Crichton said Lewis' concern was that being described as the CEO represented a "position [that] has particular significance within the banking industry".
"He draws the [ERA's] attention to the fact that that role is of particular importance especially in terms of the relationship between [JPMorgan Chase] and the Reserve bank of New Zealand."
Crichton said the Reserve Bank considered the title of CEO could be held only by "a fit and proper person'".
However, Crichton said there was no evidence JPMorgan Chase had breached its contract with Lewis or that it owed him any damages.
"The short point is that there is no evidence ... that the settlement agreement has been breached. In particular, as to the suggestion that the bank has disparaged Mr Lewis, that allegation is vigorously denied."
Crichton said Lewis' claim "fails in its entirety".
There had been attempts at mediation between Lewis and the bank before the ERA decision was made.
Crichton said after Lewis first complained to the ERA, in September 2010, the bank made "an exception" to help him by referencing his role as CEO in his certificate of service.