SecProbe.io

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May 20, 2005

Mr. Tony Burak
U.S. Securities & Exchange Commission
450 5th Street, N.W.
Washington DC  20549

             RE: Response to Comments on the John Hancock Trust ("JHT") Form
             N-CSR filed for the year ended December 31, 2004 (the "Form
             N-CSR Filing")

Dear Mr. Burak:

Please find below our response to your comments on the Form N-CSR Filing as
provided to me via telephone on April 21, 2005.

--       Comment: On the Schedule of Investments, certain fixed income
         securities with the same interest rate were combined together with
         a maturity date range displayed. This occurred primarily in the
         Foreign Government Bond section of the Schedule of Investments.

--       Response: This presentation of foreign government bonds occurred
         in Income & Value Trust, Global Allocation Trust, High Yield
         Trust, Global Bond Trust and Diversified Bond Trust. The
         presentation of foreign government bonds for these portfolios and
         all Trust portfolios as applicable will be changed in all future
         filings so that these securities are no longer combined.

--       Comment: JHT has four master-feeder funds which invest exclusively
         in Class 2 shares of the American Growth Fund, American
         International Fund, American Blue Chip Income and Growth Fund and
         the American Growth-Income Fund, each of which are series of
         American Funds Insurance Series ("AFIS"). In the Statements of
         Changes for JHT, the JHT American Growth Trust, the JHT American
         International Trust and the JHT Growth-Income Trust disclosed
         "Distributions to Shareholders from Capital Gains" as capital gain
         distributions received from mutual funds. Is this caption correct
         as the corresponding American Funds Insurance Series master funds
         did not declare capital gains but only ordinary income?

--       Response: The caption disclosed on the JHT Statements of Changes
         for the JHT American Growth Trust, the JHT American International
         Trust and the JHT Growth-Income Trust was incorrect at December
         31, 2004. The disclosure should have stated "net realized short
         term gains on investments" as these amounts were the capital gains
         distributions declared by the JHT American Growth Trust, the JHT
         American International Trust and the JHT Growth-Income Trust. All
         future filings will reflect the correct disclosure.

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Mr. Tony Burak
U.S. Securities & Exchange Commission
Comments on the JHT Form N-CSR filed for the year ended December 31, 2004.
Page 2

--       Comment: As noted above, JHT has four master-feeder funds which
         invest exclusively in shares of AFIS funds. In accordance with the
         letter dated December 30, 1998 from Kenneth V. Domingues, Chief
         Accountant, to the Chief Financial Officers of registered
         investment companies, the Trust should include in its Form N-CSR
         Filing the Annual Report of the underlying master fund for each of
         these four master-feeder funds. Specifically, the AFIS Annual
         Report for the year ended December 31, 2004 should have been
         included in the JHT Form N-CSR filing.

--       Response: The AFIS Annual Report was included with the JHT annual
         report when it was mailed to JHT shareholders/contractowners and
         will be included in all future JHT Form N-CSR filings unless these
         four master-feeder funds cease to invest in AFIS funds.

         Comment:  Please provide a "Tandy Representation."

         JHT hereby makes the following representations to the Staff of the
         Securities and Exchange Commission (the "Commission"):

         JHT acknowledges that the adequacy and accuracy of the disclosure
         in the JHT Annual Report is the responsibility of JHT. JHT also
         acknowledges that Staff comments or changes in response to Staff
         comments in the disclosure in the JHT Annual Report do not
         foreclose the Commission from taking any action with respect to
         the Annual Report. JHT represents to the Commission that Staff
         comments may not be asserted as a defense in any proceeding
         initiated by the Commission or by any person under the federal
         securities laws of the United States.

Please do not hesitate to call me at 617 663-2168 or Greg D'Angelo at
617 663-2115 if we may answer any further questions.

Very truly yours,

Gordon M. Shone,
Chief Financial Officer
And Vice President of JHT

CC: Gregory D'Angelo,
Vice President, Fund Administration
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