, the CEO and Chairman of JPMorgan Chase.

Wearing multiple hats, Dimon is the Chairman of The Business Council, a long-time member of the Council on Foreign Relations, The Trilateral Commission, a "Class A" Director of the New York Federal Reserve and Advisory Board member of the President's Council on Jobs and Competitiveness, that is, until the Council was foreclosed on earlier this year.

It doesn't hurt that JPM's embattled capo di tutti capi is also a leading light and Executive Committee member of The Business Roundtable, a corporatist "association of chief executive officers of leading U.S. companies with more than $7.3 trillion in annual revenues and nearly 16 million employees."

As they say on the street, Dimon has juice.

So much in fact, that when he and Brian Moynihan, the CEO of the Bank of America, and other members of the Financial Services Forum, a benighted cabal chaired by Goldman Sachs CEO Lloyd Blankfein and comprised of serial financial predators such as Deutsche Bank, AIG, Citigroup, Credit Suisse, UBS, HSBC, Morgan Stanley and Wells Fargo, met with Obama at the White House for April discussions, the press was barred.

As investigative journalist Pam Martens reported in Wall Street On Parade at the time, "The Financial Services Forum is a lobby group composed of 19 CEOs of the too-big-to-fail banks, both U.S. and foreign. . . . The Forum is not bashful about its lobbying agenda. According to the lobby disclosure document it filed with the Senate last year, it doesn't believe big banks should be broken up: 'The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions'."

One result of that April White House meeting may be watered-down rules adopted by the Commodity Futures Trading Commission (CFTC) last week over domination by too-big-to-fail-and-jail banks of the $700 trillion (£461.4tn) global derivatives markets.

As Reuters reported, the new rules are a "compromise" that will leave regulators "fewer tools in hand to rein in the opaque derivatives trading between two parties that was among the causes of the 2007-2009 credit meltdown."

Allegedly "designed to make trading less opaque as part of the Dodd-Frank law overhauling Wall Street practices," the rules are "an important nod to an industry dominated by big banks, such as Citigroup Inc, Bank of America Corp and JPMorgan Chase & Co, the CFTC lowered the number of quotes clients need to collect from banks."

Indeed, the deeply-flawed, Wall Street-friendly Dodd-Frank legislation had a provision that would have made bidding on derivatives contracts public but it was left to CFTC to iron out the details. Well, we see where that went. CFTC's Chairman Gary Gensler, caving to pressure by lobbyists had already compromised on moves to make those trades public; hence his proposal to require at least five banks to issue price quotes on financialized garbage.

"But even that plan," The New York Times reported, "prompted a full-court press from Wall Street lobbyists. Banks and other groups that opposed the plan held more than 80 meetings with agency officials over the last three years, an analysis of meeting records shows. Goldman Sachs attended 19 meetings; the Securities Industry and Financial Markets Association, Wall Street's main lobbying group, was there for 11."

"The outcome was a 'massive convenience' for the largest banks," Will Rhodes, "an analyst at Tabb Group, a market structure research and consultancy firm," told Reuters.

"I don't think it's going to have the same impact in terms of . . . the decentralization of risk that would have occurred had there been a requirement (for five quotes) in place."

But even these weak-kneed rules were too much for the best Congress that FIRE sector money can buy. One particularly filthy piece of legislative detritus which passed out on the House Agriculture and Financial Services Committees in March, HR 992, would allow banks to hold any kind of derivative in the same account as depositor funds, i.e., checking and savings accounts which enjoy FDIC insurance protection against bank losses.

And should one of these corrupt banks go belly up, since derivatives are senior in terms of bankruptcy pay-outs, hedge fund pirates sitting on the other side of trades with the bank would get paid back first with depositors potentially left holding the bag!

In other words, as banking analyst Ellen Brown pointed out last month in the wake of Cyprus' confiscation of depositor funds, when captured governments "are no longer willing to use taxpayer money to bail out banks that have gambled away their capital, the banks are now being instructed to 'recapitalize' themselves by confiscating the funds of their creditors, turning debt into equity, or stock; and the 'creditors' include the depositors who put their money in the bank thinking it was a secure place to store their savings."

"Too big to fail" now trumps all," Brown wrote. "Rather than banks being put into bankruptcy to salvage the deposits of their customers, the customers will be put into bankruptcy to save the banks."

And standing at the front of the line with his hand out is none other than Wall Street "maestro," Jamie Dimon.

JPM Energy Price Manipulation: History Repeats as Tragedy and Farce

The latest scandal to rock JPM concern fraudulent schemes to manipulate energy markets.

Earlier this month, The New York Times reported that multiple government investigations uncovered evidence that America's largest bank, with some $2.5 trillion (£1.61tn) in assets, "devised 'manipulative schemes' that transformed 'money-losing power plants into powerful profit centers,' and that one of its most senior executives gave 'false and misleading statements' under oath."

That senior executive, Blythe Masters, one of JPM's "smartest gals in the room" who helped develop "credit default swaps, a derivative that played a role in the financial crisis," that is, blow up the global capitalist economy, was accused by the Federal Energy Regulatory Commission (FERC) in a 70-page document cited by the Times, for her "'knowledge and approval of schemes' carried out by a group of energy traders in Houston" to manipulate energy prices in the "California and Michigan electric markets."

"The agency's investigators claimed," the Times disclosed, "that Ms. Masters had 'falsely' denied under oath her awareness of the problems and said that JPMorgan had made 'scores of false and misleading statements and material omissions' to authorities, the document shows."

In other words, Masters may have committed perjury, a jailable offense.

The FERC investigation was triggered by charges last year by the California Independent System Operator, a nonprofit run by California's state government, which estimated that "JPMorgan may have gamed the state's power market," resulting in tens of millions of dollars in "improper payments" in 2010 and 2011. "But that could be just the tip of the iceberg," the Los Angeles Times reported last summer.

According to the LA Times, "The bank continued its activities past that time frame, according to the ISO. It also says JPMorgan's alleged manipulation could have helped throw the entire energy market out of whack, imposing what could be incalculable costs on ratepayers."

Though suspended from energy trading in California," Bloomberg reported that JPM "may be evading the ban through swap agreements with EDF Group and Cargill Inc. subsidiaries, the state's grid operator said."

According to Bloomberg, Cal ISO said in a recent filing with FERC that JPM may be using "using swap contracts to secure a portion of the profit stream from a unit, while masking the identity of a party that has some level of control over the bidding."

Through its contracts with EDF and Cargill, "JPMorgan could be bringing in profits during its suspension 'beyond those contemplated' by FERC in its order, Cal ISO said. The operator recommended broad changes that would capture any situation in which 'a market participant structured transactions to evade its suspension of market-based rate authority'."

If any of this sounds familiar, it should. "What's worse," the Los Angeles Times reported, "it shows that we haven't learned anything from Enron's bogus energy trading, the disclosure of which helped destroy that firm in 2001 and land several of its executives in jail."

According to reporter Michael Hiltzik, "To the extent it was designed to exploit loopholes in energy trading rules, experts say, the scheme allegedly perpetrated by JPMorgan Ventures Energy Corp. is cut from the same cloth as Enron's infamous 'fat boy' swindle, which cost the state's ratepayers an estimated $1.4 billion in 2000."

Indeed, during the Securities and Exchange Commission's 2003 investigation into JPM's collusion with Enron, federal regulators charged Chase with "aiding and abetting Enron Corp.'s securities fraud."

At the time, the SEC said that "J.P. Morgan Chase aided and abetted Enron's manipulation of its reported financial results through a series of complex structured finance transactions, called 'prepays,' over a period of several years preceding Enron's bankruptcy."

Those fraudulent transactions were exploited by Enron officers led by "Bush Ranger," Chairman Kenneth "Kenny Boy" Lay, CEO Jeffrey Skilling and CFO Andrew Fastow, "to report loans from J.P. Morgan Chase as cash from operating activities. The structural complexity of these transactions had no business purpose aside from masking the fact that, in substance, they were loans from J.P. Morgan Chase to Enron. Between December 1997 and September 2001, J.P. Morgan Chase effectively loaned Enron a total of approximately $2.6 billion in the form of seven such transactions." (emphasis added)

But as a Florida airline executive once told investigative journalist Daniel Hopsicker during his probe into the 9/11 attacks: "Sometimes when things don't make business sense, its because they do make sense . . . just in some other way."

According to the SEC complaint, "the critical difference in the J.P. Morgan Chase/Enron prepays--and the reason that these transactions were in substance loans--was that they employed a structure that passed the counter-party commodity price risk back to Enron, thus eliminating all commodity risk from the transaction."

In other words, this was a classic example of what criminologist William K. Black describes as an "accounting control fraud." Under such schemes, a firm's chief operating officers are the recipients of massive corporate bonuses as they loot their own companies. As became evident during Enron's collapse, as well as during the 2007-2008 financial meltdown, Enron executives manipulated company books as fraudulently reported income drove share prices higher, which enriched those at the top through inflated asset values, while simultaneously disappearing liabilities, which were hidden from shareholders and Enron employees.

In the wake of Enron's collapse, shareholders lost $74 billion (£48.78bn), $45 billion (£29.66bn) of which was attributed to fraud, and the firm's 20,000 employees lost more than $2 billion (£1.32bn) from looted pension funds.

SEC investigators found that the JPM-Enron fraud was "accomplished through a series of simultaneous trades whereby Enron passed the counter-party commodity price risk to a J.P. Morgan Chase-sponsored special purpose vehicle called Mahonia, which passed the risk to J.P. Morgan Chase, which, in turn, passed the risk back to Enron."

The complaint charged that JPM's "Mahonia was included in the structure solely to effectuate Enron's accounting and financial reporting objectives. Enron told J.P. Morgan Chase that Enron needed Mahonia in the transactions for Enron's accounting. Mahonia was controlled by Chase and was directed by Chase to participate in the transactions ostensibly as a separate, independent, commodities-trading entity. As the complaint further alleges, in order to facilitate Enron's accounting objectives, J.P. Morgan Chase took various steps to make it appear that Mahonia was an independent third party."

Any future obligation assumed by Enron "were reduced to the repayment of cash it received from J.P. Morgan Chase with negotiated interest. The interest was calculated with reference to," wait for it, "LIBOR." (!)

"Since all price risk and, in certain transactions, even the obligation to transport a commodity were eliminated, the only risk in the transactions was Chase's risk that Enron would not make its payments when due, i.e., credit risk. In short, the complaint alleges, these seven prepays were in substance loans."

What penalties were extracted from JPM by the SEC for helping design Enron's massive fraud? A measly $120 million; in other words, chump change.

"Adopting eight different 'schemes' between September 2010 and June 2011," The New York Times reported, "the traders offered the energy at prices 'calculated to falsely appear attractive' to state energy authorities. The effort prompted authorities in California and Michigan to dole out about $83 million in 'excessive' payments to JPMorgan, the investigators said. The behavior had 'harmful effects' on the markets, according to the document."

As a result of fraudulent "schemes," designed solely to "generate large profits" at the expense of consumers in California and Michigan, FERC "enforcement officials plan to recommend that the commission hold the traders and Ms. Masters 'individually liable.' While Ms. Masters was 'less involved in the day-to-day decisions,' investigators nonetheless noted that she received PowerPoint presentations and e-mails outlining the energy trading strategies."

Plausible deniability aside, it appears that Masters was up to her eyeballs in the grift and "'planned and executed a systematic cover-up' of documents that exposed the strategy, including profit and loss statements," the Times averred.

Citing regulators' complaints that their investigation was "obstructed" by Masters and her cohorts, when "state authorities began to object to the strategy, Ms. Masters 'personally participated in JPMorgan's efforts to block' the state authorities 'from understanding the reasons behind JPMorgan’s bidding schemes,' the document said."

Referencing an April 2011 email, "Masters ordered a 'rewrite' of an internal document that raised questions about whether the bank had run afoul of the law. The new wording stated that 'JPMorgan does not believe that it violated FERC's policies'."

Will history repeat? You bet it will! Even if FERC were to levy a maximum penalty of $1 million per day for violating the rules, "the $180-million bill would be a pittance compared with the $14 billion in revenue collected annually by JPMorgan's investment banking arm, which houses the energy trading," the Los Angeles Times reported.

Talk about a sweet deal!

A Criminal Enterprise

Coming on the heels of a scathing 307-page Senate report released by the Permanent Subcommittee on Investigations in March, which provided details of the scandalous actions by senior officers as they covered-up bank overexposure in the synthetic credit derivatives market along with a mammoth $6.2 billion (£3.98bn) loss for investors, and a toothless Consent Order by the Office of the Comptroller of the Currency over allegations of JPM drug money laundering, the question is: Why hasn't Jamie Dimon already landed in the dock?

Leaving aside the criminal behavior of US Attorney General Eric Holder, adept at prosecuting national security whistleblowers and seizing the phone records of Associated Press reporters through the mechanism of an administrative subpoena, i.e., solely on the say-so of the Justice Department and the FBI, when it comes to prosecuting corporate criminals, including those who collude with transnational drug cartels, The Most Transparent Administration Ever™ has surpassed the deceitful practices of the Bush regime.

No where is this more apparent than with the non-prosecution of criminogenic banks.

A withering 45-page report authored by GrahamFisher analyst Joshua Rosner, JPMorgan Chase: Out of Control, paints the organization as a criminal enterprise. According to Rosner: "Even without the inclusion" of some $16 billion [£10.41bn] in "litigation expenses" arising from JPM's foreclosure scandals, "since 2009, the Company has paid more than $8.5 billion [£5.53bn] in settlements for the various regulatory and legal problems discussed in this report. These settlement costs, which include a small number of recent settlements of older issues, represent almost 12% of the net income generated between 2009-2012."

Amongst the patently illegal schemes hatched by JPM detailed in Rosner's report we find the following:

● Bank Secrecy Act violations
● Money laundering for drug cartels
● Sanctions busting
● Violations of the Commodities Exchange Act
● The execution of fictitious trades where the customer, with JPM's full knowledge, is on both sides of the deal
● SEC enforcement actions relating to CDO and RMBS misrepresentations
● Foreclosure fraud and abuse
● Failure to properly segregate customer funds and then failing to report it
● Consumer abuses related to check overdraft penalties
● Violations of NY State's ERISA Act, the result of JPM investments in failing structured investment vehicles (SIVs)
● Credit card collection practices, "eerily similar" to JPM's foreclosure abuses
● Violations of the Servicemembers Civil Relief Act; i.e., illegally foreclosing on the homes of soldiers, including those stationed in Afghanistan and Iraq
● Illegal flood insurance commissions
● Municipal bond market manipulation, including $8 million in bribes paid to "close friends" of Jefferson County, Alabama commissioners for sewer system bonds that eventually bankrupted the county
● Violation of the Sherman Antitrust Act related to bid rigging and payments associated with "seeing competitors' bids in 93 municipal bond deals"
● Repeated obstruction and refusal to hand over documents to the OCC related to their investigation of JPM's role in the Madoff fraud

Will any of this change? It's doubtful.

Rosner writes: "JPM appears to have taken a page out of the Fannie Mae playbook in which the company perfected the art of cozying up to elected officials, dominating trade associations, employing political heavyweights and their former staffers and creating the image of American Flag-waving, apple-pie-eating, good corporate-citizen, all of which supported an 'implied government guarantee' and seemingly lowered their cost of funding. Additionally, rather than being driven by the strength of its operations and management, many of the JPM's returns appear to be supported by an implied guarantee it receives as a too-big-to-fail institution."

In other words, as with other well-connected "Families" that come to mind, "too-big-to-fail-and-jail" is bankster code for "we can do whatever the fuck we want."