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CORRESP
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CORRESP

 Simpson Thacher & Bartlett LLP

900 G STREET, NW

WASHINGTON, D.C. 20001

TELEPHONE:
+1-202-636-5500

 Direct Dial Number

(202) 636-5916

 E-mail Address

matthew.micklavzina@stblaw.com

 December 22, 2022

Via EDGAR

 Securities
and Exchange Commission

 Division of Investment Management

100 F Street, N.E.

 Washington,
D.C. 20549

 Attn: Raymond A. Be, Attorney-Adviser

Re:         JPMorgan Private Markets Fund

              Draft Registration Statement on Form N-2

              Filing Nos.: 333-267866, 811-23832

 Ladies and Gentlemen:

On behalf of JPMorgan Private Markets Fund (the “Fund”), we hereby file with the staff (the “Staff”) of the
Division of Investment Management of the Securities and Exchange Commission (the “Commission”) the first pre-effective amendment to the draft registration statement on Form N-2 (the “Registration Statement”) under the Securities Act of 1933, as amended (the “1933 Act”) and the Investment Company Act of 1940, as amended (the “1940 Act”). The Registration
Statement includes revisions in response to the Staff’s comments received by email on November 14, 2022 relating to the Registration Statement and revisions to otherwise update disclosure.

For convenience of reference, the Staff’s comments have been reproduced herein. All capitalized terms used but not
defined in this letter have the meanings given to them in the Registration Statement. Where the Fund has revised disclosure in the Registration Statement in response to a comment, additions are underlined and deletions are
struck.

 GENERAL COMMENTS

 1.

 Staff Comment: We note that the Registration Statement is missing information and exhibits and
contains numerous sections that indicate that they will be added, completed or updated by amendment. Please expect comments on such portions when you add, complete or update them in any pre-effective
amendment, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits filed in any pre-effective amendment. Please plan accordingly.

Response: The Fund respectfully acknowledges the Staff’s comment.

 2.

 Staff Comment: Where a comment is made with regard to disclosure in one location, it is applicable to
all similar disclosure appearing elsewhere in the Registration Statement. Please make all conforming changes.

Response: The Fund has made applicable conforming changes.

 3.

 Staff Comment: We note that the Registration Statement discloses a number of requests for exemptive
relief (e.g., multi-class and co-investment relief). Please advise us as to the status of each of the applications disclosed in the Registration Statement and whether you have submitted or expect to submit any
other exemptive applications or no-action requests in connection with the Registration Statement.

Response: The Fund filed an application for a co-investment exemptive order on
October 13, 2022, which is under review by the Staff. The Fund intends to file an application for a multi-class exemptive order in the near term.

 4.

 Staff Comment: Please tell us if you have presented or will present any “test the waters”
materials to potential investors in connection with this offering. If so, please provide us with copies of such materials.

Response: The Fund confirms that it does not currently intend to present any “test the waters” materials to
potential investors in connection with its offering of Shares but may rely on Rule 433 or Rule 482 to present information outside of “test the waters” materials. If, in the future, the Fund determines to present any “test the
waters” materials, it will provide the Staff with copies of those materials.

 PROSPECTUS

Cover Page

 5.

 Staff Comment: The disclosure in footnote 1 to the fee table indicates that the Fund may, in its sole
discretion, accept investments below the stated minimums. Please confirm supplementally that the absolute minimum investment (after waiver of the disclosed minimum investment) will be $25,000. Please explain the circumstances investors subscribing
through a broker/dealer or registered investment adviser may

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have shares aggregated to meet the minimums. Please explain the reference to “vehicles controlled by such employees” on page 13. Also, clarify all of the situations in which the Fund
“in its sole discretion” may waive this minimum (i.e., state whether aggregating related accounts is the only scenario in which the minimum will be waived, and if not, disclose the other scenarios). In addition, please confirm
supplementally that the accredited investor and qualified client criteria will still apply to all investors and will not be waived.

Response: The Fund has revised the disclosure as requested. See pages 85 and 86 of the amended Registration Statement.
The Fund supplementally confirms that the accredited investor and qualified client criteria will still apply to all investors and will not be waived.

 6.

 Staff Comment: If true, disclose that the Fund may pay distributions in significant part from sources
that may not be available in the future and that are unrelated to the Fund’s performance, such as from offering proceeds, borrowings, and amounts from the Fund’s affiliates that are subject to
re-payment by investors.

 Response: The Fund has added the
following disclosure to the bullet points on the cover page:

 •

 The Fund may pay distributions in significant part from sources that may not be available in the future and
that are unrelated to the Fund’s performance, such as the sale of assets, borrowings, return of capital, offering proceeds or from temporary waivers or expense reimbursements borne by the Adviser or its affiliates that may be subject to
reimbursement to the Adviser or its affiliates.

 The Fund has also moved the following disclosure earlier
in the Prospectus, with additional disclosure as marked under the “Summary of Offering Terms—Distributions” section:

The Fund cannot guarantee that it will make distributions. The Fund may finance its cash distributions to
Shareholders from any sources of funds available to the Fund, including offering proceeds, borrowings, net investment income from operations, capital gains proceeds from the sale of assets (including fund investments),
non-capital gains proceeds from the sale of assets (including fund investments), dividends or other distributions paid to the Fund on account of preferred and common equity investments by the Fund in Portfolio
Funds and/or Co-Investments and expense reimbursements from the Adviser. The Fund has not established limits on the amount of funds the Fund may use from available sources to make distributions. The
repayment of any amounts owed to the Adviser or its affiliates will reduce future distributions to which you would otherwise be entitled.

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 7.

 Staff Comment: The disclosure states that the Distributor will distribute Fund shares on a best
efforts basis. Disclose if there is any minimum amount that must be purchased prior to commencement of operations and if there are arrangements to place funds received in escrow, trust or similar arrangement until then. If no arrangements have been
made, so state. See Instruction 5 to Item 1 of Form N-2. In addition, if a lack of significant Fund assets may contribute to your having a less diversified portfolio, less access to certain types of private
funds, or higher expense ratios, please ensure these matters are addressed in your disclosure.

Response: The Fund has revised Footnote 1 to the table required by Instruction 5 to Item 1 of Form N-2 as follows:

 [    ] (the
“Distributor”), an affiliate of the Adviser, acts as principal underwriter for the Fund’s Shares and serves in that capacity on a reasonable best efforts basis, subject to various conditions. The Distributor is not obligated to sell
any specific number of shares, nor have arrangements been made to place shareholders’ funds in escrow, trust, or similar arrangement. Class S Shares, Class D Shares and Class I Shares are or will be continuously offered at a
price per share equal to the NAV per share for such class. Each share class will initially be offered at $[                 ] per share. Generally, the stated minimum
investment by an investor in the Fund is $25,000 with respect to Class S Shares and Class D Shares and $1,000,000 with respect to Class I Shares. The stated minimum investment for Class I Shares may be reduced for certain
investors as described under “Purchasing Shares.” The minimum additional investment in the Fund is $10,000. The Fund may, in its sole discretion, accept investments below these minimums. Investors subscribing through a given broker/dealer
or registered investment adviser may have shares aggregated to meet these minimums, so long as initial investments are not less than $25,000 and incremental contributions are not less than $10,000.

The Fund respectfully submits that the Fund’s disclosure as written conveys the material risks noted above and
respectfully refers the staff to the disclosure located in “Lack of Operating History,” “Non-Diversified Status” and “Competition for Access to Private Equity Investment
Opportunities.”

 Fund Summary

Investment Objective and Strategy (page 1)

 8.

 Staff Comment: The disclosure indicates that the Fund will invest primarily in Secondary Investments,
Co-Investments, and Primary Investments. However, on page 3, the Fund’s 80% test includes Private Credit Investments. Briefly clarify the role of Private Credit Investments in the Fund’s strategy.
Revised disclosure should address how you obtain private credit exposures and evaluate such investments.

Response: The Fund’s principal investments strategies are to invest primarily in Secondary Investments, Co-Investments and Primary Investments. As a Fund that provides exposure to the private markets, the Fund’s 80% test under Rule 35d-1 also allows for investments in
Private Credit Investments. The Fund believes the inclusion of Private Credit Investments will be an important liquidity risk management tool that will allow the Fund to invest in tradable private market investments in the event it needs to include
its Liquid Assets in excess of the 20% bucket. The Fund has added disclosure regarding potential Private Credit Investment exposures and to clarify that Private Credit Investments includes investments in privately placed securities issued by public
companies. The Fund has added the following disclosure defining Private Credit Investments.

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 To manage portfolio liquidity, the Fund may also have exposure to privately
placed debt securities and other yield-oriented investments, including without limitation 144A securities, syndicated and other floating rate senior secured loans issued in private placements by U.S. and foreign corporations, partnerships and
other business entities, privately placed bank loans, restricted securities, and other securities and instruments issued in transactions exempt from the registration requirements of the Securities Act (“Private Credit Investments”).

 9.

 Staff Comment: The Prospectus indicates that the Fund may use leverage. Supplementally advise whether
the Fund intends to incur leverage during its first year of operations and, if so, include an estimate of the expected cost of leverage in the fee table.

Response: The Fund confirms that it may use leverage for investment purposes during its first year of operations. The
Fund intends to enter into a credit facility for purposes of managing cash flows, including subscriptions to the Fund and repurchases by the Fund. The Fund may also use the credit facility for investment purposes. In response to the Staff’s
comment, the Fund has included a caption for estimated costs of interest payments on borrowed funds in the fee table, consistent with the requirements of Item 3.1 of Form N-2 and has enhanced its strategy and
risk disclosure to reflect the Fund’s potential use of leverage for investment purposes.

 10.

 Staff Comment: The disclosure indicates that the Fund will “over-commit” to its
investments. Supplementally provide: (1) a representation that the Fund reasonably believes its assets will provide adequate cover to allow it to satisfy all of its unfunded investment commitments and (2) a general explanation as to why it
believes it can cover its commitments.

 Response: The Fund plans to rely on the exemption in Rule 18f-4(e) when entering into unfunded commitment agreements. The Fund reasonably believes that its assets will provide adequate cover to allow it to meet its obligations with respect to all of its unfunded investment
commitments, in each case as they come due, in accordance with the exemption in Rule 18f-4(e) under the 1940 Act. The Fund plans to manage its unfunded commitments such that it will have sufficient cash and
cash equivalents to meet its obligations at the time that an unfunded commitment agreement comes due. The Fund expects to meet these obligations through a combination of its liquid sleeve, a credit facility, maturing investments and, if necessary,
sales of investments that are not illiquid.

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 Purchasing Shares (page 14)

 11.

 Staff Comment: We note the disclosure that pending any closing funds received from prospective
investors will be placed in an account with the Transfer Agent. Please advise who will have control over the money during that period.

Response: The Fund confirms that any amounts held in escrow will comply with Rule
15c2-4 under the Securities Exchange Act of 1934, as amended.

 Repurchases of Shares (page
16)

 12.

 Staff Comment: The disclosure on page 17 states that under certain circumstances, the Board may offer
to repurchase shares at a discount to their prevailing net asset value. Please replace “Board” with “Fund” and describe the circumstances under which the Fund would offer to repurchase shares at a discount to their prevailing new
asset value. We may have more comments after reviewing your response.

 Response: The Fund has
changed “Board” to “Fund.” As the Fund has no present intent to offer to repurchase shares at a discount to net asset value, and the repurchase price is a function of the Board’s business judgment, the Fund respectfully
submits that disclosing specific circumstances when the Fund may offer to repurchase shares at a discount to net asset value at this time would be impracticable. The Fund believes that it cannot know the circumstances that it will be presented with
in the future that could result in the Fund determining to offer to repurchase shares at a discount to net asset value. The Fund notes that any such terms would be disclosed in the tender offer materials for such repurchase offer.

Incentive Fee (page 18)

 13.

 Staff Comment: Please enhance the disclosure to more fully explain the implications of the Loss
Recovery Account reset to investors (e.g., substantial losses in any particular year will not impact the Adviser’s ability to earn Incentive Fees in subsequent periods even if an investor’s overall returns are less than 10%).

 Response: The Fund has revised the disclosure as follows:

The Fund’s Loss Recovery Account’s reset mechanism could make it more likely that the Fund, and indirectly its
Shareholders, would incur an Incentive Fee payment as compared to another fund that is subject to an incentive fee that has a similar loss recovery account, but with no reset mechanism. This is because substantial losses in any particular year
would not affect the Adviser’s ability to earn an Incentive Fee in following periods even if an investor’s overall returns are negative. In addition, due to the Fund’s Loss Recovery Account reset mechanism, depending on when a
Shareholder invests in the Fund, there is a possibility that a Shareholder may indirectly bear Incentive Fee payments by the Fund without having experienced a gain in his or her investment.

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 Use of Proceeds (page 26)

 14.

 Staff Comment: Disclose how long