SecProbe.io

Mail Stop 4628

May 22 , 201 7

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 12 , 2016
  Filed February 28, 2017
  File No. 1-5805

Dear Ms. 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
understa nd your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

General

1. In your letter to us dated October 14 , 2014, you described contacts with Syria and Sudan.
As you are aware, Syria and Sudan are designated by the State Department as state
sponsors of terrorism and are subject to U.S. economic sanctions and export controls.
Please describe to us the nature and extent of past, current, and anticipated contacts with
Syria and Sudan since your prior letter, whether through subsidiaries, affiliates,
customers  or other direct or indirect arrangements.  You should describe any products  or
services  you have provided to Syria and Sudan, directly or indirectly, and any
agreements, commercial arrangements, o r other contacts with the governments of those
countries or entities they control.

Marianne Lake
JPMorgan Chase & Co.
 May 22 , 2017
 Page 2

 2. Please discuss the materiality of any contacts with Syria and Sudan you describe 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 revenues, 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 woul d deem
important in making an investment decision, including the potential 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 companies that do business with
U.S.-designated state sponsors of terrorism.  In this regard, we note that an October 1 ,
2016 Sudan Divestment Report prepared by the Municipal Fire & Police  Retirement
System of Iowa includes JPMorgan on lists of scrutinized companies dated September
11, 2015, December 15, 2015 and June 10, 2016.  You should address the potential
impact of the investor sentiment evidenced by such actions directed toward compa nies
that have operations associated with Syria and Sudan.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the sta ff.

You may 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:  Dietrich King
  Assistant Director