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.
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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.
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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.
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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.
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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
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Schedule A |
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|
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 |