unless jpm had a strange agreement between the master corporation and its trust department it doesn't really matter. MU was an employee and therefore an "authorized" agent (no matter how you slice it) and his job was to make fiduciary based decisions on behalf of the bank and its client, the MOSH trust unitholders.
it is correct imo. the only way jp morgan would not be exposed to liability is if ulrich did something that was completely unrelated to the scope of his position. clearly in this case he was acting within the scope of his position albeit terribly. if ulrich went home and killed someone later that night then obviously it wouldn't be responsible because it was not on the job or within the foreseeable scope of his job duties.