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June 2, 2022

VIA EDGAR (Correspondence Filing)

    Ms. Christina DiAngelo-Fettig

    U.S. Securities & Exchange Commission

    100 F Street, N.E.

    Washington, DC 20549

Re: Johnson Mutual Funds Trust (the
 “Registrant”)

  File Nos. 33-52970, 811-07254

Dear Ms. DiAngelo-Fettig:

On behalf of the Registrant,
this letter responds to the comments you provided to Andrew Davalla on April 20, 2022 with respect to the Staff’s review of
the Registrant’s filings. Your comments are set forth below and each is followed by the Registrant’s response.

Comment
1 – Please note that Form N-CSR has recently been revised. Please use revised form in future filings and confirm
that Items 4(i) and 4(j) were not applicable.

Response
1 – The Registrant will use the revised form for future filings. The Registrant confirms that Items 4(i) and 4(j) were
not applicable for the fiscal year ended December 31, 2021.

Comment
2 – Pursuant to Item 2(c) of Form N-CSR, please explain whether code of ethics revisions required disclosure.

Response
2 – The revisions to the code of ethics did not require the Registrant to make disclosure pursuant to Item 2(c).

Comment
3 – For Item 4(b) of Form N-CSR, please provide a more sufficient description of audit-related fees and services.

Response
3 – The Registrant will provide such disclosure in future filings.

Comment
4 – Please file an amended Form N-CSR that provides for the appropriate references to the period covered by the
report as required by Item 11(b).

Response
4 – The Registrant will file an amended Form N-CSR that includes the appropriate disclosure under Item 11(b).

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Comment
5 – The Staff notes that approximately 75% of the Johnson Municipal Income Fund’s portfolio was comprised of municipal
issuers in Ohio. Please consider the Fund’s portfolio when referring to the Fund as being diversified by issuer, sector and state
in shareholder communications.

Response
5 – The Registrant will make such considerations in future disclosures and marketing materials.

Comment
6 – In management’s discussion of fund performance for the Johnson Enhanced Return Fund, please discuss the effect
of the use of derivatives on fund performance in future filings.

Response
6 – Future filings will include an appropriate discussion of the effect of derivatives on the Fund’s performance.

Comment
7 – With respect to graphic representation of the Municipal Income Fund’s holdings, please disclose (1) whether
such ratings are those provided by S&P or Moodys; and (2) how such ratings were selected (i.e. which is the primary source of
ratings? If rated by both agencies which rating is used?).

Response
7 – Disclosure in the future will provide more details regarding the how the ratings are determined and which ratings
are used for the purposes of the chart.

Comment
8 – With respect to the chart used for the International Fund to show its investments by country, please note in future
filings whether such percentages are based on net assets or total investments.

Response
8 – The requested additional disclosure will be provided in future filings.

Comment
9 – For the holdings chart for Enhanced Return Fund, please disclose whether the chart includes derivatives.

Response
9 – Future filings will include the requested disclosure.

Comment
10 – Please correct the headings in the Schedule of Investments for the International Fund in future filings.

Response
10 – The requested revisions will be made in future filings.

Comment
11 – Please confirm calculations in Schedule of Investments for the Municipal Income Fund in future filings.

Response
11 – The percentages will be confirmed in future filings.

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Comment
12 – Please include a holdings table for Municipal Income Fund and International Fund that categorizes holdings by state/country
of issuance. Please see FASB ASC 825-10-50 and AICPA expert panel meeting minutes from January 21, 2020.

Response
12 – The requested tables will be provided in future filings.

Comment
13 – Given the Fund’s unitary fee structure, please explain the amounts shown as “Other Expenses” for
Enhanced Return Fund’s statement of operations.

Response
13 – The “other expense line item referred to certain extraordinary audit fees related to year-end fund distributions.
Such extraordinary fees were deemed to be outside the normal operating fees and expenses covered by the Fund’s unitary fee structure.

Comment
14 – Please explain the auditing expense line item in the statement of operations for Core Plus Bond Fund.

Response
14 – The Registrant notes that, unlike the other funds in the Trust, Core Plus Bond Fund has a traditional fee structure
and does not employ a unitary fee.

Comment
15 - The financial highlights for the International Fund and Municipal Income Fund disclose return of capital and the notes
for Short Duration Bond Fund indicate a return of capital. Please explain why return of capital was not disclosed in the statement of
changes in net assets (see Reg S-X 607-3).

Response
15 – The amount of the return of capital distributions made for each of the Funds is immaterial and management elected
not to make the disclosure within the Statement of Changes. It is treated as a permanent difference for tax purposes.

Comment
16 – Please confirm that 19a-1 notices were provided to shareholders of fund with a return of capital.

Response
16 – Certain Funds pays dividends to shareholders based upon the book income of the Fund estimated in accordance with
Rule 19a-1(e) under the 1940 Act. Under Rule 19a-1, the Fund was not required to provide a written statement at the time
of the distribution as the Fund’s estimates did not indicate that the distribution would include a return of capital. Once the source
of the dividend was determined to be a return of capital, the applicable Fund disclosed the reclassification of the dividend in the report
to shareholders for the period and on the 1099-DIVs that were provided to shareholders.

Comment
17 – The Staff was unable to calculate a ratio of net investment income to average net assets of 0.84% for Opportunity
Fund. Please confirm or explain this calculation.

Response
17 – The ratio was calculated prior to adjustments made to income due to reallocation of components related to real estate
investment trusts held in the portfolio. The Registrant will ensure in the future that all ratios will be verified prior to filing.

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Comment 18 – For the funds with a unitary
fee structure, please confirm that Adviser is current with payments to fund service providers.

Response
18 – The Registrant so confirms.

Comment
19 – In Note 6 in the shareholder report for the retail Johnson Funds, please disclose how often management fees are
paid. In future filings, please disclose which fees and expenses are excluded from what is covered by the unitary fee (e.g. acquired fund
fees and expenses).

Response
19 – The requested additional disclosures will be made in future filings.

Comment
20 – In the Trustee and Officer table, please disclose the term of office (see Item 27(b)(5) of Form N-1A).

Response
20 – The requested disclosure will be provided in future filings.

Comment
21 – Please specify the fund names in the first paragraph of the expense example table.

Response
21 – The requested disclosure will be made in future filings.

Comment
22 – For Form N-CEN, please explain why “no” was checked for Item B.23 regarding return of capital.

Response
22 – Certain Funds pay dividends to shareholders based upon the book income of the Fund estimated in accordance with
Rule 19a-1(e) under the 1940 Act. Under Rule 19a-1, the Fund was not required to provide a written statement at the time
of the distribution as the Fund’s estimates did not indicate that the distribution would include a return of capital. Once the source
of the dividend was determined to be a return of capital, the applicable Fund disclosed the reclassification of the dividend in the report
to shareholders for the period and on the 1099-DIVs that were provided to shareholders.

Comment
23 – For Form N-CEN Item C.4., please note that “Yes” was marked for Municipal Income Fund though it
is a diversified fund.

Response
23 – The appropriate box will be checked in future N-CEN filings.

Comment
24 – For Item C.2.b. for Short Duration Bond Fund and Core Bond Fund, new share classes were indicated as being added
which is inconsistent with the financial statements for each fund.

Response
24 – There were no new shares classes in 2021. This will be properly noted in future filings.

Comment
25 – For Item C.8.b. for Core Plus Bond Fund, please explain the responses regarding expenses waived and potential recoupment
given the Fund’s expense waiver agreement.

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Response
25 – It is not the adviser’s intention to recoup any previously waived fees pursuant to the expense limitation
agreement. The expense limitation agreement will be revised to eliminate the adviser’s ability to recoup any such previously waived
fees.

Comment
26 – With respect to Form 40-17G filings please include the appropriate board resolution and statement for the periods
in which premiums have been paid.

Response
26 – The appropriate resolution and statement required will be provided for in future filings.

Please contact me at (614) 469-3353 if you should
require any further information.

Sincerely,

    /s/
    Andrew Davalla

    Andrew Davalla

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