SEC Company Response from JOHN HANCOCK LIFE INSURANCE CO (USA) SEPARATE ACCOUNT H (CIK 0000753892) — Sep 1, 2020
JOHN HANCOCK LIFE INSURANCE CO (USA) SEPARATE ACCOUNT H (CIK 0000753892)
Date: Sept. 1, 2020 · CIK: 0000753892 · Accession: 0001193125-20-236962
AI Filing Summary & Sentiment
File numbers found in text: 333-162245, 333-172473, 333-172476, 333-70728, 333-70850, 333-71072, 333-71074, 811-04113
Letter
VIA EDGAR Division of Investment Management Post-Effective Amendment No. 51 to the Registration Statement on Form N-4 of John Hancock Life Insurance Company (U.S.A.) Separate Account H File Nos. 333-70728, 811-04113
Re: Request for Template Filing Relief
Dear Ms. Magovern:
In accordance with Rule 485(b)(1)(vii) under the Securities Act of 1933, as amended (the “1933 Act”), John Hancock Life Insurance Company (U.S.A.) (“John Hancock”) respectfully requests template relief from the staff of the U.S. Securities and Exchange Commission with respect to Post-Effective Amendment No. 51 to the Registration Statement on Form N-4 of John Hancock Life Insurance Company (U.S.A.) Separate Account H (the “Registrant”) that was filed pursuant to Rule 485(a) on June 5, 2020 (the “Template Filing”). The Template Filing included a supplement that announces a limited offer to owners of certain variable annuity contracts, pursuant to which John Hancock would permit contract owners to voluntarily terminate their Income Plus For Life Series Riders and certain guaranteed death benefits (the “Offer Supplement”).
John Hancock proposes to use the Template Filing to include the Offer Supplement for the following post-effective amendments to be filed by the Registrant (the “Replicate Filings”). Because the Offer Supplement already covers each variable annuity contract to which the offer relates, John Hancock does not believe that any revisions to the Offer Supplement will be necessary for the Replicate Filings that are filed in reliance on the requested relief:
Replicate Filings
File Nos.
Relevant Contracts
(Contract Id Nos.)
Approximate Dates of
Filing and Effectiveness
Post-Effective Amendment No. 38
333-70850;
811-04113
Venture III (C000007846)
September 2, 2020
Post-Effective Amendment No. 37
333-71072;
811-04113
Vantage (C000007839)
September 2, 2020
Post-Effective Amendment No. 38
333-71074;
811-04113
Vision 2007 (C000043115)
Vis 25 (C000007837)
VV (C000007838)
September 2, 2020
Post-Effective Amendment No. 16
333-162245;
811-04113
Venture 4 (C000081726)
September 2, 2020
Post-Effective Amendment No. 11
333-172473;
811-04113
Venture 4 Series (C000100451)
September 2, 2020
Post-Effective Amendment No. 12
333-172476;
811-04113
Venture 7 Series (C000100454)
September 2, 2020
200 Berkeley Street, Boston, Massachusetts, United States, 02116
Andrea Ottomanelli Magovern, Assistant Director
September 1, 2020
Page 2
In connection with this request, John Hancock confirms that:
•
The disclosure changes in the Template Filing are substantially identical to the disclosure changes that will be made in the Replicate Filings; the Replicate Filings will be sufficiently identical to the Template Filing to make this request under Rule 485(b)(1)(vii) appropriate.
•
The Replicate Filings will incorporate changes made to the disclosure included in the Template Filing to resolve any SEC Staff comments thereon.
•
The Replicate Filings will not include any other changes that would otherwise render them ineligible for filing under Rule 485(b) under the 1933 Act.
* * * * *
We understand that the SEC Staff will respond orally to this request. Please direct your reply or any questions to me at 617-663-3192 or Sophia Pattas at 617-663-2332.
Very truly yours,
/s/ Thomas J. Loftus
Show Raw Text
CORRESP 1 filename1.htm Request for Template Filing Relief VIA EDGAR September 1, 2020 Andrea Ottomanelli Magovern, Assistant Director Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Request for Template Filing Relief Post-Effective Amendment No. 51 to the Registration Statement on Form N-4 of John Hancock Life Insurance Company (U.S.A.) Separate Account H File Nos. 333-70728, 811-04113 Dear Ms. Magovern: In accordance with Rule 485(b)(1)(vii) under the Securities Act of 1933, as amended (the “1933 Act”), John Hancock Life Insurance Company (U.S.A.) (“John Hancock”) respectfully requests template relief from the staff of the U.S. Securities and Exchange Commission with respect to Post-Effective Amendment No. 51 to the Registration Statement on Form N-4 of John Hancock Life Insurance Company (U.S.A.) Separate Account H (the “Registrant”) that was filed pursuant to Rule 485(a) on June 5, 2020 (the “Template Filing”). The Template Filing included a supplement that announces a limited offer to owners of certain variable annuity contracts, pursuant to which John Hancock would permit contract owners to voluntarily terminate their Income Plus For Life Series Riders and certain guaranteed death benefits (the “Offer Supplement”). John Hancock proposes to use the Template Filing to include the Offer Supplement for the following post-effective amendments to be filed by the Registrant (the “Replicate Filings”). Because the Offer Supplement already covers each variable annuity contract to which the offer relates, John Hancock does not believe that any revisions to the Offer Supplement will be necessary for the Replicate Filings that are filed in reliance on the requested relief: Replicate Filings File Nos. Relevant Contracts (Contract Id Nos.) Approximate Dates of Filing and Effectiveness Post-Effective Amendment No. 38 333-70850; 811-04113 Venture III (C000007846) September 2, 2020 Post-Effective Amendment No. 37 333-71072; 811-04113 Vantage (C000007839) September 2, 2020 Post-Effective Amendment No. 38 333-71074; 811-04113 Vision 2007 (C000043115) Vis 25 (C000007837) VV (C000007838) September 2, 2020 Post-Effective Amendment No. 16 333-162245; 811-04113 Venture 4 (C000081726) September 2, 2020 Post-Effective Amendment No. 11 333-172473; 811-04113 Venture 4 Series (C000100451) September 2, 2020 Post-Effective Amendment No. 12 333-172476; 811-04113 Venture 7 Series (C000100454) September 2, 2020 200 Berkeley Street, Boston, Massachusetts, United States, 02116 Andrea Ottomanelli Magovern, Assistant Director September 1, 2020 Page 2 In connection with this request, John Hancock confirms that: • The disclosure changes in the Template Filing are substantially identical to the disclosure changes that will be made in the Replicate Filings; the Replicate Filings will be sufficiently identical to the Template Filing to make this request under Rule 485(b)(1)(vii) appropriate. • The Replicate Filings will incorporate changes made to the disclosure included in the Template Filing to resolve any SEC Staff comments thereon. • The Replicate Filings will not include any other changes that would otherwise render them ineligible for filing under Rule 485(b) under the 1933 Act. * * * * * We understand that the SEC Staff will respond orally to this request. Please direct your reply or any questions to me at 617-663-3192 or Sophia Pattas at 617-663-2332. Very truly yours, /s/ Thomas J. Loftus Thomas J. Loftus AVP and Assistant Chief Counsel 617-663-3192 tloftus@jhancock.com 200 Berkeley Street, Boston, Massachusetts, United States, 02116