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SEC Correspondence

 Confidential Treatment

Requested by JPMorgan Chase & Co.

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 May 2, 2012

Ms. Suzanne Hayes

 Assistant Director

 Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

Re:
JPMorgan Chase & Co.

Form 10-K for Fiscal Year Ended December 31, 2011

 Filed February 29, 2012

 Form 8-K filed April 13, 2012

File No. 001-05805

 Dear
Ms. Hayes:

 We are in receipt of the letter dated April 17, 2012 to Douglas L. Braunstein, Executive Vice President
and Chief Financial Officer of JPMorgan Chase & Co. (“JPMorgan Chase” or the “Firm”), from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), regarding the
above-referenced filings.

 Certain confidential portions of this letter were omitted by means of redacting a portion of the
text. The word “[Redacted]” has been inserted in place of the portions so omitted. Pursuant to the provisions of 17 C.F.R. §200.83, we have separately submitted a copy of this letter containing the redacted portions of this letter
with the Staff and have requested confidential treatment for the redacted portions of this letter.

 To assist in your review
of our responses to the comments set forth in the Staff’s letter, we have set forth below in full the comments contained in the letter, together with our responses.

 Form 10-K for Fiscal Year Ended December 31, 2011

 Item1A. Risk Factors,
page 7

 A breach of security of JPMorgan Chase’s systems could disrupt its businesses, result in the disclosure of
confidential information, damage its reputation and create significant financial and legal exposure for the Firm, page 13

1.
 We note that you disclose that you and other financial services institutions have reported breaches in the security of your websites or other
systems, including sophisticated and targeted attacks and that the consequences could include disruption of your operations, misappropriation of confidential information, and damages to computers or systems. Please tell us what consideration you
have given to expanding your risk factor disclosure to discuss any specific security breaches or attacks you

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have experienced in the past, including any related known or potential costs and other consequences of those breaches or attacks, in order to place the risks described in this risk factor in
appropriate context. Please refer to the Division of Corporation Finance’s Disclosure Guidance Topic No. 2 at http://www.sec.gov/divisions/corpfin/guidance/cfguidance-topic2.htm for additional information.

The Firm has evaluated and continues to monitor and assess actual and potential attacks or threats to the security of its computer
systems, software, networks and other technology assets and the integrity and confidentiality of information belonging to the Firm and its customers in light of its disclosure obligations under the securities laws. The Firm does not believe that any
past security breaches or attacks that it has experienced have had or will have a material adverse effect on the Firm’s operations or financial results or have resulted or will result in any material harm to its customers and clients.

 As a large financial services institution, it is critical for the Firm to maintain the security of its systems and information
against cyberattacks and other types of security breaches and, as indicated in the Firm’s risk factor disclosure, the Firm devotes significant resources in order to maintain and regularly upgrade the systems and processes that are designed to
defend against such attacks and breaches.

 As noted in the Firm’s risk factor, the Firm is the target of ongoing
cybersecurity attacks, and has experienced various kinds of cybersecurity incidents from time to time. For the Staff’s information, these have included:

•

 phishing – attempts to obtain confidential or personal data about the Firm or its customers through fraudulent emails directed to the Firm

•

 malware – attempts to obtain information or disrupt operations through disguised software containing viruses

•

 attacks against third-party vendors that provide services to the Firm in an effort to obtain information about the Firm or its customers

 As indicated above, none of these types of incidents have in the past, either individually or in the
aggregate, resulted in material harm to the Firm or its customers. The Firm will continue to monitor and evaluate the impact of actual and potential cybersecurity breaches or attacks and will make appropriate further disclosures should any such
incidents have a material adverse effect on the Firm or its customers.

 Management’s Discussion and Analysis, page 63

 General

2.
 Recent news articles have reported about alleged problems in your credit card collection process and the fact that you had halted or dismissed a
number of credit card collection suits. Please tell us what effect, if any, such halt or dismissal of credit card collection suits had, or will have, on your results of operations. In your response,

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please also address how you determined that no disclosure was needed in the Management’s Discussion and Analysis section or, alternatively, please point us to the location in your filing
where the discussion is presented.

 Based upon issues discovered in mortgage foreclosure litigation, the Firm
conducted a review of collection litigation processes in other lines of business and found certain procedural issues associated with credit card collection cases. As a result, in the second quarter of 2011, the Firm stayed or dismissed the credit
card collection cases that were then in collection litigation and suspended the filing of new cases. The Firm has since performed testing and found that, in the overwhelming majority of cases, the amounts collected from customers were
appropriate. In addition, because only a small portion of delinquent accounts are sent to litigation and other collection tools continue to be used for these delinquent credit card accounts, this suspension or dismissal of litigation had a
relatively insignificant effect on the Firm’s overall credit card net charge-offs and its credit loss forecast.

Throughout the second half of 2011, the Firm experienced significant improvement in its overall credit card loss forecast primarily as a
result of declining delinquency rates due to a generally improving economic environment, and the insignificant unfavorable variances to the Firm’s credit loss forecast as a result of the collection litigation moratorium did not impact this
trend. Because i) the unfavorable variances described above did not have a significant impact on either the Firm’s credit loss trends (i.e., net charge-offs) or forecast, ii) only a small portion of delinquent accounts are sent to
litigation, and iii) the Firm believed that remediation risk was relatively low based on the results of the Firm’s testing procedures, the Firm did not separately disclose the effects of halting or dismissing these credit card collection
suits.

 Selected European exposure, page 164

3.
Please address the following regarding the disclosure around your Country Risk Management, including your Selected European exposure:

•

 In future filings, please provide a breakout of your Ireland, Portugal, and Greece exposures to provide greater transparency around your activities
in each of these individual countries.

•

 In future filings, for your lending activities, please provide the gross amount prior to the deduction of the allowance for loan losses to
supplement your presentation of the net amount after allowance for loan losses.

•

 We note your disclosure around your credit default swaps including both the gross notional and fair value. In future filings, please provide this
information on a country-by-country basis, preferably included in the table on page 165 to provide greater transparency around your activities in each of these individual countries.

The Firm shares the Staff’s interest in transparent disclosures that enable financial statement users to understand and evaluate the
Firm’s financial performance and risk

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exposures. Such transparency is enhanced by disclosures that are appropriately tailored to the size and characteristics of the Firm’s specific risk exposures, and we believe that the
disclosures in the Firm’s Form 10-K for the year ended December 31, 2011 related to the five named European countries appropriately focus on relevant information without adding details regarding individual items that are too small to
provide meaningful information to financial statement users.

•

 Spain and Italy represent over 85% of the Firm’s total exposure in the five named European countries, and the Firm’s exposure in the
remaining three countries is insignificant (individually and in the aggregate) to the Firm’s country risk profile and financial performance. For this reason, the Firm does not believe that this additional information would be meaningful to
financial statement users. In addition, due to the small size of the Firm’s exposures in these countries, more granular disclosures may result in disclosure of individual transactions or positions, which the Firm does not believe is relevant or
appropriate. The Firm will continue to monitor the size and nature of the Firm’s exposures in these countries and should there be material changes in its exposures, the Firm will adjust its presentation accordingly in future filings.

•

 Predominantly all of the Firm’s lending exposures in the five named European countries are to investment grade borrowers. [Redacted] This
allowance is insignificant relative to the Firm’s exposures in these five countries and to the Firm’s provision and allowance for credit losses, and therefore is not meaningful to separately disclose.

•

 The Firm’s disclosures of gross notional amounts and fair values of single-name credit default swap (“CDS”) protection sold and
purchased in the five named European countries is intended to provide information regarding the volume of the Firm’s single-name CDS relative to the net amounts presented in the total exposure table (which the Firm believes are more relevant
for the reasons addressed on page 165 of the Firm’s Form 10-K for the year ended December 31, 2011). To provide additional information regarding the geographic distribution of the volume of the Firm’s single-name CDS, the Firm will
enhance its disclosures in future filings to note that approximately 30% and 50% of the notional amount of the single-name CDS relates to Spain and Italy, respectively, with the remaining amounts distributed relatively equally among the remaining
countries.

 The Firm will continue to monitor the size and risks of its exposures in the five named European
countries and will continue to evaluate its disclosures in future filings to address material changes in the Firm’s exposures and economic conditions.

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 Consolidated Financial Statements

 Notes to Consolidated Financial Statements

 Note 3 – Fair value
measurement, page 184

4.
We note that in your fair value hierarchy table on page 189 and footnote (c) on page 190, you have approximately $26 billion in physical commodities that are
reported at a lower of cost or fair value. Please tell us the amount of your physical commodities that are at fair value. Also, please clarify the statement that your physical commodities are carried at lower of cost or fair value and not lower of
cost of market as defined in ASC 330.

 The Firm’s physical commodities inventories are generally carried
at the lower of cost or fair value, subject to applicable fair value hedge accounting adjustments. As of December 31, 2011, the composition of these physical commodities was as follows (in USD millions):

 Lower of cost or fair value (no hedge accounting):

 Cost

$
1,199

 Fair value

635

 Total – Lower of cost or fair value

$
1,834

 Subject to fair value hedge accounting

24,130

 Total

$
25,964

 For the Firm’s physical commodities, the primary difference between “fair value” and
“market value” as defined in accounting literature relates to the treatment of transaction costs. Such costs are excluded in the determination of fair value, but are included in the determination of market value. The Firm’s physical
commodity positions are generally located in our principal market for that commodity; accordingly, transaction costs are either not applicable, or are an immaterial component of the asset’s overall fair value. The Firm uses the term “fair
value” throughout its financial statements and, to avoid confusion for users of our financial statements regarding the insignificant and nuanced difference between “market value” and “fair value”, we refer to these positions
being recorded at the lower of cost or fair value.

5.
For amounts that are not at fair value, please tell us your basis for including these amounts in the fair value hierarchy.

The Firm includes all physical commodities inventories in the fair value hierarchy for the following reasons:

•

 A significant portion of our physical commodities inventories is subject to fair value hedge accounting. As of December 31, 2011, approximately
98% of the physical commodities inventories that are the hedged item in a fair value hedge relationship and have been subject to the hedge relationship since purchase. Therefore the current adjusted cost basis reflects the changes in fair value
since purchase and equals fair value. Predominantly all (93%) of the Firm’ physical commodities are recorded on

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the balance sheet at fair value because they were either a) subject to fair value hedging since inception, or b) carried at the lower of cost or fair value where fair value was below cost.

•

 The Firm’s reporting enhances comparability of the fair value hierarchy information with the Firm’s primary U.S. competitors in the
commodities business, which have been permitted to carry physical commodities inventory at fair value on the balance sheet with gains and losses reported in net income (and therefore report physical commodity inventory in the fair value hierarchy
table). It is also consistent with how our international competitors in the commodities business report and disclose physical commodities under International Financial Reporting Standards.

•

 The Firm believes that reporting commodities inventories in the recurring fair value table, with appropriate footnote disclosures, provides the most
meaningful information for financial statement users. The Firm does not believe that it would be appropriate to include commodities inventories in the non-recurring fair value table given the high proportion of the inventory for which the cost basis
is adjusted to fair value. Similarly, presenting a portion of the Firm’s commodities inventory in the recurring fair value disclosures and a portion in the non-recurring fair value disclosures (where such portions would vary period to period)
would be more confusing for users than to simply present the Firm’s commodities inventory in a single location with appropriate disclosure.

 For these reasons, the Firm believes that inclusion of its physical commodity inventory in the fair value hierarchy table is the most transparent and relevant information for financial statement users.
Given the significance of the balance carried at fair value as a result of fair value hedge accounting, we will clarify our disclosure in future filings as follows:

 Physical commodities inventories are generally carried at the lower of cost or fair value, subject to any ap