There is a question of whether the NOL's will transfer. WMI is in a unique situation because it no longer has a bank, although on paper it is a bank holding company. BUT if the IRS allows the NOL's to transfer, then JPM would have an incentive to buy it.
But if they merge with another company/bank, and we end up owning 50% or more of the resulting entity, then the NOL's WILL transfer.