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,

Schedule A