X0306 4 2016-07-14 0 0001166126 J C PENNEY CO INC JCP 0001219802 ULLMAN MYRON E III C/O J. C. PENNEY COMPANY, INC. 6501 LEGACY DRIVE PLANO TX 75024 1 1 0 0 Chairman of the Board Phantom Stock Units 2016-07-14 4 A 0 648.8366 8.57 A Common Stock 648.8366 94850.965 D Represents equivalent shares based on units of participation in the JCPenney stock fund credited to Mr. Ullman's account under the Company's Mirror Savings Plan. Each phantom stock unit entitles the reporting person to receive, on the applicable payment date, the cash value of one share of JCPenney common stock. *** Under continuing POA as filed with the S.E.C. *** /s/ David A. Shipley, attorney in fact 2016-07-15