John Hancock Group of Funds
200 Berkeley Street
Boston, Massachusetts 02116
April 14, 2023
VIA EDGAR
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Mindy Rotter
Re: Closed End Fund
John Hancock GA Mortgage Trust Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended December 31, 2021; File No. 811-23418
Open End Funds
John Hancock Investment Trust Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended March 31, 2022; File No. 811-23418
John Hancock Funds II Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended July 31, 2022 and Form N-CSR Annual Reports to Shareholders ("Form N-CSR") August 31, 2022; File No. 811-00560 and 811-21779
Dear Ms. Rotter:
This letter responds to the comments of the Staff of the Securities and Exchange Commission ("SEC"), which were conveyed to us by telephone on March 24, 2023 with respect to the filings on Form N-CSR for the John Hancock Funds listed on Annex A, attached hereto. The Staff's comments are set forth below, each followed by the respective fund's response.
Open End Funds
1.Comment: For those funds that had exposure to derivatives during the last fiscal year end but did not discuss the effect of derivatives in Management's Discussion of Fund Performance (MDFP), please confirm that such usage did not have a material impact on performance or explain why the MDFP did not include a discussion regarding the derivative usage (Count # from Annex A - 3, 4, 8, 9, 15, and 21).
•3 – John Hancock Funds II Emerging Markets Debt Fund
•4 - John Hancock Funds II Emerging Markets Fund
•8 - John Hancock Funds II International Small Company Fund
•9 - John Hancock Funds II Multi-Asset High Income Fund
•15 - John Hancock Funds II Floating Rate Income Fund
•21 - John Hancock Funds II High Yield Fund
Securities and Exchange Commission
April 14, 2023
Page 2 of 7
Response: We confirm that derivatives usage for the identified funds did not have a material impact on performance.
2.Comment: The performance graph for John Hancock GA Mortgage Trust begins 1/14/2019, the total returns chart, Financial Highlights, and report of Independent Registered Accounting Firm report has 1/11/2019.
Response: This was a typographical error in the performance graph, and it was corrected in the most recent annual report as of 12/31/2022 filed on March 7, 2023. The fund's performance figures were not impacted as a result of this date revision.
3.Comment: Portfolio objective noted in the prospectus versus the disclosure in the MDFP is not consistent for the John Hancock Fund II Fundamental Global Franchise Fund, please explain the difference.
Response: Disclosure of investment objective on page 2 and within Organization note is consistent with the prospectus. Commentary within the MDFP is not a statement of the Fund's investment objective and policies but rather the view of the portfolio manager of the Fund's performance over the specified period. This does not and is not intended to reflect any change in the investment objective and policies of the Fund and the Fund is managed in accordance with these.
4.Comment: John Hancock Funds II Emerging Market Debt Fund has been identified in the annual report as a non-diversified fund; however it appears the fund is operating as a diversified fund. If fund has been operation as diversified for more than three years, please confirm that the fund will receive shareholder approval prior to changing its status back to non-diversified.
Response: We confirm the John Hancock Funds II Emerging Markets Debt Fund is a non-diversified fund. The fund has not operated as a diversified fund for more than three years.
5.Comment: The Staff was unable to find any information about the John Hancock GA Mortgage Trust on the Registrants' website. Please explain in correspondence where a shareholder is able to review fund documents and fund information. If located on the website, please provide a direct link in response.
Response: The fund is only sold in private placements to qualified institutional investors. Therefore, the fund is not listed on advisor's website.
6.Comment: John Hancock Funds II Multi-Index Preservation Funds - Class I total returns in the performance chart do not agree to the total returns in the Financial Highlights, please explain the difference and consider including a note in the notes to the performance chart going forward.
Response: The Financial Highlights total return for Class I is presented since class inception (stub period) while total return figures in the performance table shows a full year utilizing the most similar class for the period before Class I opened (Class 1 in this instance) as disclosed in Footnote 1 "Class I shares were first offered on 10/21/21. Returns prior to this date are those of Class 1 shares that have not been adjusted for class-specific expenses; otherwise, returns would vary."
7.Comment: Average annual total returns as of 7/31/2022 for John Hancock Funds II Multi-Asset Absolute Return Fund (page 2 of report) uses a blended benchmark of 30% MSCI All Country World Index and 70% Bloomberg Global Aggregate Bond USD Hedged Index. The MDFP narrative notes that the fund declined modestly and underperformed the return of the primary benchmark (Intercontinental Exchange (ICE) Bank of America (BofA) 0-3 Month U.S. Treasury Bill Index). The total returns for the period 7/31/22 table and the performance graph include all three indices.Please explain the differences in the disclosure.
Response: The benchmark presented in the bar graph on page 2 is the fund's secondary benchmark. The MDFP discusses performance against the fund's primary benchmark, ICE Bank of America 0-3 Month U.S. Treasury Bill
Securities and Exchange Commission
April 14, 2023
Page 3 of 7
Index, and the performance tables and line graph present the fund's primary benchmark as well as the secondary benchmark for comparative purposes.
8.Comment: Please confirm current Form N-CSR will be used going forward, the most recent version of the form can be found on the SEC website which includes Item 4(i) and Item 4(j) that are required to be addressed whether the response is N/A. Applies across the fund complex. Form was updated in January 2022.
Response: We confirm and will use the updated form effective immediately for all future filings.
* * *
We hope that these foregoing responses adequately address the Staff's comments. If you have any questions, please do not hesitate to contact me at (617) 543-9634.
Sincerely,
/s/ Salvatore Schiavone Salvatore Schiavone Treasurer
John Hancock Group of Funds
Securities and Exchange Commission
April 14, 2023
Page 4 of 7
Annex A
Count | Series ID | FYE | File # | Series Name | Registrant Name |
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1 | S000023552 | 8/31/2022 | 811-21779 | Alternative Asset Allocation Fund | John Hancock Funds II |
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2 | S000003311 | 8/31/2022 | 811-21779 | Blue Chip Growth Fund | John Hancock Funds II |
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3 | S000027304 | 8/31/2022 | 811-21779 | Emerging Markets Debt Fund | John Hancock Funds II |
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4 | S000017260 | 8/31/2022 | 811-21779 | Emerging Markets Fund | John Hancock Funds II |
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5 | S000003317 | 8/31/2022 | 811-21779 | Equity Income Fund | John Hancock Funds II |
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6 | S000037602 | 8/31/2022 | 811-21779 | Fundamental Global Franchise | John Hancock Funds II |
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7 | S000040959 | 8/31/2022 | 811-21779 | Global Equity Fund | John Hancock Funds II |
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8 | S000009779 | 8/31/2022 | 811-21779 | International Small Company | John Hancock Funds II |
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| Fund |
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9 | S000045160 | 8/31/2022 | 811-21779 | Multi-Asset High Income Fund | John Hancock Funds II |
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10 | S000003360 | 8/31/2022 | 811-21779 | New Opportunities Fund | John Hancock Funds II |
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11 | S000003356 | 8/31/2022 | 811-21779 | Real Estate Securities Fund | John Hancock Funds II |
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12 | S000003363 | 8/31/2022 | 811-21779 | Small Cap Growth Fund | John Hancock Funds II |
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13 | S000009819 | 8/31/2022 | 811-21779 | Small Cap Value Fund | John Hancock Funds II |
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14 | S000009820 | 8/31/2022 | 811-21779 | Strategic Income Opportunities | John Hancock Funds II |
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15 | S000020234 | 8/31/2022 | 811-21779 | Floating Rate Income Fund | John Hancock Funds II |
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16 | S000003319 | 8/31/2022 | 811-21779 | Opportunistic Fixed Income Fund | John Hancock Funds II |
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17 | S000003312 | 8/31/2022 | 811-21779 | Capital Appreciation Fund | John Hancock Funds II |
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18 | S000030799 | 8/31/2022 | 811-21779 | Capital Appreciation Value Fund | John Hancock Funds II |
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19 | S000003313 | 8/31/2022 | 811-21779 | Core Bond Fund | John Hancock Funds II |
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20 | S000034046 | 8/31/2022 | 811-21779 | Health Sciences Fund | John Hancock Funds II |
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Securities and Exchange Commission
April 14, 2023
Page 5 of 7
21 | S000003320 | 8/31/2022 | 811-21779 | High Yield Fund | John Hancock Funds II |
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22 | S000055170 | 8/31/2022 | 811-21779 | International Strategic Equity | John Hancock Funds II |
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| Allocation Fund |
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23 | S000024677 | 8/31/2022 | 811-21779 | Mid Value Fund | John Hancock Funds II |
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24 | S000009815 | 8/31/2022 | 811-21779 | Science & Technology Fund | John Hancock Funds II |
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25 | S000055171 | 8/31/2022 | 811-21779 | U.S. Sector Rotation Fund | John Hancock Funds II |
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26 | S000069425 | 8/31/2022 | 811-21779 | Multimanager 2065 Lifetime | John Hancock Funds II |
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27 | S000053254 | 8/31/2022 | 811-21779 | Multimanager 2060 Lifetime | John Hancock Funds II |
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| Portfolio |
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28 | S000044502 | 8/31/2022 | 811-21779 | Multimanager 2055 Lifetime | John Hancock Funds II |
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| Portfolio |
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29 | S000013659 | 8/31/2022 | 811-21779 | Multimanager 2050 Lifetime | John Hancock Funds II |
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| Portfolio |
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30 | S000013658 | 8/31/2022 | 811-21779 | Multimanager 2045 Lifetime | John Hancock Funds II |
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| Portfolio |
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31 | S000013657 | 8/31/2022 | 811-21779 | Multimanager 2040 Lifetime | John Hancock Funds II |
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| Portfolio |
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32 | S000013656 | 8/31/2022 | 811-21779 | Multimanager 2035 Lifetime | John Hancock Funds II |
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| Portfolio |
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33 | S000013655 | 8/31/2022 | 811-21779 | Multimanager 2030 Lifetime | John Hancock Funds II |
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34 | S000013654 | 8/31/2022 | 811-21779 | Multimanager 2025 Lifetime | John Hancock Funds II |
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| Portfolio |
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35 | S000013653 | 8/31/2022 | 811-21779 | Multimanager 2020 Lifetime | John Hancock Funds II |
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| Portfolio |
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36 | S000013652 | 8/31/2022 | 811-21779 | Multimanager 2015 Lifetime | John Hancock Funds II |
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| Portfolio |
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37 | S000013649 | 8/31/2022 | 811-21779 | Multimanager 2010 Lifetime | John Hancock Funds II |
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| Portfolio |
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38 | S000069424 | 8/31/2022 | 811-21779 | Multi-Index 2065 Preservation | John Hancock Funds II |
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| Portfolio |
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39 | S000053253 | 8/31/2022 | 811-21779 | Multi-Index 2060 Preservation | John Hancock Funds II |
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| Portfolio |
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40 | S000044501 | 8/31/2022 | 811-21779 | Multi-Index 2055 Preservation | John Hancock Funds II |
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Securities and Exchange Commission
April 14, 2023
Page 6 of 7
41 | S000028818 | 8/31/2022 | 811-21779 | Multi-Index 2050 Preservation | John Hancock Funds II |
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| Portfolio |
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42 | S000028817 | 8/31/2022 | 811-21779 | Multi-Index 2045 Preservation | John Hancock Funds II |
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| Portfolio |
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43 | S000028826 | 8/31/2022 | 811-21779 | Multi-Index 2040 Preservation | John Hancock Funds II |
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| Portfolio |
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44 | S000028825 | 8/31/2022 | 811-21779 | Multi-Index 2035 Preservation | John Hancock Funds II |
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| Portfolio |
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45 | S000028824 | 8/31/2022 | 811-21779 | Multi-Index 2030 Preservation | John Hancock Funds II |
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| Portfolio |
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46 | S000028823 | 8/31/2022 | 811-21779 | Multi-Index 2025 Preservation | John Hancock Funds II |
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| Portfolio |
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47 | S000028821 | 8/31/2022 | 811-21779 | Multi-Index Income Preservation | John Hancock Funds II |
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| Portfolio |
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48 | S000069423 | 8/31/2022 | 811-21779 | Multi-Index 2065 Lifetime | John Hancock Funds II |
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| Portfolio |
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49 | S000053255 | 8/31/2022 | 811-21779 | Multi-Index 2060 Lifetime | John Hancock Funds II |
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50 | S000044503 | 8/31/2022 | 811-21779 | Multi-Index 2055 Lifetime | John Hancock Funds II |
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51 | S000042855 | 8/31/2022 | 811-21779 | Multi-Index 2050 Lifetime | John Hancock Funds II |
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52 | S000042854 | 8/31/2022 | 811-21779 | Multi-Index 2045 Lifetime | John Hancock Funds II |
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53 | S000042853 | 8/31/2022 | 811-21779 | Multi-Index 2040 Lifetime | John Hancock Funds II |
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54 | S000042852 | 8/31/2022 | 811-21779 | Multi-Index 2035 Lifetime | John Hancock Funds II |
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55 | S000042851 | 8/31/2022 | 811-21779 | Multi-Index 2030 Lifetime | John Hancock Funds II |
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| Portfolio |
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56 | S000042850 | 8/31/2022 | 811-21779 | Multi-Index 2025 Lifetime | John Hancock Funds II |
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57 | S000042849 | 8/31/2022 | 811-21779 | Multi-Index 2020 Lifetime | John Hancock Funds II |
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58 | S000042848 | 8/31/2022 | 811-21779 | Multi-Index 2015 Lifetime | John Hancock Funds II |
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59 | S000042847 | 8/31/2022 | 811-21779 | Multi-Index 2010 Lifetime | John Hancock Funds II |
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60 | S000043433 | 8/31/2022 | 811-21779 | Multi-Index Lifestyle Aggressive | John Hancock Funds II |
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Securities and Exchange Commission
April 14, 2023
Page 7 of 7
61 | S000043436 | 8/31/2022 | 811-21779 | Multi-Index Lifestyle Growth | John Hancock Funds II |
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62 | S000043434 | 8/31/2022 | 811-21779 | Multi-Index Lifestyle Balanced | John Hancock Funds II |
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63 | S000043437 | 8/31/2022 | 811-21779 | Multi-Index Lifestyle Moderate | John Hancock Funds II |
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64 | S000043435 | 8/31/2022 | 811-21779 | Multi-Index Lifestyle | John Hancock Funds II |
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| Conservative Portfolio |
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65 | S000029556 | 7/31/2022 | 811-21779 | Absolute Return Currency Fund | John Hancock Funds II |
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66 | S000032685 | 7/31/2022 | 811-21779 | Fundamental All Cap Core Fund | John Hancock Funds II |
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67 | S000035066 | 7/31/2022 | 811-21779 | Multi-Asset Absolute Return | John Hancock Funds II |
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68 | S000061352 | 3/31/2022 | 811-00560 | John Hancock Diversified Real | John Hancock Investment Trust |
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69 | S000072133 | 3/31/2022 | 811-00560 | John Hancock Mid Cap Growth | John Hancock Investment Trust |
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70 | CEF0010705 | 12/31/2021 | 811-23418 | John Hancock GA Mortgage Trust | John Hancock GA Mortgage Trust |
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