In 2010, Irving Picard, the SIPC receiver appointed to liquidate Madoff's company, alleged that JPMorgan failed to prevent Madoff from defrauding his customers. According to the suit, Chase "knew or should have known" that Madoff's wealth management business was a fraud. However, Chase did not report its concerns to regulators or law enforcement until October 2008, when it notified the UK Serious Organised Crime Agency. Picard argued that even after Morgan's investment bankers reported its concerns about Madoff's performance to UK officials, Chase's retail banking division did not put any restrictions on Madoff's banking activities until his arrest two months later. The receiver's suit against J.P. Morgan was dismissed by the Court for failing to set forth any legally cognizable claim for damages.