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Six Circles Trust

 March 13, 2020

 VIA EDGAR

 Ms. Elena Stojic

 Attorney Adviser

 Securities and Exchange Commission

Division of Investment Management

 100 F Street, NE

Washington, D.C. 20549

Re:    Six Circles Trust

Post-Effective Amendment No. 14 to Registration Statement on Form N-1A filed on December 20,
2019 (File Nos. 333-225588, 811-23325) (the “Registration Statement”)

Dear Ms. Stojic:

 On behalf of Six Circles
Trust (the “Registrant”), we are submitting this letter to respond to comments received from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) regarding the Registration
Statement. The Staff’s comments were conveyed to the Registrant telephonically on February 10, 2020. Below are the Staff’s comments and the Registrant’s responses thereto. Where revisions to the Registration Statement are
referenced in the Registrant’s responses, such revisions will be included in Post-Effective Amendment No. 16 (the “Amendment”), which the Registrant intends to file on or about the date hereof.

SIX CIRCLES GLOBAL BOND FUND

1.
 Please submit completed fee table and expense example.

Response: The Registration Statement has been revised accordingly to include the fee table and expense example set forth below.

 ANNUAL FUND
OPERATING EXPENSES

 (Expenses that you pay each year as a
percentage of the

 value of your
investment)

 Management Fees1,2

0.25%

 Distribution (Rule
12b-1) Fees

NONE

 Other Expenses3

                0.11%

 Total Annual Fund Operating Expenses

0.36%

 Fee Waivers and Expense Reimbursements1,2

(0.17%)

Total Annual Fund Operating Expenses After Fee Waivers and Expense
Reimbursement1,2

0.19%

1
 The Fund’s adviser, J.P. Morgan Private Investments Inc. (“JPMPI”) and/or its affiliates have
contractually agreed through at least 04/30/2021 to waive any management fees that exceed the aggregate management fees the adviser is contractually required to pay the Fund’s sub-advisers. Thereafter,
this waiver will continue for subsequent one year terms unless terminated in accordance with its terms. JPMPI may terminate the waiver, under its terms, effective upon the end of the then-current term, by providing at least ninety (90) days
prior written notice to the Six Circles Trust. The waiver may not otherwise be terminated by JPMPI without the consent of the Board of Trustees of the Six Circles Trust, which consent will not be unreasonably withheld. Such waivers are not subject
to reimbursement by the Fund.

2
 Additionally, the Fund’s adviser has contractually agreed through at least 04/30/2021 to reimburse expenses to the
extent Total Annual Fund Operating Expenses (excluding acquired fund fees and expenses, if any, dividend and interest expenses related to short sales, brokerage fees, interest on borrowings, taxes, expenses related to litigation and potential
litigation, and extraordinary expenses) exceed 0.40% of the average daily net assets of the Fund (the “Expense Cap”). An expense reimbursement by the Fund’s adviser is subject to repayment by the Fund only to the extent it can be made
within thirty-six months following the date of such reimbursement by the adviser. Repayment must be limited to amounts that would not cause the Fund’s operating expenses (taking into account any
reimbursements by the adviser and repayments by the Fund) to exceed the Expense Cap in effect at the time of the reimbursement by the adviser or at the time of repayment by the Fund. This expense reimbursement is in effect through 04/30/2021, at
which time the adviser and/or its affiliates will determine whether to renew or revise it.

3
 “Other Expenses” are based on estimated amounts for the current fiscal year.

 1

 This Example is intended to help you compare the cost of investing in the Fund with the cost of investing in other mutual
funds. The Example assumes that you invest $10,000 in the Fund for the time periods indicated. The Example also assumes that your investment has a 5% return each year and that the Fund’s operating expenses are equal to the total annual fund
operating expenses after fee waivers and expense reimbursements shown in the fee table through 04/30/2021 and total annual fund operating expenses thereafter. Your actual costs may be higher or lower.

WHETHER OR NOT YOU SELL YOUR SHARES,

YOUR COST WOULD BE:

            1 Year

            3 Years

 SHARES
($)

19

98

2.
   In footnote 2 to the fee table, please confirm that the expense reimbursement will be in
effect for no less than one year from the Fund’s effective date.

   Response:
  Confirmed.

3.
   As the word “global” is included in the name of the Fund, please expressly describe
how the Fund will invest its assets in companies that are economically tied to a number of countries throughout the world. For example, the Fund could include a policy that under normal market conditions it would invest significantly (e.g. 40% of
its assets), unless market conditions were not favorable, in which case the Fund would invest 30% of its assets, in companies organized or located in multiple countries outside the United States or doing a substantial amount of business in multiple
countries outside the United States. (See IC Rel. No. 24828, January 17, 2001.) Additionally, please revise the strategy of the Fund to indicate that the Fund will invest significantly (e.g., 40%) in multiple non-U.S. companies and countries, and specify how the Fund defines “non-U.S. investments.” Statements like “the majority of investments will be made in non-U.S. companies,” or “the Fund will invest primarily in non-U.S. companies” are also acceptable.

Response:   The Registration Statement has been revised to include the disclosure set forth below regarding
how the Fund defines “non-U.S. investments”:

 “For purposes of the
Global Bond Fund’s investment policies, an issuer of a security can be deemed to be located in a particular country if: (i) the relevant security is issued in such country; (ii) the principal trading market for the relevant security
is in such country; (iii) the issuer is organized under the laws of such country; (iv) the issuer derives at least 50% of its revenues or profits from such country or has at least 50% of its total assets situated in such country; or
(v) the issuer is the government of such country (or any political subdivision, agency, authority or instrumentality of such government or country).”

The Registrant, however, respectfully submits that its current description of its geographic investment policy as a
“global” fund is consistent with SEC guidance and widespread industry practice. With respect to SEC guidance, footnote 42 to the adopting release for Rule 35d-1 under the Investment Company Act
clarifies that the use of the term “international” or “global” in a fund’s name does not trigger the 80% test of the rule. Nonetheless, the release states that “[the Commission] would expect … that investment
companies using these terms in their names will invest their assets in investments that are tied economically to a number of countries throughout the world.” In the past, the Commission and the Staff have distinguished “global”
investment companies by suggesting that an investment company with “global” in its name

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invest in securities of issuers in at least three different countries (which may include the United States).1 The Registrant notes that the
absence, in the adopting release for Rule 35d-1, of a specific, minimum number of countries in which such a fund must invest is consistent with the Commission’s view in the proposing release for Rule 35d-1 that “the number of countries in which an ‘international’ or ‘global’ investment company may invest at any one time may appropriately differ from company to company.”

As such, Registrant’s policy of investing, under normal circumstances, in a number of different countries around the
world, with the portfolio as a whole economically tired to at least three countries, including the United States, is consistent with prior SEC guidance. Further, in terms of industry practice, numerous other global funds disclose similar geographic
investment policies.2

 Nevertheless, to alleviate any question in
this regard, the Registrant has amended its policy to provide that the Fund will invest “in a number of different countries around the world, with the portfolio as a whole economically tied to at least three four countries, including the United
States.”

 Principal Investment Strategies

4.
   Please provide plain English descriptions of the terms “stripped MBS” and
“mortgage pass-through securities.”

 Response: The Registration Statement has been
revised to include the disclosure below:

 “As part of this investment strategy, the Fund will invest in some or all
of the following: debt securities of corporate issuers, obligations of governments, government agencies or instrumentalities, including U.S. Treasury securities (including Separate Trading of Registered Interest and Principal of Securities
(“STRIPS”)), securities issued or guaranteed by the U.S. government or its agencies and instrumentalities, securities issued or guaranteed by supranational organizations, securities issued or guaranteed by foreign governments,
asset-backed, mortgage-related and mortgage-backed securities (“MBS”) (residential or commercial) (and which may include “to be announced” (“TBA”) transactions), and other debt securities. Mortgage-related and MBS may
be structured as collateralized mortgage obligations (“CMOs”) (agency and non-agency), stripped MBS (mortgage securities split into
interest-only and principal-only securities), commercial mortgage-

 1 See Letter to Registrants from Carolyn B. Lewis, Assistant Director, Division of Investment Management, SEC (Jan. 3, 1991) at II.A (rescinded without comment by Registration Form Used by Open-End Management Investment Companies, Investment Company Act Rel. No. 23064 (Mar. 13, 1998) (“Release No. 23064”)).

2 See Harbor Robeco Global Conservative Equities Fund (“Under normal market conditions, the
Fund expects to invest in at least three countries, including the United States.”); Templeton Global Bond Fund (“In addition, the Fund’s assets are invested in issuers located in at least three countries (including the U.S.).”);
BNY Mellon Global Equity Income Fund (“The fund ordinarily invests in at least three countries, and, at times, may invest a substantial portion of its assets in a single country.”); Goldman Sachs Global Managed Beta Fund (“The Fund
intends to have investments economically tied to at least three countries, including the United States, and may invest in the securities of issuers in emerging market countries.”); Goldman Sachs Global Real Estate Securities Fund (“The
Fund will invest in securities of real estate industry companies that are economically tied to at least three countries, including the United States.”); and Goldman Sachs Global Infrastructure Fund (“The Fund will invest in the securities
of infrastructure companies that are economically tied to at least three countries, including the United States.”).

 3

backed securities (“CMBS”), or mortgage pass-through securities (interests in securities representing pools of
mortgages).”

5.
   Please clarify what the term “other pooled investment vehicles” means, and if it
includes private funds. If private funds would be included, such investments must be limited to no more than 15% of the assets of the Fund.

Response: The Registration Statement has been revised to include the disclosure below, which indicates that the Fund may invest in
private funds:

 “The Fund may also invest in other investment companies, such as
open-end, closed-end and exchange-traded funds, and other pooled investment vehicles, which may include
private funds.”

 The Registrant does not intend to invest more than 15% of its assets in private funds.

6.
   The principal strategy section includes the following sentence: “The Fund has flexibility
to invest in derivatives and may use such instruments to manage duration, credit quality and currency risk and/or as substitutes for securities and other instruments in which the Fund can invest.” Please indicate what specific derivatives will
primarily be used by the Fund and confirm that it is an exhaustive list of such derivatives. (See Barry Miller, Letter to ICI, July 30, 2010.)

Response: The Registrant has revised the following disclosure in the principal strategy section to indicate the specific derivatives
the Fund expects primarily to use:

 “The Fund may
also use futures
contracts, swaps, options, and
forward contracts, foreign exchange instruments (spot and forward), and options (including options on swaps),
and structured notes, as well as repurchase agreements and
reverse repurchase agreements, in connection with its principal strategies in certain market conditions in order to hedge various investments, for risk management purposes
and/or, as a substitute for securities and other instruments in which the Fund can invest
or to increase income or gain to the Fund. The Fund may also use currency-related transactions involving currency derivatives as part of its investment strategy to hedge
currency risk.”

 The Registrant confirms that this is a list of the derivatives that the Fund
expects primarily to use as part of its principal investment strategy.

7.
   Please revise the discussion of the Fund’s strategy to indicate which indexes or sub-indexes the Adviser or Sub-Advisers intend to use as a benchmark.

Response: The Registrant notes that the Adviser actively changes the indexes and sub-indexes
assigned to Sub-Advisers, in order to implement the Adviser’s investment views. As the indexes and sub-indexes assigned to
Sub-Advisers are expected to change regularly, the Registrant respectfully submits that it would not be meaningful to investors to specify any particular index in the Registration Statement. The Registration
Statement has been revised to provide more information regarding the Adviser’s use of indexes to manage the Fund, as shown below:

“For a portion of the Fund portfolio, one Sub-Adviser will seek to replicate and
enhance the performance of certain fixed income exposures using the indices or sub-

 4

indices (“Index”) selected from time to time by the Adviser to express its current investment views. Generally, an Index will represent a certain sector component or geographic component of a public global bond index, such as government,
credit, or securitized, across varying geographies and regions including, among others, the US, Pan-Europe and Asia Pacific. For the remainder of the Fund portfolio, one or more
Sub-Advisers will actively manage components of the portfolio using investment strategies targeting risk profiles and investment exposures across the global government, global corporate, and global securitized
fixed income universe, as allocated by the Adviser.

 In allocating the assets of the Fund, the Adviser generally makes
strategic and tactical allocation decisions by directing shifts in allocations among the various investment strategies represented by Sub-Advisers
(including the indexes they have been directed to replicate and enhance). The Adviser will periodically review and determine the
allocations among the investment strategies and may make changes to these allocations when it believes it is beneficial to the Fund. The Adviser may, in its discretion, add to, delete from or modify the categories of investment strategies employed
by the Fund at any time, or add other investment strategies, including active strategies, managed by the Sub-Advisers at any time. In making allocations among such investment strategies and/or in changing the
categories of indexed investment strategies and other investment strategies employed by the Fund, the Adviser expects to take into account the investment goals of the broader investment programs administered by the