Correspondence 0001683863-24-003849 from JOHN HANCOCK FINANCIAL OPPORTUNITIES FUND (BTO) (CIK 0000925683) (BTO)
JOHN HANCOCK FINANCIAL OPPORTUNITIES FUND (BTO) (CIK 0000925683)
Date: May 8, 2024 · CIK: 0000925683 · Accession: 0001683863-24-003849
AI Filing Summary & Sentiment
File numbers found in text: 811-00560, 811-01677, 811-02485, 811-03999, 811-04146, 811-04173, 811-04186, 811-05908, 811-08568, 811-21131, 811-21202, 811-21287, 811-21416, 811-21777, 811-21779, 811-22056, 811-22441, 811-22733, 811-23027
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission Attention: Jeff Long Securities and Exchange Commission John Hancock Funds III Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended March 31, 2023; File No. 811-21777 John Hancock Investment Trust Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended October 31, 2023; File No. 811-00560 John Hancock Investment Trust II Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended October 31, 2023; File No. 811-03999 John Hancock Variable Insurance Trust Form N-CSR Annual Reports to Shareholders ("Form N- CSR") for the Period Ended December 31, 2023; File No. 811-04146
Dear Mr. Long:
This letter responds to the comments of the Staff of the Securities and Exchange Commission ("SEC"), which were conveyed to us by telephone on April 1, 2024 with respect to the filings on Form N-CSR for the John Hancock Funds listed on Annex A, attached hereto. The Staff's comments are set forth below, each followed by the respective fund's response.
1.Comment: For John Hancock Financial Opportunities Fund, registration statements rely on the short form (General Instructions A 2). Form N-2 requires 10 years of financial highlights to be presented in the registration statement. Noted that the 12-31-23 Form N-CSR filing only included 5 years of financial highlights. Options to extend financial highlights to 10 years include: 1) incorporate by reference historical financial statements filed in Form N-CSR, 2) file an amendment to the registration statement on Form 424B3, or 3) include the earliest 5 years of financial highlights in the additional information section of the shareholder report filed in Form N-CSR.
Response: We agree and will file Form 424B3 for John Hancock Financial Opportunities Fund in response to this comment.
2.Comment: For the John Hancock Variable Insurance Trust Form N-CSR filing, annual shareholder reports include summary schedules of investments and Item 6 of Form N-SCR includes full schedules of investments with the independent auditor opinions on full schedules. For the equity funds, the independent auditor opinion on the full schedules of investments incorrectly references summary schedules.
Response: We agree and will file an amended Form N-CSR for John Hancock Variable Insurance Trust, which will include an updated independent auditor opinion referencing the full schedule of investments for the equity funds.
3.Comment: For John Hancock Income Securities Trust, John Hancock Investors Trust, and John Hancock Financial Opportunities Fund, noted the expense ratios included on the Fact Sheets as of December 31, 2023 do not agree to the financial highlights in the most current financial statements.
Securities and Exchange Commission
April 28, 2021
Page 3 of 7
Response: The expense ratios per the Fact Sheets are generally updated annually following the effective date of the prospectus update (e.g. Fact Sheet expense ratios for October 31, 2023 fiscal year end funds with a March 1, 2024 prospectus update would be updated for the March 31, 2024 quarter end Fact Sheet).
4.Comment: For John Hancock Tax-Advantaged Dividend Income Fund (HTD), the performance section of the annual report compares performance to two blended indices (primary and secondary) however Form N-2 states that performance should be compared to a broad-based securities index. Please explain how the fund is meeting this requirement.
5.Response: The Fund respectfully disagrees that the fund's blended benchmark is not an "appropriate broad-based securities market index" as used in Instruction 4.g.(2)(F) to Item 24 in Form N-2. The blended benchmark used by the fund, consistent with Form N-2, is "one that is administered by an organization that is not an affiliated person of the Fund, its investment adviser, or principal underwriter, unless the index is widely recognized and used." The Fund uses blended benchmarks comprised of constituent asset class indices that are calculated and administered by organizations that are not affiliated persons of the Fund, its investment adviser, or principal underwriter, and each of these constituent indices qualifies as an "appropriate broad-based securities market index." Moreover, the benchmark blend is static and not "administered" by the adviser on an ongoing
basis. Notwithstanding the foregoing, in response to the Staff's request, the Fund will include the performance of the ICE BofA U.S. All Capital Securities Index first in the performance section of its annual report, in addition to the Primary and Secondary Blended Indexes, which will be renamed the Blended Benchmark and Additional Blended Benchmark, respectively.
We hope that these foregoing responses adequately address the Staff's comments. If you have any questions, please do not hesitate to contact me via e-mail at sschiavone@jhancock.com .
Sincerely,
/s/ Salvatore Schiavone Salvatore Schiavone Treasurer
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CORRESP
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filename1.htm
April 2024 SEC comments
John Hancock Group of Funds
200 Berkeley Street
Boston, Massachusetts 02116
May 8, 2024
VIA EDGAR
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Jeff Long
Re: Closed End Fund
John Hancock Financial Opportunities Fund Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended December 31, 2023; File No. 811-08568
John Hancock Hedged Equity & Income Fund Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended December 31, 2023; File No. 811-22441
John Hancock Income Securities Trust Form N-CSR Annual Reports to Shareholders ("Form N- CSR") for the Period Ended October 31, 2023; File No. 811-04186
John Hancock Investors Trust Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended October 31, 2023; File No. 811-04173
John Hancock Premium Dividend Fund Form N-CSR Annual Reports to Shareholders ("Form N- CSR") for the Period Ended October 31, 2023; File No. 811-05908
John Hancock Tax-Advantaged Dividend Income Fund Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended October 31, 2023; File No. 811-21416
John Hancock Tax-Advantaged Global Shareholder Yield Fund Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended October 31, 2023; File No. 811-22056
John Hancock Preferred Income Fund Form N-CSR Annual Reports to Shareholders ("Form N- CSR") for the Period Ended July 31, 2023; File No. 811-21131
John Hancock Preferred Income Fund II Form N-CSR Annual Reports to Shareholders ("Form N- CSR") for the Period Ended July 31, 2023; File No. 811-21202
John Hancock Preferred Income Fund III Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended July 31, 2023; File No. 811-21287
Open End Funds
John Hancock Capital Series Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended October 31, 2023; File No. 811-01677
John Hancock Collateral Trust Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended December 31, 2023; File No. 811-23027
Securities and Exchange Commission
April 28, 2021
Page 2 of 7
John Hancock Current Interest Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended March 31, 2023; File No. 811-02485
John Hancock Exchange-Traded Fund Trust Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended April 30, 2023; File No. 811-22733
John Hancock Funds II Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended December 31, 2023; File No. 811-21779
John Hancock Funds III Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended March 31, 2023; File No. 811-21777
John Hancock Investment Trust Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended October 31, 2023; File No. 811-00560
John Hancock Investment Trust II Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended October 31, 2023; File No. 811-03999
John Hancock Variable Insurance Trust Form N-CSR Annual Reports to Shareholders ("Form N- CSR") for the Period Ended December 31, 2023; File No. 811-04146
Dear Mr. Long:
This letter responds to the comments of the Staff of the Securities and Exchange Commission ("SEC"), which were conveyed to us by telephone on April 1, 2024 with respect to the filings on Form N-CSR for the John Hancock Funds listed on Annex A, attached hereto. The Staff's comments are set forth below, each followed by the respective fund's response.
1.Comment: For John Hancock Financial Opportunities Fund, registration statements rely on the short form (General Instructions A 2). Form N-2 requires 10 years of financial highlights to be presented in the registration statement. Noted that the 12-31-23 Form N-CSR filing only included 5 years of financial highlights. Options to extend financial highlights to 10 years include: 1) incorporate by reference historical financial statements filed in Form N-CSR, 2) file an amendment to the registration statement on Form 424B3, or 3) include the earliest 5 years of financial highlights in the additional information section of the shareholder report filed in Form N-CSR.
Response: We agree and will file Form 424B3 for John Hancock Financial Opportunities Fund in response to this comment.
2.Comment: For the John Hancock Variable Insurance Trust Form N-CSR filing, annual shareholder reports include summary schedules of investments and Item 6 of Form N-SCR includes full schedules of investments with the independent auditor opinions on full schedules. For the equity funds, the independent auditor opinion on the full schedules of investments incorrectly references summary schedules.
Response: We agree and will file an amended Form N-CSR for John Hancock Variable Insurance Trust, which will include an updated independent auditor opinion referencing the full schedule of investments for the equity funds.
3.Comment: For John Hancock Income Securities Trust, John Hancock Investors Trust, and John Hancock Financial Opportunities Fund, noted the expense ratios included on the Fact Sheets as of December 31, 2023 do not agree to the financial highlights in the most current financial statements.
Securities and Exchange Commission
April 28, 2021
Page 3 of 7
Response: The expense ratios per the Fact Sheets are generally updated annually following the effective date of the prospectus update (e.g. Fact Sheet expense ratios for October 31, 2023 fiscal year end funds with a March 1, 2024 prospectus update would be updated for the March 31, 2024 quarter end Fact Sheet).
4.Comment: For John Hancock Tax-Advantaged Dividend Income Fund (HTD), the performance section of the annual report compares performance to two blended indices (primary and secondary) however Form N-2 states that performance should be compared to a broad-based securities index. Please explain how the fund is meeting this requirement.
5.Response: The Fund respectfully disagrees that the fund's blended benchmark is not an "appropriate broad-based securities market index" as used in Instruction 4.g.(2)(F) to Item 24 in Form N-2. The blended benchmark used by the fund, consistent with Form N-2, is "one that is administered by an organization that is not an affiliated person of the Fund, its investment adviser, or principal underwriter, unless the index is widely recognized and used." The Fund uses blended benchmarks comprised of constituent asset class indices that are calculated and administered by organizations that are not affiliated persons of the Fund, its investment adviser, or principal underwriter, and each of these constituent indices qualifies as an "appropriate broad-based securities market index." Moreover, the benchmark blend is static and not "administered" by the adviser on an ongoing
basis. Notwithstanding the foregoing, in response to the Staff's request, the Fund will include the performance of the ICE BofA U.S. All Capital Securities Index first in the performance section of its annual report, in addition to the Primary and Secondary Blended Indexes, which will be renamed the Blended Benchmark and Additional Blended Benchmark, respectively.
We hope that these foregoing responses adequately address the Staff's comments. If you have any questions, please do not hesitate to contact me via e-mail at sschiavone@jhancock.com .
Sincerely,
/s/ Salvatore Schiavone Salvatore Schiavone Treasurer
John Hancock Group of Funds
Securities and Exchange Commission
April 28, 2021
Page 4 of 7
Annex A
Count
Series ID
FYE
File #
Series Name
Registrant Name
1
S000000620
10/31/2023
811-01677
U.S. Global Leaders Growth Fund
John Hancock Capital Series
2
S000000617
10/31/2023
811-01677
Classic Value Fund
John Hancock Capital Series
3
S000048934
12/31/2023
811-23027
John Hancock Collateral Trust
John Hancock Collateral Trust
4
S000000623
3/31/2023
811-02485
John Hancock Money Market Fund
John Hancock Current Interest
5
S000050077
4/30/2023
811-22733
John Hancock Multifactor Large Cap
John Hancock Exchange-Traded Fund
ETF
Trust
6
S000074603
4/30/2023
811-22733
John Hancock Preferred Income ETF
John Hancock Exchange-Traded Fund
Trust
7
S000055737
4/30/2023
811-22733
John Hancock Multifactor Developed
John Hancock Exchange-Traded Fund
International ETF
Trust
8
S000072179
4/30/2023
811-22733
John Hancock Mortgage-Backed
John Hancock Exchange-Traded Fund
Securities ETF
Trust
9
S000063017
4/30/2023
811-22733
John Hancock Multifactor Emerging
John Hancock Exchange-Traded Fund
Markets ETF
Trust
10
S000077441
4/30/2023
811-22733
John Hancock U.S. High Dividend
John Hancock Exchange-Traded Fund
ETF
Trust
11
S000071291
4/30/2023
811-22733
John Hancock Corporate Bond ETF
John Hancock Exchange-Traded Fund
Trust
12
S000050079
4/30/2023
811-22733
John Hancock Multifactor Mid Cap
John Hancock Exchange-Traded Fund
ETF
Trust
13
S000059464
4/30/2023
811-22733
John Hancock Multifactor Small Cap
John Hancock Exchange-Traded Fund
ETF
Trust
14
S000079041
4/30/2023
811-22733
John Hancock International High
John Hancock Exchange-Traded Fund
Dividend ETF
Trust
15
12/31/2023
811-08568
John Hancock Financial
John Hancock Financial Opportunities
Opportunities Fund
Fund
16
S000003339
12/31/2023
811-21779
Multimanager Lifestyle Growth
John Hancock Funds II
Portfolio
17
S000003337
12/31/2023
811-21779
Multimanager Lifestyle Balanced
John Hancock Funds II
Portfolio
18
S000003342
12/31/2023
811-21779
Multimanager Lifestyle Moderate
John Hancock Funds II
Portfolio
19
S000003338
12/31/2023
811-21779
Multimanager Lifestyle Conservative
John Hancock Funds II
Portfolio
20
S000003335
12/31/2023
811-21779
Multimanager Lifestyle Aggressive
John Hancock Funds II
Portfolio
21
S000023715
3/31/2023
811-21777
John Hancock Disciplined Value
John Hancock Funds III
Fund
22
S000001412
3/31/2023
811-21777
John Hancock International Growth
John Hancock Funds III
Fund
23
S000035055
3/31/2023
811-21777
John Hancock U.S. Growth Fund
John Hancock Funds III
24
S000028882
3/31/2023
811-21777
John Hancock Disciplined Value Mid
John Hancock Funds III
Cap Fund
25
S000015906
3/31/2023
811-21777
John Hancock Global Shareholder
John Hancock Funds III
Yield Fund
26
12/31/2023
811-22441
John Hancock Hedged Equity &
John Hancock Hedged Equity & Income
Income Fund
Fund
Securities and Exchange Commission
April 28, 2021
Page 5 of 7
27
10/31/2023
811-04186
John Hancock Income Securities
John Hancock Income Securities
28
S000066059
10/31/2023
811-00560
John Hancock Diversified Macro
John Hancock Investment Trust
Fund
29
S000053961
10/31/2023
811-00560
John Hancock ESG Large Cap Core
John Hancock Investment Trust
Fund
30
S000043448
10/31/2023
811-00560
John Hancock Infrastructure Fund
John Hancock Investment Trust
31
S000045751
10/31/2023
811-00560
John Hancock Disciplined Value
John Hancock Investment Trust
International Fund
32
S000049614
10/31/2023
811-00560
John Hancock Emerging Markets
John Hancock Investment Trust
Equity Fund
33
S000043449
10/31/2023
811-00560
John Hancock Seaport Long/Short
John Hancock Investment Trust
Fund
34
S000065244
10/31/2023
811-00560
John Hancock International Dynamic
John Hancock Investment Trust
Growth Fund
35
S000055868
10/31/2023
811-00560
John Hancock ESG International
John Hancock Investment Trust
Equity Fund
36
S000043450
10/31/2023
811-00560
John Hancock Small Cap Core Fund
John Hancock Investment Trust
37
S000000630
10/31/2023
811-00560
Fundamental Large Cap Core Fund
John Hancock Investment Trust
38
S000063662
10/31/2023
811-00560
John Hancock Global Thematic
John Hancock Investment Trust
Opportunities Fund
39
S000000629
10/31/2023
811-00560
Balanced Fund
John Hancock Investment Trust
40
S000072387
10/31/2023
811-00560
John Hancock Global Environmental
John Hancock Investment Trust
Opportunities Fund
41
S000000635
10/31/2023
811-03999
Regional Bank Fund
John Hancock Investment Trust II
42
S000000634
10/31/2023
811-03999
Financial Industries Fund
John Hancock Investment Trust II
43
10/31/2023
811-04173
John Hancock Investors Trust
John Hancock Investors Trust
44
7/31/2023
811-21131
John Hancock Preferred Income Fund
John Hancock Preferred Income Fund
45
7/31/2023
811-21202
John Hancock Preferred Income Fund
John Hancock Preferred Income Fund II
II
46
7/31/2023
811-21287
John Hancock Preferred Income Fund
John Hancock Preferred Income Fund
III
III
47
10/31/2023
811-05908
John Hancock Premium Dividend
John Hancock Premium Dividend Fund
Fund
48
10/31/2023
811-21416
John Hancock Tax-Advantaged
John Hancock Tax-Advantaged
Dividend Income Fund
Dividend Income Fund
49
10/31/2023
811-22056
John Hancock Tax-Advantaged
John Hancock Tax-Advantaged Global
Global Shareholder Yield Fund
Shareholder Yield Fund
50
S000008231
12/31/2023
811-04146
Global Equity Trust
John Hancock Variable Insurance Trust
51
S000029542
12/31/2023
811-04146
Ultra Short Term Bond Trust
John Hancock Variable Insurance Trust
52
S000024662
12/31/2023
811-04146
Short Term Government Income
John Hancock Variable Insurance Trust
Trust
53
S000008296
12/31/2023
811-04146
Fundamental All Cap Core Trust
John Hancock Variable Insurance Trust
54
S000008273
12/31/2023
811-04146
Investment Quality Bond Trust
John Hancock Variable Insurance Trust
55
S000008278
12/31/2023
811-04146
Managed Volatility Growth Portfolio
John Hancock Variable Insurance Trust
56
S000008216
12/31/2023
811-04146
American International Trust
John Hancock Variable Insurance Trust
57
S000008281
12/31/2023
811-04146
Managed Volatility Conservative
John Hancock Variable Insurance Trust
Portfolio
Securities and Exchange Commission
April 28, 2021
Page 6 of 7
58
S000008280
12/31/2023
811-04146
Managed Volatility Moderate
John Hancock Variable Insurance Trust
Portfolio
59
S000021933
12/31/2023
811-04146
Capital Appreciation Value Trust
John Hancock Variable Insurance Trust
60
S000008312
12/31/2023
811-04146
Small Cap Opportunities Trust
John Hancock Variable Insurance Trust
61
S000008302
12/31/2023
811-04146
Disciplined Value International Trust
John Hancock Variable Insurance Trust
62
S000008316
12/31/2023
811-04146
Small Company Value Trust
John Hancock Variable Insurance Trust
63
S000008278
12/31/2023
811-04146
Managed Volatili