November 16, 2012
Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
Washington, D.C. 20549
Manulife Financial Corporation
Dear Mr. Rosenberg:
We have received your letter dated November 16, 2012, confirming the comment orally communicated to Lynda Sullivan, EVP and Controller on October 23, 2012 by Ms. Tabatha Akins via a phone conversation. As discussed by our U.S. counsel, Alan Paley of Debevoise & Plimpton LLP, with Ms. Akins this morning, we are reviewing your comment and we intend to submit a response as soon as practical. As Ms. Sullivan and others required to prepare our response will be in Asia next week, we respectfully request an extension for our response for 10 business days from today’s date, which would be December 3rd. I would appreciate it if you would confirm to me that this will be acceptable.
Sincerely,
/s/ Angela Shaffer
Vice President & Corporate Secretary
cc: Stephen Sigurdson
Manulife Financial Corporation
Alan Paley
Debevoise & Plimpton LLP
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