JPMORGAN INSTITUTIONAL TRUST
277 PARK AVENUE
NEW YORK, NEW YORK 10172
VIA EDGAR
October 24, 2019
Alison White
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: JPMorgan Institutional Trust; File No. 811-21638 Amendment No. 41
Dear Ms. White:
This letter is in response to the comment you provided with respect to Amendment No. 41 to the Registration Statement of the JPMorgan Institutional Trust (the Trust). Our response to your comment is set forth below. Capitalized terms used but not defined in this letter have the meanings given to them in the Trusts Registration Statement.
PROSPECTUS
1. | Comment: If consideration of environmental, social and governance (ESG) factors is not a part of either of JPMorgan Core Bond Trusts or JPMorgan Intermediate Bond Trusts (each, a Fund and together, the Funds) principal investment strategy, please advise whether the disclosure belongs in each Funds Risk/Return Summary section. If consideration of ESG factors is part of either Funds principal investment strategy, please explain whether ESG risk should be included as a principal or additional risk for the Fund. |
Response: The disclosure is appropriately included in the investment process description to summarize how the Funds adviser decides which securities to buy and sell in accordance with Item 9(b)(2) of Form N-1A. As indicated in the disclosure, the portfolio managers assess the impact of ESG factors on the cash flows of many companies in which they may invest. Such analysis is part of each Funds normal investment process and is integrated into the advisers research process, the risks of which are disclosed under the The Funds Main Investment Risks heading in the statement that each Fund is subject to management risk and may not achieve its objective if the advisers expectations regarding particular instruments or markets are not met. Additionally, the Funds do not believe that ESG risk is a principal or additional risk of the Funds. In contrast to funds where it may be appropriate to include ESG risk, these Funds do not seek to invest a certain percentage of their assets in companies that meet ESG goals (e.g., socially responsible companies) or screen out certain types of stocks or industries based solely on ESG factors (e.g.,
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tobacco companies). As a result, we do not believe that ESG should be considered as a principal risk of the Funds and that ESG disclosure should continue to be included in the investment process disclosure, as it provides information to shareholders as to how the adviser decides which securities to buy and sell.
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We hope that the Staff finds this letter responsive to the Staffs comment. Should members of the Staff have any questions or comments concerning this letter, please call me at (212) 270-6803.
Sincerely, |
/s/ Zachary Vonnegut-Gabovitch |
Zachary Vonnegut-Gabovitch |
Assistant Secretary |
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