Item 8.01 Other Events.

On October 23, 2008, the Human Resources and Compensation Committee ("the Committee") of the J. C. Penney Company, Inc. (the "Company") Board of Directors adopted the Company's Executive Severance Arrangements Policy (the "Policy"). The Policy provides that the Company will not enter into a future severance agreement with a senior executive that provides for severance benefits in an amount exceeding 2.99 times the sum of the senior executive's annual base salary as in effect immediately prior to the date of the senior executive's termination of employment and target bonus for the fiscal year in which the termination of employment occurs unless such agreement receives approval of the stockholders of the Company. The Policy applies only to future severance agreements. Future severance agreements do not include existing severance agreements unless the severance agreement is materially modified. The Board of Directors retains the right to amend the Policy and will promptly disclose any amendment.

The foregoing description of the Policy is a summary and is qualified in its entirety by reference to the full text of the Policy. A copy of the Policy is furnished herewith as Exhibit 99.1.

Item 9.01 Financial Statements and Exhibits.

(d) Exhibit 99.1 J. C. Penney Company, Inc. Executive Severance Arrangements Policy adopted October 23, 2008