JP Morgan apparently simply changed their risk evaluation procedures (according to the investigation by the US congress) in order to hide the size of the risks they were taking.
This would have been harder had the risk evaluation procedure been public.

And the penalty for applying a different procedure than the published one could be fairly straightforward: the bank is immediately put into receivership, the relevant chain of command lose their work contracts on the spot and need to re-apply if they want to retain their roles (needing to establish that they were innocent in order to be successful). Something like that.

Earth provides enough to satisfy every man's need, but not every man's greed. Gandhi