SecProbe.io

February 15, 2013

Via E -mail
Marianne Lake
Chief Financial Officer
JPMorgan Chase & Co.
270 Park Avenue
New York, NY 10017

Re: JPMorgan Chase & Co .
 Form 10 -K for Fiscal Year Ended December 31, 2011
 Filed  February 29, 2012
Form 10-Q for Fiscal Quarter Ended March 31, 2012
Filed May 10, 2012
Form 10 -Q for Fiscal Quarter Ended September 30, 2012
Filed November 8, 2012
Response dated December 3, 2012
File No. 001 -05805

Dear Ms. Lake :

We have reviewed your filing s and response letter dated December 3, 2012  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 thi s letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.   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 -Q for Fiscal Quarter Ended March 31, 2012

Notes to Consolidated Financial Statements , page 90

Note 3 – Fair Value Measurement, page 91

1. We note your response to prior comment 4 of our letter dated November 7, 2012.  Please
tell us whether as of March 31, 2012 any positions in the Chief Investment Office ( CIO)
synthetic credit portfolio were found to have been valued at an amount t hat was outside
of the bid -offer spread, and if so, quantify the amount that was outside of the spread.
Please also tell us whether you performed a similar analysis as of December 31, 2011 or

Marianne Lake
JPMorgan Chase & Co.
February 15, 2013
Page 2

 earlier periods, and if so quantify the amount that was outside  of the spread.  Lastly, tell
us whether you performed any procedures to evaluate the sensitivity of the pricing
variance thresholds utilized by CIO Valuation Control Group ( VCG ) as of
December 31, 2011 and whether, as a result of these procedures, you be lieve that the
front office marks could have been outside of the bid -ask spread but still within the
acceptable VCG range  such that the fair value of the CIO synthetic portfolio could have
been materially misstated.

2. We note your responses to prior comments 11, 13,  and 21 from our letter dated
July 25, 2012 where you discuss, in part, the liquidity of the CIO synthetic credit
portfolio, the valuatio n process for those instruments , and the fact that they are all
classified as Level 2 instruments in the fair value hierarchy.   Please respond to the
following:

 Tell us the percentages of on -the-run and off -the-run synthetic credit instruments that
were priced based on or validated with  observable pricing sources as of
December 31, 2011, March 31, 2012, and December 31, 2012.

 Please identify and quantify the extent of the sources used (such as Markit and Totem
noted in response to prior comment 13), and explain in further detail how each source
functioned with respect to these instruments.   As part of your response, please
provide an indication of the volume of transactions that these pricing sources were
able to look to in order to develop a price for these instruments.

 Discuss whet her there were any changes in the level of the validating information
available at June 30, 2012 or September 30, 2012.

 Tell us whether any CIO synthetic credit portfolio positions were priced using non -
binding quotes, and if so, quantify the value of tho se positions at each respective
balance sheet date as noted above.   As part of your response, please tell us the
corroborating information you considered in concluding that these positions fell
within Level 2 of the fair value hierarchy, and confirm whethe r such corroborating
evidence was available for all these positions.

Note 24 – Business Segments, page 163

3. We note your response to prior comment 19 of our letter dated July 25, 2012.  In your
response you state that any difference between a reporting  unit’s net assets (considering
its identified/attributed assets and liabilities) and its allocated equity represents an
intercompany funding asset and/or liability.  Please quantify and describe the significant
assets and liabilities that are recorded in your Corporate/Private equity segment and tell
us in more detail how you considered the guidance in ASC 350 -20-35-7 in determining
that you were not required to specifically allocate those assets and liabilities to your
reporting units.

Marianne Lake
JPMorgan Chase & Co.
February 15, 2013
Page 3

 4. Describe any recon ciling procedures you perform to conclude that the establishment of
intercompany funding assets and liabilities based on assumed terms (e.g., interest rates,
maturities) is consistent with the terms of the actual assets and liabilities you held.  Please
tell us how you determine whether there are differences between the actual fair values of
the assets and liabilities that are allocated from the Corporate/Private Equity segment  and
the fair values of those same assets and liabilities based on the assumed te rms you
included in your intercompany funding assets and liabilities

Form 10 -Q for Fiscal Quarter Ended September 30, 2012

Market Risk Management – Value -at-risk, page 96

5. We note your disclosure on page 98 that during the third quarter of 2012 you applied a
new Value at Risk (“VaR”) model to calculate VaR for the synthetic credit portfolio, and
that this new model resulted in a reduction in average total VaR of $36 million for the
three months ended September 30, 2012.  Please revise your disclosure  in future filings to
explain how the new model differs from your previous model, including a discussion of
any changes made to key model characteristics, assumptions and parameters.  Please also
explain to us how the new model was validated.

Please conta ct Angela Connell at (202) 551 -3426  or Kevin W. Vaughn, Accounting
Branch Chief, at (202) 551 -3494 with any other questions.

Sincerely,

 /s/ Kevin W. Vaughn for

Suzanne Hayes
Assistant Director