The SEC's consent order in the "London whale" matter contained uncommonly strong language, the regulatory experts said. It made more than 100 references to "senior management" and didn't name Mr. Dimon specifically but described senior management as "individuals who held the listed positions as of May 10, 2012: the JPMorgan Chief Executive Officer, the JPMorgan Chief Financial Officer, the JPMorgan Chief Risk Officer, the JPMorgan Controller, and the JPMorgan General Auditor."