But the OCC isn’t the only bank regulator who should be red-faced over the JPMorgan debacle, says Mayra Rodriguez Valladares, managing principal of financial regulatory and capital markets consultancy MRV Associates. The derivatives trades were made out of the bank’s London office, which is the regulatory territory of the U.K.’s Financial Services Authority, she said.

“They slept on this one, big-time,” Valladares told Law360.

But while bank regulators deserve blame for not adequately assessing the risks of JPMorgan’s derivative trades, they shouldn’t be blamed for not being aware of information hidden by the bank, Valladares said. 

“Bank examiners aren’t detectives; bank examiners are charged with doing thorough risk-based supervision,” she said.”As long as I can see that the bank is capitalized, I wouldn’t necessarily suspect that’s something wrong.”