Some of the difference is because of the way banks book second liens. Non-performing home-equity loans typically are written off in six months. That compares to an average two-year period from delinquency to a foreclosure sale on a primary mortgage. Also, home-equity payments are smaller, meaning homeowners are likely to keep paying after a default on their primary mortgage -- at least for awhile.

"When we analyzed it, it was pretty obvious it was just a timing difference," Dimon said. "In almost all cases when the first went delinquent, the second eventually went delinquent. And in all cases where the first went into foreclosure, the second was a loss, basically a total loss."

Jerry Dubrowski, a Bank of America spokesman, declined to comment, as did Wells Fargo's Mary Eshet and Citigroup's Mark Rodgers. Amy Bonitatibus, a JPMorgan spokeswoman, declined to comment beyond Dimon's remarks.

"We're seeing the lingering effects of the housing market bust," Swonk said in an interview. Guidance from regulators "is the reality of making sure banks are sound and secure while we work through the ripple effects of the financial crisis."

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