SEC Company Response from JPMORGAN TRUST II (CIK 0000763852) — Sep 28, 2021
JPMORGAN TRUST II (CIK 0000763852)
Date: Sept. 28, 2021 · CIK: 0000763852 · Accession: 0001193125-21-285135
AI Filing Summary & Sentiment
File numbers found in text: 811-04236, 811-07874, 811-21295, 811-22903, 811-23117
Letter
Division of Investment Management Brookfield Place 200 Vesey Street – Suite 400 New York, NY 10281-1022 RE: JPMorgan Trust I, File No. 811-21295; JPMorgan Trust II, File No. 811-04236; JPMorgan Trust IV, File No. 811-23117; JPMorgan Insurance Trust, File No. 811-07874; and J.P. Morgan Exchange-Traded Fund Trust, File No. 811-22903 (each, a ”Trust” and collectively, the “Trusts”)
Dear Mr. Long:
This letter responds to the comment you provided to us by telephone on September 1, 2021, with respect to the series of the Trusts listed on Schedule A hereto (each series, a “Fund” and collectively, the “Funds”) and certain shareholder reports of such Funds in connection with a review of certain filings and reports by the staff of the Securities and Exchange Commission pursuant to the Sarbanes-Oxley Act of 2002. Our response to your comment is set forth below.
Comment: JPMorgan Insurance Trust Global Allocation Portfolio (for the purposes of this comment and response, the “Fund”) answered “Yes” to Form N-CEN Item B.22 [During the reporting period, were any payments made to shareholders or shareholder accounts reprocessed as a result of an error in calculating the Registrant’s net asset value (or net asset value per share)]. Since there was no explanation of the error in the December 31, 2020 annual report, please provide details around the NAV error and remedial steps taken to help ensure the error does not occur again.
Response: The NAV error was the result of utilizing incorrect prices for certain S&P 500 futures contacts held by the Fund. The impact of the error was greater than one half of one percent, therefore resulting in the reprocessing of shareholder transactions in the Fund. At the time of the error, the Fund’s accounting agent’s (“Fund Accounting Agent”) process to obtain daily prices for futures contracts from the Chicago Mercantile Exchange (the “Exchange”) involved a manual component to pull the Exchange prices. Subsequent to the NAV error, the valuation process to obtain the Exchange prices has become fully automated within the Fund Accounting Agent’s pricing utility, which we believe eliminated the risk of this same issue happening again.
If you have any questions regarding the foregoing, please call me at (212) 623-8104.
Very truly yours,
/s/ Timothy J. Clemens
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CORRESP 1 filename1.htm JPMorgan Trust II September 28, 2021 Jeff Long Division of Investment Management Disclosure Review and Accounting Office U.S. Securities and Exchange Commission Brookfield Place 200 Vesey Street – Suite 400 New York, NY 10281-1022 RE: JPMorgan Trust I, File No. 811-21295; JPMorgan Trust II, File No. 811-04236; JPMorgan Trust IV, File No. 811-23117; JPMorgan Insurance Trust, File No. 811-07874; and J.P. Morgan Exchange-Traded Fund Trust, File No. 811-22903 (each, a ”Trust” and collectively, the “Trusts”) Dear Mr. Long: This letter responds to the comment you provided to us by telephone on September 1, 2021, with respect to the series of the Trusts listed on Schedule A hereto (each series, a “Fund” and collectively, the “Funds”) and certain shareholder reports of such Funds in connection with a review of certain filings and reports by the staff of the Securities and Exchange Commission pursuant to the Sarbanes-Oxley Act of 2002. Our response to your comment is set forth below. Comment: JPMorgan Insurance Trust Global Allocation Portfolio (for the purposes of this comment and response, the “Fund”) answered “Yes” to Form N-CEN Item B.22 [During the reporting period, were any payments made to shareholders or shareholder accounts reprocessed as a result of an error in calculating the Registrant’s net asset value (or net asset value per share)]. Since there was no explanation of the error in the December 31, 2020 annual report, please provide details around the NAV error and remedial steps taken to help ensure the error does not occur again. Response: The NAV error was the result of utilizing incorrect prices for certain S&P 500 futures contacts held by the Fund. The impact of the error was greater than one half of one percent, therefore resulting in the reprocessing of shareholder transactions in the Fund. At the time of the error, the Fund’s accounting agent’s (“Fund Accounting Agent”) process to obtain daily prices for futures contracts from the Chicago Mercantile Exchange (the “Exchange”) involved a manual component to pull the Exchange prices. Subsequent to the NAV error, the valuation process to obtain the Exchange prices has become fully automated within the Fund Accounting Agent’s pricing utility, which we believe eliminated the risk of this same issue happening again. If you have any questions regarding the foregoing, please call me at (212) 623-8104. Very truly yours, /s/ Timothy J. Clemens Timothy J. Clemens Treasurer Schedule A File # Registrant Name Series Name FYE Reviewed 811-23117 JPMORGAN TRUST IV JPMorgan Institutional Tax Free Money Market Fund 2/28/2021 811-23117 JPMORGAN TRUST IV JPMorgan Core Focus SMA Fund 2/28/2021 811-23117 JPMORGAN TRUST IV JPMorgan Ultra-Short Municipal Fund 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan BetaBuilders Developed Asia ex-Japan ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan BetaBuilders Canada ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan USD Emerging Markets Sovereign Bond ETF 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan U.S. Quality Factor ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan U.S. Value Factor ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan U.S. Momentum Factor ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan U.S. Minimum Volatility ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan U.S. Dividend ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan Diversified Return U.S. Small Cap Equity ETF 10/31/2020 811-23117 JPMORGAN TRUST IV JPMorgan Equity Premium Income Fund 6/30/2020 811-23117 JPMORGAN TRUST IV JPMorgan Securities Lending Money Market Fund 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan BetaBuilders Japan ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan International Bond Opportunities ETF 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan BetaBuilders MSCI U.S. REIT ETF 2/28/2021 811-21295 JPMorgan Trust I JPMorgan U.S. Research Enhanced Equity Fund 6/30/2020 811-21295 JPMorgan Trust I JPMorgan Growth and Income Fund 6/30/2020 811-21295 JPMorgan Trust I JPMorgan U.S. Large Cap Core Plus Fund 6/30/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan Core Plus Bond ETF 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan Municipal ETF 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan Ultra-Short Municipal Income ETF 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan Corporate Bond Research Enhanced ETF 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan U.S. Aggregate Bond ETF 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan BetaBuilders 1-5 Year U.S. Aggregate Bond ETF 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan BetaBuilders U.S. Equity ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan BetaBuilders International Equity ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan BetaBuilders U.S. Mid Cap Equity ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan BetaBuilders Europe ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan Ultra-Short Income ETF 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan Diversified Return U.S. Mid Cap Equity ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan International Growth ETF 10/31/2020 811-04236 JPMORGAN TRUST II JPMorgan Sustainable Municipal Income Fund 2/28/2021 811-04236 JPMORGAN TRUST II JPMorgan Short-Intermediate Municipal Bond Fund 2/28/2021 811-04236 JPMORGAN TRUST II JPMorgan Tax Free Bond Fund 2/28/2021 811-04236 JPMORGAN TRUST II JPMorgan Equity Income Fund 6/30/2020 811-04236 JPMORGAN TRUST II JPMorgan Large Cap Growth Fund 6/30/2020 811-04236 JPMORGAN TRUST II JPMorgan Large Cap Value Fund 6/30/2020 811-04236 JPMORGAN TRUST II JPMorgan Liquid Assets Money Market Fund 2/28/2021 811-04236 JPMORGAN TRUST II JPMorgan Municipal Money Market Fund 2/28/2021 811-04236 JPMORGAN TRUST II JPMorgan U.S. Government Money Market Fund 2/28/2021 811-04236 JPMORGAN TRUST II JPMorgan U.S. Treasury Plus Money Market Fund 2/28/2021 811-21295 JPMorgan Trust I JPMorgan 100% U.S. Treasury Securities Money Market Fund 2/28/2021 811-21295 JPMorgan Trust I JPMorgan California Municipal Money Market Fund 2/28/2021 811-21295 JPMorgan Trust I JPMorgan Federal Money Market Fund 2/28/2021 811-21295 JPMorgan Trust I JPMorgan New York Municipal Money Market Fund 2/28/2021 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan High Yield Research Enhanced ETF 2/28/2021 811-21295 JPMorgan Trust I JPMorgan Prime Money Market Fund 2/28/2021 811-21295 JPMorgan Trust I JPMorgan High Yield Municipal Fund 2/28/2021 811-21295 JPMorgan Trust I JPMorgan Equity Focus Fund 6/30/2020 811-21295 JPMorgan Trust I JPMorgan Short Duration Core Plus Fund 2/28/2021 811-21295 JPMorgan Trust I JPMorgan Hedged Equity Fund 6/30/2020 811-07874 JPMORGAN INSURANCE TRUST JPMorgan Insurance Trust Core Bond Portfolio 12/31/2020 811-07874 JPMORGAN INSURANCE TRUST JPMorgan Insurance Trust U.S. Equity Portfolio 12/31/2020 811-07874 JPMORGAN INSURANCE TRUST JPMorgan Insurance Trust Mid Cap Value Portfolio 12/31/2020 811-07874 JPMORGAN INSURANCE TRUST JPMorgan Insurance Trust Small Cap Core Portfolio 12/31/2020 811-07874 JPMORGAN INSURANCE TRUST JPMorgan Insurance Trust Global Allocation Portfolio 12/31/2020 811-07874 JPMORGAN INSURANCE TRUST JPMorgan Insurance Trust Income Builder Portfolio 12/31/2020 811-21295 JPMorgan Trust I JPMorgan U.S. Equity Fund 6/30/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan Diversified Return International Equity ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan Diversified Return Emerging Markets Equity ETF 10/31/2020 811-22903 J.P. Morgan Exchange-Traded Fund Trust JPMorgan Diversified Return U.S. Equity ETF 10/31/2020 811-21295 JPMorgan Trust I JPMorgan Tax Free Money Market Fund 2/28/2021