Deutsche Bank AG (ETR:DBK) (FRA:DBK) (NYSE:DB) does seem to have “improperly accounted” for its losses according to accounting experts cited by the Financial Times.

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Deutsche Bank AG (ETR:DBK) (FRA:DBK) (NYSE:DB) has been accused by three of its former employees of not reporting $12 billion in paper losses during the economic crisis. That reportedly helped the bank avoid being bailed out by the government.

The Financial Times had reported previously that the former employees filed the complaints with regulators at the Securities and Exchange Commission, alleging that Deutsche Bank AG (NYSE:DB) mis-valued a large position in derivatives structures referred to as leveraged super senior trades. According to the complaint, if the bank had properly accounted for its positions, its capital would have dropped significantly amidst the financial crisis, which could have required a bail-out from the government in order for the bank to stay afloat.

The Financial Times spoke to Georgia Tech accounting professor Charles Mulford, who said the gap risk on those positions “should have been adjusted to market value,” which is also what the former employees claimed in their SEC complaints. Mulford added, “One cannot mark-to-market the upside but not the downside.

The complaints lodged against Deutsche Bank AG (ETR:DBK) (FRA:DBK) (NYSE:DB) were all given at different times in 2010 or 2011, and they came with internal documents. Two of the former employees who lodged those complaints claimed the bank forced them out after they reported the concerns internally. One of the employees was fired from the bank three days after the submission of his SEC complaint. The other employee received $900,000 in a settlement for the lawsuit he filed as a result of his firing.

Two of the three employees involved said that Deutsche Bank AG (ETR:DBK) (FRA:DBK) (NYSE:DB) mismarked the insurance value provided by Berkshire Hathaway Inc. (BRK.A) (BRK.B) in 2009. Deutsche Bank AG (NYSE:DB) said it didn’t do anything wrong in marking-to-market the risk. A spokesperson for the bank said the claims were more than two years old and reported publicly in June 2011. The statement also said the claims were “wholly unfounded” and that they “stem from people without personal knowledge of, or responsibility for, key facts and information.”

The SEC’s enforcement head, Robert Khuzami, has recused himself from the investigation because he was the bank’s general counsel for its American operations between the years of 2004 and 2009.