FORTUNE — Morgan Stanley is either the cleanest bank on Wall Street, or it’s living in denial.
Talk of JPMorgan Chase’s $13 billion settlement has dramatically upped the expectations of what banks may pay to put the financial crisis behind them. On Thursday, in a regulatory filing, Goldman Sachs (GS) estimated it may spend $4 billion more than it has already budgeted for settlements and fines and lawyers fees, up from $3.5 billion three months ago.
In the last week, nearly all of the large banks have disclosed billions in potential additional legal expenses. JPMorgan Chase (JPM) puts that number at $5.7 billion. Bank of America (BAC), which recently was found guilty of selling defective mortgages, isn’t far behind at $5.1 billion. Citigroup (C) says $5 billion.
The one exception is Morgan Stanley (MS). In its quarterly report, which the company filed with the SEC on Monday, the bank left blank what its additional legal expenses could be. Instead it said it didn’t think the cost would be “material” to its business.
Banks don’t have to disclose those costs, and accounting for legal expenses is murky. Financial institutions have reserves, but they don’t tell investors how much. Nonetheless, banks, like all firms, are supposed to alert investors if they know of any upcoming costs that could impact earnings. That’s what’s led to the disclosures of potential additional legal expenses.
Morgan Stanley declined to comment. Some people believe that the legal disclosure is meaningless, because there is no way to know how much a bank has put away for what. That could be why Morgan Stanley doesn’t state a figure.
Nonetheless, the lack of legal disclosure likely means that Morgan Stanley believes it will spend far less defending its financial crisis conduct than rivals.
That may be right. As we have noted, Morgan Stanley has completely avoided any prosecution from the federal government tied to the financial crisis. It’s the only major bank not to have paid a fine to Uncle Sam. That, of course, could make it the low-hanging fruit for prosecutors. And while Morgan Stanley never made mortgage loans directly to consumers, it sold just as many risky bonds tied to home loans as Goldman and others. Morgan Stanley also disclosed earlier this week that insurer AIG (AIG) is likely to sue the bank for as much as $3.7 billion for losses on mortgage bonds.
Still, Morgan Stanley, more than any of its rivals, appears to be actually complying with the spirit of Dodd-Frank and getting out of risky businesses, rather than trying to find a way around the new laws. That has made it somewhat of a poster child for financial reform. Perhaps it’s also hoping that its post-financial crisis good behavior will let it off the hook for past misdeeds. So far it appears to be working.