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JOHN HANCOCK LIFE INSURANCE CO (USA) SEPARATE ACCOUNT A

Table of Contents

 March 20, 2024

 197
Clarendon Street

 Boston, Massachusetts 02116

 (617) 572-0070

 Email: mramirez@jhancock.com

 Michael A Ramirez

 AVP & Senior Counsel

 Mr. Sonny Oh

U.S. Securities and Exchange Commission

 100 F Street NE

Washington, DC 20549

 Via EDGAR Correspondence Submission and
Email

Re:
 John Hancock Life Insurance Company (U.S.A.) Separate Account A Registration Statement Filed on
December 1, 2023, regarding Rule 485(a) Post-Effective Amendment Filing to Form N-6 for Accumulation Variable Universal Life 2021 Policies (“AVUL 2021”)
(333-254210) – Initial Summary Prospectus

 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 March 1, 2024, in connection with the Rule 485(a) amendment to add an Initial Summary Prospectus (“ISP”) to the
Form N-6 Registration Statement.

 Sections of each prospectus cited in the below recitations of
the Staff’s comments refer to the marked courtesy copies on which the Staff based its comments. Additionally, any applicable changes made in the attached courtesy copies of the prospectuses will be made in every other replicate prospectus which
relies on the immediate Rule 485(a) filing.

 Comments to Statutory Prospectus

Staff Comment 1: Please reconsider whether to include the Defined Benefit Chronic Illness Rider in the column for Investment Restrictions in the
“Important Information” table.

 Response: We added the reference to the Defined Benefit Chronic Illness Rider accordingly.

Staff Comment 2: Please remove the freestanding “e” on footnote 6.

Response: Thank you for point this out and we have removed the error.

Staff Comment 3: Please add the “Changes you may make” paragraph from the Initial Summary Prospectus (ISP) to the corresponding
section of the Statutory Prospectus.

 Response: This paragraph has been added accordingly.

Table of Contents

 Mr. Sonny Oh

February 9, 2024

  Page
 2

 Staff Comment 4: As in the ISP, remove “in years
1-10” in the Cash Value Enhancement Rider row of the FEE TABLE of the Statutory Prospectus.

Response: We modified the disclosure accordingly.

Comments to Form of Initial Summary Prospectus

Staff Comment 5: On the last page of the ISP, please include the dates of the documents according to Rule 498A(b)(3)(i).

Response: We included the date of the documents incorporated by reference.

Staff Comment 6: Please confirm that the 1933 Act number, 1940 Act number, and Contract Identifier number are in a smaller font than that used
in the rest of the prospectus.

 Response: While the font is smaller, we decreased the font further to make the distinction clearer.

Comments to the Template Relief Letter

Staff Comment 7: In the template request letter, add a footnote referencing the rule release for Rule 498A in the first representation.

Response: We included a new footnote to the rule release.

Staff Comment 8: In the SCHEDULE, include a third column indicating the date of last review of the registration statement for each replicate
filing. Additionally, add a footnote that indicates that each of the replicate filings was updated per the adopting release. The purpose of these filings is to add an ISP for each.

Response: We included this footnote with the requested information accordingly.

We believe that the foregoing is responsive to the comments received to date on the Rule 485(a) filing of the AVUL 2021 statutory prospectus and ISP. 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

Table of Contents

 John Hancock Life Insurance Company (U.S.A.) Separate Account A

John Hancock Life Insurance Company (U.S.A.)

(“John Hancock USA”)

Flexible Premium Variable Universal Life Insurance Policy with Indexed Accounts

ACCUMULATION VARIABLE UNIVERSAL LIFE 2021

Prospectus dated [   ], 2024

You may choose to allocate your policy value to one or more of the options that the policies make available for that purpose. These options include our
“variable investment accounts,” where the policy value will vary directly with the positive or negative investment experience of underlying investment “portfolios.” To provide you with that investment experience, amounts that you
allocate to a variable investment account are held in a corresponding “subaccount” of John Hancock Life Insurance Company (U.S.A.) Separate Account A (“Separate Account”), and the subaccount invests those amounts exclusively in
one of the portfolios.

 You may also allocate policy value to a fixed indexed account (“indexed account”) or to a “fixed account” that
the policy makes available. This prospectus provides detailed information about all such options to which you can allocate your policy value.

 Please note
that the Securities and Exchange Commission (“SEC”) has not approved or disapproved these securities or determined if this prospectus is truthful or complete. Any representation to the contrary is a criminal offense.

Additional information about certain investment products, including variable life insurance, has been prepared by the SEC’s staff and is available at
Investor.gov.

 If you are a new investor, you may cancel your policy within 10 days of receiving it without paying fees or penalties. In some states (or
if your policy replaces another policy), this cancellation period may be longer. Upon cancellation, you will receive either a full refund of the amount you paid with your application or your total policy value. You should review this prospectus, or
consult with your investment professional, for additional information about the specific cancellation terms that apply.

Table of Contents

 TABLE OF CONTENTS

 IMPORANT INFORMATION YOU SHOULD CONSIDER ABOUT THE
POLICY

5

 OVERVIEW OF THE POLICY

8

 Purpose

8

 Premiums

8

 Policy Features

8

 Death benefit

8

 Surrender of the policy

8

 Withdrawals

8

 Policy loans

9

 Policy credit

9

 Supplementary benefit riders

9

 FEE TABLE

10

 GENERAL DESCRIPTION OF THE POLICY

14

 Policy Rights

14

 Owner and beneficiary

14

 Allocation of Premiums

14

 Transfers of Policy Value

15

 Limitations on transfers to or from a variable investment
account

15

 Frequent transfers among variable investment
accounts

15

 Limitations on transfers out of the fixed account

16

 Limitations on transfers to and from an indexed
account

16

 Potential additional limitations

16

 Dollar cost averaging and asset allocation balancer
programs

16

 General Account

17

 The fixed account

17

 The indexed accounts

17

 PREMIUMS

24

 Purchase Procedures

24

 Premium Amount

24

 Premium Due Dates

24

 No-lapse
Guarantee

25

 STANDARD DEATH BENEFITS

26

 Standard Death Benefits

26

 Effectiveness and Policy Date

26

 Temporary insurance coverage

26

 Option 1 and Option 2

26

 Base Face Amount and Supplemental Face Amount

27

 Minimum death benefit

27

 Calculation and payment of the death benefit

28

 Additional Information About Standard Death
Benefits

28

 Requesting an increase or decrease in coverage

28

 Change of death benefit option

28

 Tax consequences of coverage changes

28

 Limitations on payment of death benefit

30

 SURRENDERS AND WITHDRAWALS

31

 Surrender and Withdrawal

31

 Additional Information Regarding Surrender and
Withdrawal

31

 Cancellation Rights

31

 2

Table of Contents

 LOANS

32

 Availability of Loans, Limitations and Interest

32

 Effect of Loans on Cash Value and Death Benefit

32

 Other Effects of Loans

33

 Loan Repayments

33

 OTHER BENEFITS AVAILABLE UNDER THE POLICY

34

 More About Certain Optional Benefits

37

 Healthy Engagement Rider

37

 Critical Illness Benefit Rider

38

 Disability Payment of Specified Premium Rider

39

 Long-Term Care Rider

40

 Long-Term Care Rider 2018

41

 Return of Premium Death Benefit Rider

41

 Cash Value Enhancement Rider

42

 Overloan Protection Rider

43

 Accelerated Benefit Rider

43

 Healthy Engagement Core Rider

43

 Accelerated Death Benefit for Chronic Illness
Rider

44

 Defined Benefit Chronic Illness Rider

44

 TAXES

46

 Tax Consequences of Owning a Policy

46

 Effect on the Company’s Taxes

48

 PRINCIPAL RISKS OF INVESTING IN THE POLICY

49

 Lapse Risk

49

 Investment Risk/Risk of Loss

49

 Risks Associated with Indexed Accounts

49

 Transfer Risk

49

 Early Surrender or Withdrawal Risk/Not a Short-Term
Investment

50

 Tax Risks

50

 ADDITIONAL INFORMATION REGARDING THE POLICY

50

 Charges

50

 Deductions from premium payments

50

 Deductions from policy value

51

 Charges at the portfolio level

52

 Additional Information About How Certain Policy Charges
Work

52

 Other Charges We Could Impose in the Future

52

 Commissions Paid to Dealers

52

 Lapse and Reinstatement

53

 Lapse

53

 Reinstatement

53

 Variations

53

 Policy or Separate Account Changes

54

 When We Pay Policy Proceeds

55

 Coverage at and After Age 121

55

 GENERAL DESCRIPTION OF REGISTRANT, DEPOSITOR AND
PORTFOLIOS

57

 Depositor

57

 Registrant

57

 Portfolios

57

 Voting Portfolio Shares

57

 LEGAL PROCEEDINGS

58

 3

Table of Contents

 FINANCIAL STATEMENTS

58

 APPENDIX: PORTFOLIOS AVAILABLE UNDER THE POLICY

Appendix-1

 4

Table of Contents

 IMPORANT INFORMATION YOU SHOULD CONSIDER ABOUT THE POLICY

 FEES AND EXPENSES

Charges for Early Withdrawals

There are surrender charges assessed upon surrender, withdrawal, or policy lapse in the first fifteen policy years from the Policy Date The maximum surrender charge is 5.92% of Base Face Amount. For example, if the Base
Face Amount is $100,000, the highest possible surrender charge would be $5,924.

 FEE TABLE

Deductions from policy value

Transaction Charges

 In addition to surrender charges (if applicable), you may also be charged for the following transactions:

 A premium charge will be deducted from each premium paid.

 A transfer fee may be deducted upon transfers into or out of a variable investment
account after you have made more than 12 such transfers in a year.

 FEE TABLE

Deductions from premium payments

 Deductions
from policy value

Ongoing Fees and Expenses (annual charges)

 In addition to surrender charges and transaction charges, you will also be subject to certain ongoing fees and
expenses, including a cost of insurance charge, administrative charge, Base Face Amount charge, Supplemental Face Amount charge, asset-based risk charge, indexed performance charge, policy loan costs, and supplementary benefit rider charges. Some of
these fees and expenses are based wholly or in part on the characteristics of the insured person (e.g., age, sex, and underwriting classification).

You should view the “policy specifications” page of your policy for rates applicable to your policy.

 You will also bear expenses associated with the portfolios under the policy, as shown in
the following table:

 FEE TABLE

Deductions from policy value

Charges at the portfolio level

Annual Fee

Minimum

Maximum

APPENDIX

Variable investment accounts (portfolio fees and expenses)

[ ]%

[ ]%

 RISKS

Risk of Loss

You can lose money by investing in this policy.

PRINCIPAL RISKS OF INVESTING IN A POLICY

Not a Short-Term Investment

This policy is not a short-term investment and is not appropriate for an investor who needs ready access to cash. The policy is unsuitable as a short-term savings vehicle because of substantial policy-level charges,
including the premium charge and the surrender charge, as well as potential adverse tax consequences from such short-term use.

Early Surrender or Withdrawal Risk/Not a Short-Term Investment

Risks Associated with Investment Options

An investment in this policy is subject to the risk of poor performance and can vary depending on the performance of the account allocation options available under the policy (e.g., portfolios). Each such option
(including the fixed account and indexed accounts) will have its own unique risks, and you should review these options before making an allocation decision.

 Investment Risk/Risk of Loss

Risks Associated with Indexed Accounts

 5

Table of Contents

 RISKS

Insurance Company Risks

Your investment in the policy is subject to risks related to John Hancock USA, including that the obligations, the fixed account and indexed accounts, guarantees, or benefits are subject to the claims- paying ability of
John Hancock USA. Information about John Hancock USA, including its financial strength ratings, is available upon request from your John Hancock USA representative. Our current financial strength ratings can also be obtained by contacting the
Service Office at 1-800-732-5543.

 Depositor

Registrant

Policy Lapse

Unless the No-Lapse Guarantee is in effect, this policy will go into default if at the beginning of any policy month the policy’s net cash surrender value would be zero or
below after deducting the monthly deductions then due. The “net cash surrender value” is your policy value, less any policy debt, and less any applicable surrender charges. This can happen as a result of insufficient premium payments, poor
performance of the variable or general account options you have chosen, withdrawals, or unpaid loans or loan interest. If a default is not cured within a 61-day grace period, your policy will lapse without
value, and no death benefit or other benefits will be payable. You can apply to reinstate a policy that has gone into default, subject to conditions including payment of a specified amount of additional premiums.

 Lapse and

Reinstatement

 RESTRICTIONS

Investments

 There are restrictions that may limit the variable investment account options and general account options, the fixed account and
indexed accounts that you may choose, as well as limitations on the transfer of policy value among those options. These restrictions may include a monthly limit on the number of transfers you may make. We may also impose additional restrictions to
discourage market timing and disruptive trading activity.

 In particular, your
allocation options will be affected if you elect to take a loan or receive benefits under certain supplementary benefit riders.

Among other things, the policy also allows us to eliminate the shares of a portfolio or substitute shares of another new or existing portfolio, subject to
applicable legal requirements.

 Limitations on transfers to or from a variable investment account

 Limitations on transfers out of the fixed account

 Effect of Loans on Cash Value and Death Benefit

 Long-Term Care Rider, Long-Term Care Rider 2018 and Overloan Protection
Rider

 Defined Benefit Chronic Illness Rider

 Portfolios and The Indexed Accounts

Optional Benefits

There are restrictions and limitations relating to optional benefits, as well as conditions under which an optional benefit may be modified or terminated by us. For example, certain supplementary benefit riders may be
subject to underwriting, and your election of an option may result in restrictions upon some of the policy benefits, including availability of investment options.

 Return of Premium Death Benefit Rider Overloan Protection Rider

 Defined Benefit Chronic Illness Rider

 More About Certain Optional
Benefits

 6

Table of Contents

 TAXES

Tax Implications

You should consult with a tax professional to determine the tax implications of an investment in and payments received under the policy. There is no additional tax benefit to you if the policy is purchased through a tax-qualified plan or an individual retirement account (IRA). If we pay out any amount of your poli