SEC Company Response from UNDISCOVERED MANAGERS FUNDS (CIK 0001047712) — Apr 16, 2020
UNDISCOVERED MANAGERS FUNDS (CIK 0001047712)
Date: April 16, 2020 · CIK: 0001047712 · Accession: 0001683863-20-003603
AI Filing Summary & Sentiment
File numbers found in text: 811-04236, 811-08437, 811-21295, 811-21552, 811-21638, 811-22575, 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 Institutional Trust, File No. 811-21638; Undiscovered Managers Funds, File No. 811-08437; J.P. Morgan Access Multi-Strategy Fund II, File No. 811-22575; and J.P. Morgan Access Multi-Strategy Fund, L.L.C., File No. 811-21552 (each, a ”Trust” and collectively, the “Trusts”)
Dear Ms. Rotter:
This letter is in response to the comments you provided to us by telephone on March 17, 2020 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 the Sarbanes-Oxley examination of the Funds. Our responses to your comments are set forth below.
1.
Comment: For JPMorgan Realty Income Fund, JPMorgan Intermediate Bond Trust, JPMorgan Core Bond Trust, JPMorgan Floating Rate Income Fund, JPMorgan Core Bond Fund, JPMorgan Core Plus Bond Fund, JPMorgan Government Bond Fund, JPMorgan California Municipal Money Market Fund, JPMorgan New York Municipal Money Market Fund, J.P. Morgan Access Multi-Strategy Fund II and J.P. Morgan Access Multi-Strategy Fund, L.L.C., confirm that there are no open payables to the Trustees and the Chief Compliance Officer at each Fund’s respective year end. If there were, explain why the amounts weren’t disclosed separately in accordance with Rule 6-04 under Regulation S-X.
Response: We confirm there were no amounts payable to the Trustees or the Chief Compliance Officer for JPMorgan Core Bond Trust, JPMorgan Floating Rate Income Fund, J.P. Morgan Access Multi-Strategy Fund II and J.P. Morgan Access Multi-Strategy Fund, L.L.C. as of such Fund’s or Trust’s respective year end. The remaining Funds or Trusts had amounts payable to the Trustees and the Chief Compliance Officers as of their respective fiscal year end that were, in each case, less than $500 and therefore deemed to be immaterial. Accordingly, these amounts were not disclosed as a separate line item on the statement of assets and liabilities since the financial statements are reported in thousands.
2.
Comment: For the JPMorgan High Yield Municipal Fund, please explain the increase in portfolio turnover rate as of February 28, 2019 in comparison with the prior year.
Response: The increase in portfolio turnover rate for the fiscal year ended February 28, 2019 compared to the rate for the fiscal year ended February 28, 2018 was the result of changes made to the Fund’s portfolio following a change to the Fund’s investment strategy regarding investments in high yield securities.
3.
Comment: For those money market funds (e.g., JPMorgan Liquid Assets Money Market Fund and JPMorgan Institutional Tax Free Money Market Fund) with the ability to charge liquidity fees and/or impose redemption gates, please explain why these policies have not been disclosed in the Notes to Financial Statements in accordance with Rule 2a-7 under the Investment Company Act of 1940.
Response: For a money market fund with the ability to charge a liquidity fee and/or impose a redemption gate, such fee and/or redemption policy is disclosed in Note 1 to the Financial Statements in the February 28, 2019 annual report. None of the money market funds charged a fee or imposed a redemption gate during the period covered in the financial statements.
4.
Comment: Prospectus – For the JPMorgan Securities Lending Money Market Fund, please explain why the Fund’s investment objective is not described in the Prospectus dated July 1, 2019.
Response: The sentence describing the Fund’s investment objective was inadvertently omitted from the Prospectus as originally filed. The Prospectus was refiled on October 7, 2019 to include the sentence after the inadvertent omission was detected.
If you have any questions regarding the foregoing, please call me at (212) 623-8104.
Very truly yours,
/s/ Timothy J. Clemens
Show Raw Text
CORRESP
1
filename1.htm
April 16, 2020
Mindy Rotter, Esq., CPA
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 Institutional Trust, File No. 811-21638; Undiscovered Managers Funds, File No. 811-08437; J.P. Morgan Access Multi-Strategy Fund II, File No. 811-22575; and J.P. Morgan Access Multi-Strategy Fund, L.L.C., File No. 811-21552 (each, a ”Trust” and collectively, the “Trusts”)
Dear Ms. Rotter:
This letter is in response to the comments you provided to us by telephone on March 17, 2020 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 the Sarbanes-Oxley examination of the Funds. Our responses to your comments are set forth below.
1.
Comment: For JPMorgan Realty Income Fund, JPMorgan Intermediate Bond Trust, JPMorgan Core Bond Trust, JPMorgan Floating Rate Income Fund, JPMorgan Core Bond Fund, JPMorgan Core Plus Bond Fund, JPMorgan Government Bond Fund, JPMorgan California Municipal Money Market Fund, JPMorgan New York Municipal Money Market Fund, J.P. Morgan Access Multi-Strategy Fund II and J.P. Morgan Access Multi-Strategy Fund, L.L.C., confirm that there are no open payables to the Trustees and the Chief Compliance Officer at each Fund’s respective year end. If there were, explain why the amounts weren’t disclosed separately in accordance with Rule 6-04 under Regulation S-X.
Response: We confirm there were no amounts payable to the Trustees or the Chief Compliance Officer for JPMorgan Core Bond Trust, JPMorgan Floating Rate Income Fund, J.P. Morgan Access Multi-Strategy Fund II and J.P. Morgan Access Multi-Strategy Fund, L.L.C. as of such Fund’s or Trust’s respective year end. The remaining Funds or Trusts had amounts payable to the Trustees and the Chief Compliance Officers as of their respective fiscal year end that were, in each case, less than $500 and therefore deemed to be immaterial. Accordingly, these amounts were not disclosed as a separate line item on the statement of assets and liabilities since the financial statements are reported in thousands.
2.
Comment: For the JPMorgan High Yield Municipal Fund, please explain the increase in portfolio turnover rate as of February 28, 2019 in comparison with the prior year.
Response: The increase in portfolio turnover rate for the fiscal year ended February 28, 2019 compared to the rate for the fiscal year ended February 28, 2018 was the result of changes made to the Fund’s portfolio following a change to the Fund’s investment strategy regarding investments in high yield securities.
3.
Comment: For those money market funds (e.g., JPMorgan Liquid Assets Money Market Fund and JPMorgan Institutional Tax Free Money Market Fund) with the ability to charge liquidity fees and/or impose redemption gates, please explain why these policies have not been disclosed in the Notes to Financial Statements in accordance with Rule 2a-7 under the Investment Company Act of 1940.
Response: For a money market fund with the ability to charge a liquidity fee and/or impose a redemption gate, such fee and/or redemption policy is disclosed in Note 1 to the Financial Statements in the February 28, 2019 annual report. None of the money market funds charged a fee or imposed a redemption gate during the period covered in the financial statements.
4.
Comment: Prospectus – For the JPMorgan Securities Lending Money Market Fund, please explain why the Fund’s investment objective is not described in the Prospectus dated July 1, 2019.
Response: The sentence describing the Fund’s investment objective was inadvertently omitted from the Prospectus as originally filed. The Prospectus was refiled on October 7, 2019 to include the sentence after the inadvertent omission was detected.
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 ID
Series Name
FYE Reviewed
1
811-08437
UNDISCOVERED MANAGERS FUNDS
S000004186
Undiscovered Managers Behavioral Value Fund - changed YE (8/31)
6//30/2019
2
811-08437
UNDISCOVERED MANAGERS FUNDS
S000004187
JPMorgan Realty Income Fund - changed YE (8/31)
2/28/2019
3
811-21638
JPMorgan Institutional Trust
S000007336
JPMorgan Intermediate Bond Trust
2/28/2019
4
811-21638
JPMorgan Institutional Trust
S000007337
JPMorgan Core Bond Trust
2/28/2019
5
811-21295
JPMorgan Trust I
S000032548
JPMorgan Floating Rate Income Fund - changed YE (8/31)
8/31/2019
6
811-21295
JPMorgan Trust I
S000037860
JPMorgan Global Bond Opportunities Fund (8/31)
2/28/2019
7
811-21295
JPMorgan Trust I
S000029581
JPMorgan Managed Income Fund
2/28/2019
8
811-04236
JPMorgan Trust II
S000003477
JPMorgan Core Bond Fund
2/28/2019
9
811-04236
JPMorgan Trust II
S000003478
JPMorgan Core Plus Bond Fund
2/28/2019
10
811-04236
JPMorgan Trust II
S000003485
JPMorgan Government Bond Fund
2/28/2019
11
811-04236
JPMorgan Trust II
S000003486
JPMorgan High Yield Fund
2/28/2019
12
811-21295
JPMorgan Trust I
S000044081
JPMorgan Income Fund
2/28/2019
13
811-21295
JPMorgan Trust I
S000028002
JPMorgan Inflation Managed Bond Fund
2/28/2019
14
811-04236
JPMorgan Trust II
S000003492
JPMorgan Limited Duration Bond Fund
2/28/2019
15
811-04236
JPMorgan Trust II
S000003488
JPMorgan Mortgage-Backed Securities Fund
2/28/2019
16
811-04236
JPMorgan Trust II
S000003490
JPMorgan Short Duration Bond Fund
2/28/2019
17
811-21295
JPMorgan Trust I
S000039927
JPMorgan Short Duration Core Plus Fund
2/28/2019
18
811-21295
JPMorgan Trust I
S000002966
JPMorgan California Municipal Money Market Fund
2/28/2019
19
811-21295
JPMorgan Trust I
S000002968
JPMorgan New York Municipal Money Market Fund
2/28/2019
20
811-21295
JPMorgan Trust I
S000002945
JPMorgan California Tax Free Bond Fund
2/28/2019
21
811-21295
JPMorgan Trust I
S000002946
JPMorgan Intermediate Tax Free Bond Fund
2/28/2019
22
811-21295
JPMorgan Trust I
S000002948
JPMorgan New York Tax Free Bond Fund
2/28/2019
23
811-21295
JPMorgan Trust I
S000039803
JPMorgan Corporate Bond Fund
2/28/2019
24
811-21295
JPMorgan Trust I
S000041740
JPMorgan Emerging Markets Corporate Debt Fund
2/28/2019
25
811-21295
JPMorgan Trust I
S000002916
JPMorgan Emerging Markets Debt Fund
2/28/2019
26
811-21295
JPMorgan Trust I
S000022994
JPMorgan Strategic Income Opportunities Fund
2/28/2019
27
811-21295
JPMorgan Trust I
S000022843
JPMorgan Total Return Fund
2/28/2019
28
811-21295
JPMorgan Trust I
S000030249
JPMorgan Unconstrained Debt Fund
2/28/2019
29
811-21295
JPMorgan Trust I
S000018749
JPMorgan High Yield Municipal Fund (formerly known as JPMorgan Tax Aware High Income Fund)
2/28/2019
30
811-04236
JPMorgan Trust II
S000003497
JPMorgan Municipal Income Fund
2/28/2019
31
811-04236
JPMorgan Trust II
S000003499
JPMorgan Short-Intermediate Municipal Bond Fund
2/28/2019
32
811-04236
JPMorgan Trust II
S000003500
JPMorgan Tax Free Bond Fund
2/28/2019
33
811-23117
JPMorgan Trust IV
S000052823
JPMorgan Ultra-Short Municipal Fund
2/28/2019
34
811-21295
JPMorgan Trust I
S000002969
JPMorgan Prime Money Market Fund
2/28/2019
35
811-23117
JPMorgan Trust IV
S000061245
JPMorgan Institutional Tax Free Money Market Fund
2/28/2019
36
811-23117
JPMorgan Trust IV
S000063113
JPMorgan Securities Lending Money Market Fund
2/28/2019
37
811-04236
JPMorgan Trust II
S000003905
JPMorgan Liquid Assets Money Market Fund
2/28/2019
38
811-04236
JPMorgan Trust II
S000003909
JPMorgan U.S. Government Money Market Fund
2/28/2019
39
811-04236
JPMorgan Trust II
S000003910
JPMorgan U.S. Treasury Plus Money Market Fund
2/28/2019
40
811-21295
JPMorgan Trust I
S000002967
JPMorgan Federal Money Market Fund
2/28/2019
41
811-21295
JPMorgan Trust I
S000002965
JPMorgan 100% U.S. Treasury Securities Money Market Fund
2/28/2019
42
811-21295
JPMorgan Trust I
S000002970
JPMorgan Tax Free Money Market Fund
2/28/2019
43
811-04236
JPMorgan Trust II
S000003906
JPMorgan Municipal Money Market Fund
2/28/2019
44
811-22575
J.P. Morgan Access Multi-Strategy Fund II
CEF0001490
J.P. Morgan Access Multi-Strategy Fund II
3/31/2019
45
811-21552
JP MORGAN ACCESS MULTI-STRATEGY FUND LLC
CEF0000997
JP MORGAN ACCESS MULTI-STRATEGY FUND LLC
3/31/2019