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JOHN HANCOCK LIFE INSURANCE CO (USA) SEPARATE ACCOUNT A

 October 20, 2023

Mr. Sonny Oh

 U.S. Securities and Exchange Commission

100 F Street NE

 Washington, DC 20549

Via EDGAR Correspondence Submission

Re:
 John Hancock Life Insurance Company (U.S.A.) Separate Account A Registration Statement Filed on
August 31, 2023, regarding Rule 485(a) Amendment Filings to Form N-6 for Certain Variable Universal Life Insurance Policies (the “Policies”)

Dear Mr. Oh:

 On behalf of John Hancock
Life Insurance Company (U.S.A.) (“John Hancock”) and its Separate Account A (811-4834), we are responding to the Commission staff comments that you provided on October 12, 2023 in connection
with the Defined Benefit Chronic Illness Rider (“DBCHR”) and Barclays Global MA Classic Indexed Account (the “Indexed Account”) supplements (each a “supplement”) filed by Rule 485(a) amendment to the respective Form N-6 Registration Statements.

 Sections of each supplement cited in our below recitations of the
Staff’s comments refer to the the marked courtesy copies on which the Staff based its comments. Additionally, changes made in the attached courtesy copies of the supplements will be made in every other supplement filed with each Policy, as
applicable.

 General Comments

 Staff Comment
1: On the cover page, make clear that the supplement is providing new information in addition to what is already provided in the May 2023 prospectus.

Response: We updated the advisory statement to clarify that the terms and disclosure in the prospectus not amended by the supplement are
unchanged and in effect.

 Staff Comment 2: Supplementally explain to the Staff what is being provided to existing and new policy owners
going forward.

 Response: The new Defined Benefit Chronic Illness Rider is available only for new policies and is not available post-issue.
Therefore, the DBCHR supplement will be available to potential owners with their prospectus prior to and at purchase. The new Barclays Global MA Classic Indexed Account is available for both new policies and existing policy owners. Therefore, it
will be available to new owners with their prospectus prior to or at point of sale and also delivered to existing policy owners when the indexed account is made available for investment. Both supplements will be incorporated into the 2024
prospectuses during the annual update process.

 Staff Comment 3: Supplementally explain to the Staff if John Hancock intends to file
another 485(a) or 485(b) supplement filing following the effective date of these supplements (October 30), what the procedural process for additional supplements would be, and if the changes made by these and other supplements will be incorporated
into the May 2024 prospectuses.

 Mr. Sonny Oh

October 20, 2023

 Page 2

 Response: As previously disclosed with the Staff, John Hancock will file a
subsequent 485(a) post-effective amendment to the registration statement for the Accumulation Variable Universal Life 2021 (“AVUL 2021”) (333-254210) in order to use a summary prospectus for its
variable life policies at its annual prospectus update in 2024. No other post-effective amendment to the variable life registration statements is currently contemplated prior to the annual update of the variable universal life policy prospectuses.
However, if one were to be filed and excluding the post-amendment to be filed for AVUL 2021, a subsequent supplement—under Rule 485 or 497—would be incorporated into the full, updated annual prospectus for 2024. Since the supplements are
comprehensive of new disclosure that may be added, we do not believe a subsequent filing would present an issue for new or current policy owners.

Staff Comment 4: In the introductory paragraph of each supplement, please state that the terms used in the supplement have the same meaning
defined in the prospectus. Also note that this information is in addition to what is already stated within the prospectus.

 Response: We
ensured that this advisory statement is included within the introductory paragraph of each supplement accordingly.

 Defined Benefit Chronic
Illness Rider Supplement Comments

 Staff Comment 5: Note that a cross-reference to the DBCHR will need to be included in the third column
of the Investments row of the Key Information Table, as applicable, when the disclosure is incorporated into the May 2024 prospectus.

Response: We confirm that we will include the appropriate cross-reference to the relevant prospectus sections when this disclosure is
incorporated into the 2024 prospectuses.

 Staff Comment 6: The headings in the middle and last column of the Fee Table disclosure
appear to be different than the column headings in the prospectus. Please change to match those found in the prospectus.

 Response: We
appreciate calling this to our attention and we have modified the headings accordingly.

 Staff Comment 7: Supplementally confirm
that the maximum charge for the DBCHR are consistent with the maximum charge in the Protection Variable Universal 23 (PVUL 23) prospectus.

Response: We confirm that the supplement is updated with the correct charges, which have been updated since the 485(a) filing. At the time the
rider was included in the PVUL 23 supplement, a conservative maximum was included as the offering price of the rider was not yet set and the rider was not immediately available. However, following offering experience, a more accurate maximum is
available and reflected in this supplement and the same price information will be updated in the PVUL 23 prospectus during the annual update process in 2024.

Staff Comment 8: Since this is a stand-alone supplement, please change the order of disclosure so that the “More About Certain Options
Benefits” section is moved to the beginning of the supplement since it explains the DBCHR, and move the FEE TABLE and OTHER BENEFITS AVAILABLE UNDER THE POLICY to just before the TAXES disclosure.

 Mr. Sonny Oh

October 20, 2023

 Page 3

 Response: We made the requested change with slight modification to keep
the OVERVIEW disclosure about adding the rider first, since it succinctly names the rider at the opening of the supplement.

 Barclays Global MA Classic
Indexed Account Supplement

 Staff Comment 9: The term “indexed account option” appears in the supplement but does not appear to
exist in the prospectus as used in the supplement. Additionally, the term “indexed account” needs to be amended in order to include the new Barclays indexed account along with the other indexed accounts available. Additionally, please make
“indexed account” lower case as it appears in the prospectus.

 Response: We removed reference to an “indexed account
option” and made the revised term “indexed account” lower case where it appears. We also modified the definition of “indexed account” in the GENERAL DESCRIPTION OF THE POLICY—The indexed accounts section to
include the new Barclays indexed account.

 Staff Comment 10: Please clarify in the introductory paragraph that this supplement is
available to both new and current policy owners in the first line of the supplement.

 Response: We made the requested modification.

Staff Comment 11: In the amended disclosure to the OVERVIEW OF THE POLICY—Premiums section, specify that the disclosure is being
added to the end of the fifth paragraph of this section.

 Response: We made the requested modification.

Staff Comment 12: The supplement does not address the allocation and lock-in process for the new indexed
account as it does in the GENERAL DESCRIPTION OF THE POLICY—The indexed accounts section of the prospectus. Add information regarding this process to the supplement.

Response: We included the paragraph in The indexed accounts subsection that discusses the lock-in
period, although a reiteration of what is included in the prospectus, because it is the same for the Barclays Global MA Classic Indexed Account.

Staff Comment 13: Clarify that the new section titled “The Barclays Global MA Index” is being included after—and not part
of—the section titled “The indexed accounts.”

 Response: We indicated in the supplement that this new subsection is a
standalone subsection.

 Staff Comment 14: Please supplementally explain the statement that “[b]ased on these allocation rules,
the sum of each component allocation may be as high as 150%” as stated in the third paragraph of The Barclays Global MA Index subsection. We would expect the maximum allocation to be 100%.

Response: The Barclays Global MA Index is used to determine interest credits to the policyholder and tracks a hypothetical diversified portfolio
of global financial assets by constructing a dynamic portfolio (the “Index Portfolio”). The Index Portfolio is determined using a composite of several underlying

 Mr. Sonny Oh

October 20, 2023

 Page 4

 components—identified in the supplement—with the goal to maximize return while
also maintaining a targeting volatility level using principles of modern portfolio theory. The combined weight of these components can be greater than or less than 100%. If the combined weight is equal to 100%, this means the hypothetical Index
Portfolio is fully allocated to the components. If the combined weight is less than 100%, the portion of the Index Portfolio which is not invested will not earn any return or carry any investment risk, similar to a cash position. If the combined
weight is greater than 100%, this means the hypothetical index portfolio reflects a leveraged position in the underlying components. A core principle of modern portfolio theory is that investors should identify an asset allocation along an efficient
frontier of risk and return and use leverage or cash to get to the desired level of risk.

 Staff Comment 15: Similarly, in the
following paragraph of the same subsection, add disclosure to explain what happens to the remaining amounts in the overall portfolio if the component exposure will be less than 100%.

Response: We added additional disclosure to succinctly state the meaning of a greater or less than 100% component portfolio exposure. See also
the Response to Staff Comment 14.

 Staff Comment 16: In the second sentence of the last paragraph of this subsection regarding “running
costs,” disclose what the “running costs” are and what it means to be “taken in to account” by the index. Clarify this disclosure to be more precise about what the charge is for and how it is accounted for.

Response: We revised this disclosure accordingly, with emphasis on clarifying the notional nature of the costs and how the costs are allocated.
We also separated this revised disclosure into its own paragraph for additional clarity.

 Staff Comment 17: In the new disclosure
for the Index Segment interest credit, we think that the entirety of the two bullets need to be added. These bullets should appear in the supplement and be tailored to the new Barclays indexed account.

Response: We included the two relevant bullet points with the disclosure modified to account for the Barclays indexed account.

Staff Comment 18: The table following the hypotheticals on page 21 of the AVUL 21 prospectus should be updated and included to account for the
new Barclays indexed account. Additionally, include the disclosure in the bullet points following the chart through the end of the relevant subsection.

Response: Following review of information conveyed in the table, we respectfully prefer to keep the disclosure
as-is, particularly for purposes of this supplement. We believe that there is adequate justification to exclude the table for this supplement. As a threshold matter, the referenced table and corresponding
bullets convey hypothetical information pertaining solely to the S&P index, which functions in a profoundly different manner than the Barclays Global MA Index. While the table in the AVUL 21 prospectus includes a basic point-to-point hypothetical segment index return in the S&P, the table would need to include additional parameters that would apply only to the Barclays indexed account,
namely a volatility percentage, component portfolio exposure assumptions (which would be a random selection), allocation percentages between components, and rebalancing frequency assumptions, among others. Even a basic
point-to-point return for the Barclays indexed account as listed in the table (-5%, 0%, 3%, 6%, 8%, and 12 to 0%) would require
significant additional information not pertinent to the S&P accounts. From a risk

 Mr. Sonny Oh

October 20, 2023

 Page 5

 perspective, we also believe that trying to fit all the indexed tables into this table
without providing the extensive assumption information would be potentially misleading. In short, the table is meant to convey performance of different indexed accounts that reference the same index. It is wholly unsuited to a comparison across
different indexes and the resulting table that tried to include the Barclays indexed account would be more confusing than helpful.

 However, we believe
that the annual update process will provide an opportunity to clarify that the information in the table pertains only to the S&P-linked indexed accounts, which is not easily done out-of-context in the supplement. We will look to make an update to the disclosure surrounding this table to better clarify what it does include (a direct comparison between
the S&P-linked indexed accounts) and what is excluded so that policy owners are not confused by the information when the Barclays indexed account is incorporated into the prospectus.

Staff Comment 19: In Part C, ensure that exhibits under N should be filed.

Response: We confirm that we will file the relevant exhibits by subsequent post-effective amendment.

We believe that the foregoing is responsive to the comments received to date on PVUL 2023. The changes reflected will be incorporated into the Registration
Statement via pre-effective amendment. If there are any questions or additional comments, please do not hesitate to reach me at
617-572-0070 or by email at mramirez@jhancock.com.

Thank you,

/s/ Michael A. Ramirez

Michael A. Ramirez

 JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.)

Separate Account A

 Supplement
Dated October 30, 2023

 Availability of Defined Benefit Chronic Illness Rider

This Supplement is to inform you that the Defined Benefit Chronic Illness Rider will be available for new policies issued on or after October 30, 2023,
subject to availability. It is intended for distribution with prospectuses dated May 1, 2023, as supplemented, for variable universal life insurance policies issued by John Hancock Life Insurance Company (U.S.A.) (each a
“Prospectus”). You should read this Supplement together with the Prospectus for your policy and retain both for future reference. This information is new
disclosure to your Prospectus, and except as modified by the supplement, all other terms and disclosure of the Prospectus remain in effect and unchanged. The affected Prospectuses are for the
following policies:

Accumulation Variable Universal Life 2021

Accumulation Variable Universal Life 2021 Core

Majestic Accumulation Variable Universal Life 2021

 Except as modified by the supplement, all
other terms of the Prospectus remain in effect and unchanged.

 The list in the
OVERVIEW OF THE POLICY—Policy Features—Supplementary benefit riders” is amended to add:

•

 Defined Benefit Chronic Illness Rider

The table and footnote under FEE TABLE—Periodic Charges Other Than
Annual Portfolio Expenses is amended to add the following:

Charge

Purpose

Brief description
of
  restrictions/limitations  

 Defined Benefit Chronic Illness Rider*

Monthly

 Minimum Charge

$0.01 per $1,000 of NAR

 Maximum Charge

$914.72 per $1,000 of NAR

 Charge for representative insured
person

$0.52 per $1,000 of NAR

*
 The charge for this rider is determined by multiplying NAR by the applicable
rate. The rates vary by the chronic illness insurance risk characteristics of t