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SEC Comment Letter for JPMORGAN CHASE & CO (JPM, AMJB, VYLD, JPM-PC, JPM-PD, JPM-PJ, JPM-PK, JPM-PL, JPM-PM) (CIK 0000019617) (JPM) — Feb 2, 2012

JPMORGAN CHASE & CO (JPM, AMJB, VYLD, JPM-PC, JPM-PD, JPM-PJ, JPM-PK, JPM-PL, JPM-PM) (CIK 0000019617)
Date: Feb. 2, 2012 · CIK: 0000019617 · Accession: 0000000000-12-005849

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Reasoning

File numbers found in text: 001-05805

Referenced dates: December 19, 2011

Date
February 2, 2012
Author
Suzanne Hayes
Form
UPLOAD
Company
JPMORGAN CHASE & CO (JPM, AMJB, VYLD, JPM-PC, JPM-PD, JPM-PJ, JPM-PK, JPM-PL, JPM-PM) (CIK 0000019617)

Letter

February 2, 2012 Via E-mail James Dimon Chairman and Chief Executive Officer JPMorgan Chase & Co. 270 Park Avenue New York, NY 10017 Re: JPMorgan Chase & Co. Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 28, 2011 Form 10-Q for Fiscal Quarter Ended September 30, 2011 Filed November 4, 2011 File No. 001-05805

Dear Mr. Dimon: We have reviewed you’re your January 18, 2012 response letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. Where we have requested changes in future filings, pleas e include a draft of your proposed disclosures that clearly identifies new or revised disclosures. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments. Form 10-K for Fiscal Period Ended December 31, 2010

General

1. Please refer to comment 3 in our letter dated December 19, 2011. In your January 18, 2012 response to the comme nt you do not address your recent $88.3 million settlement with Treasury’s Office of Financial Assets Control regarding certain apparent violations of sanctions programs relating to Cuba, Iran and Sudan. Please address the material ity of the recent settlement in light of qualitative factors, including the poten tial impact of corporate activities upon a company’s reputation and share value. In this regard, we note that the August 15, 2011 Treasury Department pre ss release about the settlement characterized certain apparent violati ons as “egregious because of reckless

James Dimon JPMorgan Chase & Co. February 2, 2012 Page 2 acts or omissions” by you. We also note newspaper articles reporting the Treasury Department’s characterizati on of certain of your actions as egregious. Form 10-Q for Fiscal Quarter Ended September 30, 2011

Regulatory Developments, page 9

2. In your response to comment seven you i ndicate that to the extent you are placed at a competitive disadvantage by the proposed rules on derivatives margin, it may impact revenues genera ted from foreign clients across a number of wholesale servi ces that you provide, not ju st revenues derived from derivatives activities within the Invest ment Bank line of business. Please expand you disclosure to identify this broader risk. The disclosure in your Form 10-Q appeared to imply that the competitive disadvantage would be limited to “a material adverse effect on [your] derivatives business.”

You may contact Rebekah Lindsey at ( 202) 551-3303 or Kevin Vaughn at (202) 551- 3494 if you have questions regarding comments on the financial statements and related matters. Please contact Seba stian Gomez Abero at (202) 55 1-3578 or me at (202) 551-3675 with any other questions. Sincerely, /s/ Suzanne Hayes Suzanne Hayes Assistant Director

Show Raw Text
February 2, 2012
 Via E-mail

James Dimon Chairman and Chief Executive Officer JPMorgan Chase & Co. 270 Park Avenue New York, NY 10017
Re: JPMorgan Chase & Co.
 Form 10-K for Fiscal Year Ended December 31, 2010
Filed February 28, 2011 Form 10-Q for Fiscal Quarter Ended September 30, 2011 Filed November 4, 2011 File No. 001-05805

Dear Mr. Dimon:
 We have reviewed you’re your January 18, 2012 response letter and have the following
comments.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
 Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  Where we have requested changes in future filings, pleas e include a draft of your proposed disclosures
that clearly identifies new or revised disclosures.  If you do not believe our comments apply
to your facts and circumstances, please tell us why in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.               Form 10-K for Fiscal Period Ended December 31, 2010

General

1. Please refer to comment 3 in our letter dated December 19, 2011.  In your
January 18, 2012 response to the comme nt you do not address your recent
$88.3 million settlement with Treasury’s Office of Financial Assets Control
regarding certain apparent violations of sanctions programs relating to Cuba,
Iran and Sudan.  Please address the material ity of the recent settlement in light
of qualitative factors, including the poten tial impact of corporate activities
upon a company’s reputation and share value.   In this regard, we note that the
August 15, 2011 Treasury Department pre ss release about the settlement
characterized certain apparent violati ons as “egregious because of reckless

James Dimon
JPMorgan Chase & Co. February 2, 2012 Page 2
 acts or omissions” by you.  We also note newspaper articles reporting the
Treasury Department’s characterizati on of certain of your actions as
egregious.
 Form 10-Q for Fiscal Quarter Ended September 30, 2011

Regulatory Developments, page 9

2. In your response to comment seven you i ndicate that to the extent you are
placed at a competitive disadvantage by the proposed rules on derivatives margin, it may impact revenues genera ted from foreign clients across a
number of wholesale servi ces that you provide, not ju st revenues derived from
derivatives activities within the Invest ment Bank line of business.  Please
expand you disclosure to identify this broader risk.  The disclosure in your
Form 10-Q appeared to imply that the competitive disadvantage would be limited to “a material adverse effect  on [your] derivatives business.”

You may contact Rebekah Lindsey at ( 202) 551-3303 or Kevin Vaughn at (202) 551-
3494 if you have questions regarding comments on the financial statements and related
matters.  Please contact Seba stian Gomez Abero at (202) 55 1-3578 or me at (202) 551-3675
with any other questions.
Sincerely,
     /s/ Suzanne Hayes  Suzanne Hayes
Assistant Director