Here's what Thomas Curry, the comptroller of the currency, told CNBC on Wednesday:
"In response to the recent financial crisis the OCC raised its expectations for large banks. We are no longer willing to accept audit and risk management functions that are simply satisfactory. We are looking for excellence. Our expectation is that large institutions will meet the standard of "strong" for audit and risk management functions. Strong corporate governance is essential. The OCC has set higher expectations in five specific areas: board willingness to provide credible challenge to management, talent management and compensation, defining and communication risk tolerance across the company, development of strong audit and risk management functions, and protecting the sanctity of the bank charter."
He said much the same thing to the Senate investigation panel last week.
So if the downgrade of JPMorgan's management (or "M" ) score in the CAMEL rating system was not strictly a Whale thing but tied to a general heightening of standards, it's reason to ask what other banks might have been downgraded. (Note for the perplexed: click here for a quickie lesson on CAMELs.)
Unfortunately, the CAMEL ratings are a closely guarded secret. Neither the government nor the banks will say what the bank's rating is or when it has changed. So we may never know who else might have run afoul of the new, higher hurdle for the M segment of CAMELs.