SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
                  WASHINGTON, D.C. 20549

      DIVISION OF
CORPORATION FINANCE

September 2 9, 2014

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

 Re: JPMorgan Chase & Co.
  Form 10-K for the Fiscal Year Ended December 31 , 2013
  Filed February 20 , 2014
  File No. 1-5805

Dear M s. Lake :

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant  Director group with respect
to other issues.   In our comments, we ask  you to provide us with information so we may better
understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by adv ising 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.

General

1. In your letters to us dated January 18, 2012 and February 14, 2012, you discussed
contacts with Syria, Sudan and Cuba.  As you are aware, Syria, Sudan and Cuba are
designated by the State Department as state sponsors of terr orism, and are subject to
U.S. economic sanctions and export controls.  Your  10-K does n ot include disclos ure
about contacts with those countries.  Please describe to us the nature and extent of
your past, current, and anticipated contacts with Syria, Sudan and Cuba since your
2011 letters, whether through subsidiaries, affiliates , customers or other direct or
indirect arrangements.   You should describe any products, services or technology
you have provided to Syria, Sudan and Cuba, directly or indirectly, and any
agreements, commercial arrangements, or other contacts with the gov ernments of
those countries or entities they control.

Marianne Lake
JPMorgan Chase & Co.
September 2 9, 2014
Page 2

2. Please discuss the materiality of any contacts with Syria , Sudan and Cuba described
in response to the comment above, and whether those contacts constitute a material
investment risk for your security holders.  You should address materiality in
quantitative terms, including the approximate dollar amounts of any associated
revenu es, assets, and liabilities for the last three fiscal years and the subsequent
interim period .  Also, address materiality in terms of qualitative factors that a
reasonable investor would deem important in making an investment decision,
including the potent ial impact of corporate activities upon a company’s reputation
and share value.  As you know, various state and municipal governments,
universities, and other investors have proposed or adopted divestment or similar
initiatives regarding investment in comp anies that do business with U.S. -designated
state sponsors of terrorism.   You should address the potential impact of the investor
sentiment evidenced by such actions directed toward companies that have operations
associated with Syria , Sudan  and Cuba .

In this regard, w e note that your most recent proxy statement again includes a
shareholder proposal requesting that your board institute transparent procedures to
prevent holding investments in companies that substantially contribute to genocide or
crimes  against humanity.  The proposal states that you are a large holder of
PetroChina which, through its parent, China National Petroleum Company, is Sudan’s
largest trading partner.  We are aware of 2012 and 2013 articles discussing such
shareholder proposals  and stating that you own shares in PetroChina and Sinopec, a
company they report also is recognized as contributing to the genocide in Sudan.
Please discuss for us the potential reputational impact of the proposal and articles
linking you to PetroChina a nd Sinopec.

We urge all persons who are responsible  for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to the company’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

In responding to our comments, please provide a written state ment from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any act ion with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Marianne Lake
JPMorgan Chase & Co.
September 2 9, 2014
Page 3

 Please contact Jennifer Hardy, Special Counsel , at (202) 551 -3767 or me at (202) 551 -
3470 if you have any questions about the comments or our review.

                  Sincerely,

                  /s/ Cecilia Blye

                  Cecilia Blye, Chief
                  Office of Global Security Risk

cc:  Suzanne  Hayes
  Assistant Director
 Division of Corporation Finance