xNY.io - Bank.org | Memo #2 - JPMorgan Chase Board of Directors ESG Marketplace Manipulation

Gunnar Larson g at xny.io
Sun Feb 26 04:40:05 PST 2023


May 1, 2022


Investor Relations
Board of Directors, JPMorgan Chase & Co.
277 Park Avenue
New York, NY 10172-0003
JPMCinvestorrelations at jpmchase.com

Re: JPMorgan Chase Board of Directors ESG Marketplace Manipulation

Dear Board of Directors:

xNY.io - Bank.org recently contacted JPMorgan Chase’s board of directors to
communicate our concern(s) that potentially JPMorgan Chase may be engaging
in exploitation of more than $100B of ESG asset liabilities, across
international regulatory arbitrage structures, while headquartered in
Manhattan. Specifically, the duty to promote the success of the company is
that a director must act in the way that she considers, in good faith, and
would be most likely to promote the success of the company for the benefit
of its members as a whole.


   Failure by a board to adequately consider ESG-related risks,
   particularly entity-specific compliance risks such as breach of securities
   laws, could serve as the basis for liability of individual directors or
   officers for breach of their fiduciary duties.

Given JPMorgan’s five cout felonies, xNY.io - Bank.org is concerned with
your board of director governance in preventing ESG fraud. xNY.io -
Bank.org’s assessment of JPMorgan’s board embraces fundamentals including
liquidity risk and protecting New York ESG cross border innovation from
marketplace manipulation.


   According to JPMorgan’s August 2021 Sovereigns and ESG whitepaper, the
   bank states that governance carries the largest weight of the three ESG
   pillars across scores, as it is the most empirically relevant for asset

   JPMorgan notes that philosophically, the bank views good governance as a
   foundational pillar for positive ESG developments in other pillars.

Today’s memo follows protocol suggested by the United States of America, in
that JPMorgan Chase’s board of directors is responsible to xNY.io -
Bank.org’s enterprise and the Department of the Interior, in connection
with any action alleging a violation of the Endangered Species Act, by any
person (“person” means an individual, corporation, partnership, trust,
association, or any other private entity) claiming the benefit of any
exemption or permit under the Act, who shall have the burden of proving
that the exemption or permit is applicable, or has been granted, and was
valid and in force at the time of alleged violation.

xNY.io - Bank.org has made 91 highlights to the Department of Interior’s
Endangered Species Act for JPMorgan Chase’s board of directors reference.


   xNY.io - Bank.org has reason to believe in the JPMorgan Chase board of
   directors’ engagement of ESG marketplace manipulation, risking your ESG
   portfolio’s future at the cost of New York digital asset innovation.

    xNY.io - Bank.org references your 2021 Environmental Social and
   Governance Report, totaling $117B of ESG “development funding”
   transferred from New York to Caribbean and Eastern European accounts.

   xNY.io - Bank.org is concerned of JPMorgan Chase board directors
   leveraged marketplace manipulation techniques in allocating ESG funds to
   engage in potential harassment (the term "harassment" means any act of
   pursuit, torment, or annoyance) of some of the world’s most precious
   endangered species protected by domestic and international governance.

   JPMorgan Chase’s $2.3B ESG “wind farm” facility is characterized by the
   Washington Post as a potential misuse of ESG assets (and board policies)
   to fund probable violation(s) of the Marine Mammal Protection Act of 1972.

Looking internationally, xNY.io - Bank.org is concerned of further ESG
marketplace manipulation structures, sacrificing endangered species, via
JPMorgan Chase’s board directed ESG investments in the Caribbean (your
largest ESG investment region). xNY.io - Bank.org signals that JPMorgan’s
board of directors is party to the Convention on Nature Protection and Wild
Life Preservation in the Western Hemisphere.

Being clear, any violation of the Endangered Species Act, the Marine Mammal
Protection Act and/or the Convention on Nature Protection and Wild Life
Preservation in the Western Hemisphere … Requires xNY.io - Bank.org to
consult JPMorgan Chase board members on ESG allocations that may be in
conflict with construction, or other development projects, or other forms
of economic activity.

xNY.io - Bank.org asks JPMorgan Chase board directors to return the
Secretary of Department of the Interior’s approval, confirming licensing
and/or exclusion to the Endangered Species Act, with further authorization
of “harassment” pursuant to exemption(s). Including (if available) a
similar Environmental Protection Agency permit that is applicable and is
valid and in force.


   Due to the riskiness of ESG portfolio mismanagement in violation of the
   Endangered Species Act, ESG marketplace manipulation risk(s) may trigger
   causal shocks to New York State monetary and regulatory innovation.

   According to JPMorgan’s sovereign fund ESG research, “A common complaint
   about ESG analysis is that data can be difficult to source. Some sovereign
   data is in fact more readily available than corporate data given the
   multitude of multinational organizations and NGOs – including the World
   Bank, the IMF and the United Nations.”

   The European Central Bank provides support to the eurozone sovereign
   debt market but has more restrictions on what and how much it can buy, so
   eurozone bonds can trade with more credit risk premium compared to other
   major developed market bonds.

   Whatever the case may be, JPMorgan disclosures detail significant
   concern of lapse in board governance and ESG portfolio risk with potential
   violation of the Endangered Species Act, risking ESG portfolio default(s)
   in Europe and the United States risking ESG customer financial abuse.

Forbes recently profiles JPMorgan Chase ESG investments as problematic,
highlighting that your board of directors potentially are allocating ESG
proceeds in competition with human rights at the expense of customers’ best
interests while investing heavily in fossil fuels. A letter to JPMorgan
Chase’s board of directors from ESG scholars (including, The Sierra Club,
Public Citizen, Greenpeace, Amazon Watch, Revolving Door Project,
Rainforest Action Network and the Center for International Environmental
Law) suggests the bank would  “...lock us into energy sources that are
overly expensive and subject to wild price swings, and that exacerbate
rather than ease global conflict.”

xNY.io - Bank.org aims to protect ESG digital asset innovation and
JPMorgan’s board should understand your proprietary ESG scoring matrix
should signal seismic marketplace manipulation risk if directors are in
potential violation of any Endangered Species Act covenant.


   Head of Europe, Middle East, and Africa (EMEA) distribution at JP Morgan
   Asset Management says, “In Europe, we do not have a semi-transparent
   product – like the US and Australia – which would add further complexity to
   the trading. For example, the US has several models which make it harder
   for the AP to guess what the actual fund looks like and therefore the costs
   might be higher accordingly.”

   Given, JPMorgan may potentially be in breach of United States Endangered
   Species Act provisions, similar risk of ESG asset failure(s) may include
   Europe, Middle East, Africa and Australia international law, as ratified by
   the Convention on International Trade in Endangered Species of Wild Fauna
   and Flora.

While directors and officers are likely to be particularly focused on the
risk that they may be found personally liable for a breach of their duties,
proper ESG compliance with fiduciary obligations requires acting to a
higher standard. Given the defenses available to fiduciaries, and the
difficulty in bringing claims for breach of fiduciary duty, a director or
officer found to be liable for such ESG breaches will generally have acted
egregiously. This ‘sliding scale’ of the standards to which directors and
officers should adhere.

Following the Endangered Species Act,  xNY.io - Bank.org kindly petitions
JPMorgan’s board of directors, in connection with all ESG investments,
claiming the benefit of any exemption or permit under the United States
Department of the Interior’s  Endangered Species Act … Shall have the
burden of proving that an exemption or permit is applicable, or has been
granted, and is valid and in force.


   At JPMorgan’s earliest convenience (within 60 days of receipt of this
   memo)  xNY.io - Bank.org kindly requests a certified copy of JPMorgan
   Chase’s approval by the Department of the Interior, being a license and/or
   exclusion to the Endangered Species Act and/or the Marine Mammal Protection

   JPMorgan Chase suggests a commitment to anti-corruption compliance is
   central to the success of its business. Your board of directors stand to
   maintain that trust by promoting a corporate culture that encourages
   ethical business practices and compliance with both the letter and the
   spirit of the laws of the countries in which the JPMorgan conducts business.

xNY.io - Bank.org’s research guidance from the United States Securities and
Exchange Commision, supports the international community in taking actions
to address ESG issues on a global basis, and those actions that can have a
material impact on companies.

Future correspondence concerning ESG innovation is at your board’s leisure.

Respectfully yours with appreciation,

Gunnar Larson | xNY.io <http://www.xny.io> - Bank.org <http://bank.org>, PBC
- Digital Currency
- Entrepreneurship and Innovation (ip)
G at xNY.io  +1-646-454-9107
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