``According to the settlement agreement, the bank will pay a civil penalty "pursuant to" a statute called the Financial Institutions Reform, Recovery and Enforcement Act. However, the Justice Department didn't lodge any claims against JPMorgan for breaking that law or any other. This was an out-of-court settlement. The Justice Department didn't file a complaint. No judge's approval was needed. The agreement did incorporate an 11-page statement of facts that explained in vague terms what JPMorgan did. Yet none of the acknowledgments by JPMorgan in that document hurt the bank. JPMorgan didn't admit liability or even any mistakes. That's no better than the old "neither admit nor deny" boilerplate. ''

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