JPMorgan Chase & Co. wants to be known as the bank that rebuilt America. Chairman and CEO Jamie Dimon (pictured above) has staked his legacy on it — announcing last October a $1.5 trillion Security and Resiliency Initiative to finance defense manufacturing, energy independence, critical minerals, advanced manufacturing, and nuclear energy. It is a bold, nationalist vision.
However, it also contradicts JPMorgan’s own underwriting framework, which penalizes precisely the industries the SRI claims to support. National Legal and Policy Center has documented the contradiction in an exempt solicitation report that has been circulated to JPMorgan investors ahead of the company’s May 19, 2026 annual meeting. Read the executive summary and the full report.
The mechanism is not subtle. JPMorgan’s Carbon Compass framework commits the bank to 2030 portfolio-level emissions intensity reductions across eight carbon-intensive sectors, benchmarked to the IEA’s Net Zero by 2050 scenario — a planning fantasy that assumes no new oil and gas field approvals after 2021, total phase-out of coal and oil power by 2040, and the rapid commercialization of technologies that do not yet exist at scale.
The bank’s Carbon Assessment Framework, which its own 2024 Climate Report describes as evaluating “each new proposed in-scope transaction” against carbon intensity targets and delivering those evaluations to “decision-makers at the Firm,” functions as a filter on lending. When a JPMorgan banker sits down to evaluate a loan to a steel producer, a cement plant, or a natural gas driller — the clients the SRI is built to serve — the CAF runs the numbers on whether that deal makes the portfolio’s carbon profile worse. For twenty-four of the SRI’s twenty-seven sub-areas, it almost certainly does.
JPMorgan left the Net Zero Banking Alliance in January 2025, timing its exit to coincide with the incoming Trump administration’s energy agenda. But it did not abandon the IEA NZE-aligned Carbon Compass targets that underpinned its NZBA membership. The environmental sustainability page on JPMorgan’s own website confirms the targets are intact. The bank dropped the alliance and kept the rules. The retreat was cosmetic.
The SRI’s advisory council is of a piece with this pattern. Mr. Dimon assembled twelve names — Condoleezza Rice, Robert Gates, Paul Ryan, Jeff Bezos, Jim Farley, three retired generals — designed to communicate seriousness without delivering it. Missing from the council: a single founder or executive from the defense technology companies actually winning Pentagon contracts today. Palmer Luckey’s Anduril Industries just secured a $20-billion Army contract — not on the council. Neither is anyone from Northrop Grumman, L3Harris, or Raytheon. The companies that do the work aren’t represented. The companies that provide the brand association are. This is what national security greenwashing looks like.
Meanwhile, the CEO who wants to be the face of American reindustrialization is managing a legal docket that tells a different story. President Trump has reportedly filed a $5-billion civil lawsuit against JPMorgan and Dimon personally over the bank’s politically motivated closing of more than fifty Trump-affiliated accounts. JPMorgan has admitted in court filings that it closed those accounts — hotels, housing developments, retail properties, and Trump’s personal banking relationship — and told the former president to “find a more suitable institution.” The Florida Attorney General has opened a separate investigation.
Also, the House Select Committee on the Chinese Communist Party subpoenaed Mr. Dimon over JPMorgan’s underwriting of the CATL IPO — a $5.2 billion Hong Kong listing for a battery company the Pentagon has designated as linked to China‘s military-civil fusion program. A bank that closed accounts for a future president on political grounds while underwriting a Chinese military-linked company’s IPO is a strange choice to lead America’s reindustrialization.
JPMorgan’s Board, in its proxy statement opposition to Proposal 4, dismisses NLPC’s concerns as a “fundamental misunderstanding.” It insists Carbon Compass is about capturing opportunities, not restricting financing — a claim that cannot survive a plain reading of the CAF’s own mechanics. It argues that the IEA NZE “assumes ongoing roles for oil and gas” — a characterization so misleading it borders on willful. And it argues the requested report would be expensive and provide no meaningful disclosure — while the company produces comprehensive ESG materials for ratings agencies as a matter of routine.
The resistance to explaining itself to its own shareholders is the most revealing thing JPMorgan has said about this conflict.
Proposal 4 asks for a report. Vote FOR it — shareholders are able to cast their ballots NOW.
If JPMorgan can reconcile a 69% reduction in electric power emissions intensity with financing the energy infrastructure of American reindustrialization, shareholders deserve to see the math. NLPC’s bet is that JPMorgan can’t show its work — because the math doesn’t add up.
(Post references PX14A6G Notice of exempt solicitation)
