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But private litigation has failed.
Private litigation is not ruled out.
The bank is also facing private litigation over rate manipulation.
It may also expose JPMorgan to private litigation.
The private litigation promises to be a marathon effort.
The trading commission still provided the bank some cover from private litigation.
Even as criminal and civil prosecutors are closing investigations into financial executives, private litigation is swelling.
"The doomsday scenarios for this private litigation would have threatened the solvency of the biggest banks.
When regulation fails, private litigation can be the most powerful force for change.
But if the settlement, in effect, precludes private litigation, then $13 billion is not enough.
However, Mr Rosenberg is not belittling the potential impact of private litigation.
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