March 9, 2006
VIA U.S. MAIL AND FACSIMILE

John Hoodlet
John Hancock Financial Services, Inc.
John Hancock Place
Post Office Box 111
Boston, MA 02117

      Re:	John Hancock Life Insurance Company of NY
      	Separate Account B
      	Initial Registration Statement on Form N-6
      File Nos. 333-131139 and 811-8329

Dear Ms. Hoodlet:

      The staff has reviewed the above-referenced registration
statement, which the Commission received on January 19, 2006.  Based
on your representation that the filing is substantially similar to
File Nos. 811-5130 and 333-126668 (effective October 12, 2005), the
registration statement received a selective review.  Based on this
review, we have the following comments on the registration statement:

1. General

Please note that if the filing is declared effective after March 31,
2006, you will need to update the financial statements and other
information to December 31, 2005.

2. Guide to this Prospectus

Please clarify that "the prospectuses for the underlying portfolios"
include the prospectuses of the American Fund Portfolios and the
corresponding master funds of the American Fund Insurance Series.

3. Summary of Benefits and Risks - Policy Loans

Please add a statement that policy loans may also result in adverse
tax consequences.



4. Summary of Benefits and Risks - Tax Risks

Similarly, please highlight the statement (either with italics or
bold lettering) that "[t]here is a tax risk associated with policy
loans."

5. The Policy Value

Please disclose whether transfers to more than one subaccount in a
given day will be treated as one or several transfers for the
purposes of the limitations on the number of free transfers.

6. Surrenders and Withdrawals

Please include the page number in your cross-reference to the
discussion on "Base Face Amount vs. Supplemental Face Amount."

7. Powers of Attorney

Rule 483(b) of the Securities Act of 1933 requires that the powers of
attorney "relate to a specific filing."  Please file new powers of
attorney that comply with the Rule.  Also, we are unable to locate
the powers of attorney filed herewith.  Please advise or revise.

8. Back Cover Page

Because the company has more than one policy issued through Separate
Account B, please disclose the 1933 Act file number for this policy
(333-131139) on this page.

9. Financial Statements, Exhibits, and Other Information

Financial statements, exhibits, and other required disclosure not
included in this registration statement must be filed in a pre-
effective amendment to the registration statement.

10. Tandy Comment

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require for an
informed decision.  Since the fund and its management are in
possession of all facts relating to the fund`s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they
have made.

Notwithstanding our comments, in the event the fund requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such request,
acknowledging that

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the fund from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and
* the fund may not assert this action as defense in any proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.

In addition, please be advised that the Division of Enforcement has
access to all information you provide to the staff of the Division of
Investment Management in connection with our review of your filing or
in response to our comments on your filing.

We will consider a written request for acceleration of the effective
date of the registration statement as a confirmation of the fact that
those requesting acceleration are aware of their respective
responsibilities.  We will act on the request and, pursuant to
delegated authority, grant acceleration of the effective date.
* * * ** * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
** * * * * * * * * * * * *
      Responses to these comments should be made in a letter to me
and in a pre-effective amendment to the registration statement.  If
you believe that you do not need to change the registration statement
in response to a comment, please explain your position in the letter.
      Although we have completed our initial review of the
registration statement, it will be reviewed further after our
comments are resolved.  Therefore, we reserve the right to comment
further on the registration statement and any amendments to it.
After we have resolved all issues, both the registrant and its
underwriter must request acceleration of the effective date of the
registration statement.
      If you have any questions, please phone me at (202) 551-6751.
My fax number is (202) 772-9285 and my email address is
Whitea@sec.gov.  Mail or deliveries should be addressed to 100 F
Street, NE, Washington DC 20549-4644.

      Sincerely,



      Alison White
      Senior Counsel
      Office of Insurance Products
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