SecProbe.io

CORRESP
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    March 13, 2020

        Trayne S. Wheeler

        trayne.wheeler@klgates.com

        T +1 617 951 9068

        F +1 617 261 3175

VIA EDGAR

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 02549

Attention: Sonny Oh

    Re:
    John Hancock Funds II (the “Trust”) — File Nos. 333-126293 and 811-21779

    Registration Statement on Form N-1A

Dear Mr. Oh:

On behalf of the Trust, we submit this
letter in response to comments received by telephone on March 3, 2020, from the staff (“Staff”) of the Securities and
Exchange Commission (the “SEC”) with respect to Post-effective Amendment No. 221 under the Securities Act of 1933,
as amended, and Amendment No. 223 under the Investment Company Act of 1940, as amended (the “1940 Act”), to the Trust’s
Registration Statement on Form N-1A, filed with the SEC on January 17, 2020, accession no. 0001133228-20-000120 (the “Amendment”).
The Amendment relates to John Hancock Opportunistic Fixed Income Fund (formerly John Hancock Global Bond Fund), a series of the
Trust (the “Fund”).

For convenience, we have set forth each
comment below, followed by the Trust’s response. Unless otherwise stated, capitalized terms have the same meaning as in the
Amendment.

Comments Applicable to All Prospectuses

 1.	 Comment— The SEC staff notes that the Fund recently changed its name and that there are certain
bracketed or omitted items in the Amendment. Please update the Fund’s series and class identifiers for the Fund’s new
name, include the new share class ticker symbols, and finalize and complete any omitted information in the Fund’s final filing.

Response — The Trust
confirms it will make the requested changes and will finalize and include any omitted information in the final filing.

 2. Comment — On the front cover and under “Fund Summary,” given the Fund’s
name change, please explain supplementally how the current Fund shareholders have been, or will be, advised of the name change
and any changes in the Fund’s principal investment strategies and risks.

        K&L Gates LLP

        State Street Financial Center   One Lincoln
        Street   Boston   MA 02111

        T +1 617 261 3100   F +1 617 261 3175   klgates.com

Response — In response
to the Staff’s comment, the Trust respectfully notes that it filed with the SEC and mailed to Fund shareholders a supplement
informing them of the changes to the Fund’s name and principal investment strategies.

 3. Comment — Under “Fund Summary — Fees and expenses,” please confirm
whether the Trust intends to designate any share class of the Fund as “Clean Shares” for purposes of the relief provided
by the SEC staff in its no action letter to Capital Group (publicly available January 11, 2017) (“Capital Group”).
If so, please confirm that the conditions of, and disclosure required by, that letter have been satisfied.

Response — The Trust
does not intend to designate any classes of shares of the Fund as “Clean Shares” for purposes of the relief provided
by the Capital Group letter. Accordingly, the Trust respectfully notes that no further confirmation is necessary in response
to this comment.

 4. Comment —Please provide for the Staff’s review completed fee tables under “Fund
summary — Fees and expenses” as part of this letter.

Response
— The fee tables for the Fund and the share classes described in the Amendment are included in Appendix A to this
letter.

 5. Comment — Under “Fund Summary — Fees and expenses,” in the “Shareholder
fees” table, with respect to “Other Expenses,” please delete the second footnote or explain supplementally how
there is an expense component unique to a given share class.

Response
— The Trust believes that including estimated “other expenses” provides useful information for shareholders.
The Trust believes the footnote appropriately and adequately informs shareholders that the stated “other expenses,”
including expected transfer agency expenses, are estimated for the first year of operations of the Fund’s Class A, Class
C, Class I and Class R6 shares, and that no additional explanation is required. The Trust notes that transfer agency expenses for
each class of shares may differ due to differences in the expected investor base, as well as potential asset level changes. Accordingly,
the Trust respectfully declines to make any changes in response to this comment.

 6. Comment — Under “Fund Summary — Fees and expenses” in the “Annual
fund operating expenses” table, please confirm and state supplementally that any contractual waivers will be in effect for
at least a one year period from the date of effectiveness of the registration statement and whether the expense limitation arrangement
may be terminated before its expiration date and, if so, by whom and under what circumstances. Please also state supplementally
whether the investment adviser has the ability to recoup amounts waived or reimbursed under the contractual expense limitation
arrangement. If so, please disclose the conditions under which recoupment may take place.

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Response
— Supplementally, the Trust confirms that any contractual waivers will be in effect for at least one year from the date of
effectiveness, and further notes that management does not have the authority to terminate the Fund’s contractual expense
limitation or waiver prior to its expiration date and that waived or reimbursed expenses are not subject to recoupment by the adviser.

 7. Comment — Regarding the disclosure under “Fund summary — Expense example,”
please disclose in the narrative introduction that the contractual waivers, if any, are reflected for only one year or the duration
of the waiver.

Response
— The Trust confirms that the expense examples reflect the effect of any contractual fee waivers only for the periods described
in the fee table, as permitted by Instruction 4(a) to Item 3 of Form N-1A. However, as Form N-1A does not require disclosure
related to this approach, the Trust respectfully declines to make any changes in response to this comment.

 8. Comment — Under “Fund summary — Principal investment strategies,”
the disclosure states that the Fund will invest in “fixed income instruments.” Please define “fixed income instruments”
in Plain English in the disclosure.

Response — In response
to the Staff’s comment, the Trust has revised the disclosure to add the following sentence as follows:

“Fixed income instruments
include, but are not limited to the following securities, which may be denominated in U.S. dollars or foreign currencies: sovereign
debt, inflation-linked bonds, corporate and high yield credit, securitized debt, bank loans and floating rate loans, and emerging
markets debt convertible and hybrid securities.”

 9. Comment — Under “Fund summary — Principal investment strategies,”
please ensure the disclosure is not generic and fully describes how the Fund will use derivatives and the risks associated with
the use of derivatives. See the letter from Barry Miller of the Division of Investment Management of the SEC to the Investment
Company Institute dated July 30, 2010 (the “Derivatives Disclosure Letter”). Please also disclose whether investments
in derivatives are included in the Fund’s 80% policy, and, if so, explain how such investments are valued.

Response —
The Trust confirms that it has reviewed the derivatives disclosure included in the Fund’s prospectus and has determined that
it is consistent with the views set forth in the Derivatives Disclosure Letter. The Trust notes that the Fund reserves the right
to include investments in its 80% policy and notes that the Fund generally will use market value, and not notional value, to value
its investments in derivatives.

 10. Comment — Under “Fund summary — Principal investment strategies,”
disclose whether the Fund intends to invest greater than 25% of its net assets in the sovereign debt of a single foreign country.

Response
— In response to the Staff’s comment, the Trust confirms that it will not invest greater than 25% of its net assets
in the sovereign debt of a single foreign country. Therefore, the Trust respectfully declines to make any changes in response to
this comment.

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 11. Comment — The Fund states under “Fund summary — Principal investment strategies”
that it seeks exposure to, among other things, “a portfolio of high conviction global fixed income securities.” Please
provide additional disclosure explaining this in Plain English.

Response — In response
to the Staff’s comment, the Trust has revised the disclosure to state that the Fund’s manager seeks:

“…exposure to a portfolio
of high conviction global fixed income securities...”

 12. Comment — The Fund states under “Fund summary — Principal investment strategies”
that it seeks exposure to, among other things, inflation-linked bonds. Please include a corresponding risk for inflation-linked
bonds under “Fund summary — Principal risks.”

Response — In response
to the Staff’s comment, the Trust believes that the risks of investing in inflation-linked bonds are similar to the risks
applicable to investment in other fixed-income securities. As a result, the Trust believes that the Fixed-income securities
principal risk is sufficient to disclose the risks of investing in inflation-linked bonds. Accordingly, the Trust respectfully
declines to make any changes in response to this comment.

 13. Comment — The Fund states under “Fund summary — Principal investment strategies”
that it seeks exposure to, among other things, high yield credit. Please include a statement that “high yield” bonds
are also known as “junk bonds.”

Response — In response
to the Staff’s comment, the Trust has made the requested change.

 14. Comment — The Fund states under “Fund summary — Principal investment strategies”
that it may invest in emerging markets debt. Please disclose the method the Fund uses to determine a country is an emerging markets
country.

Response — With respect
to the methodology used to determine whether a country is an emerging market, the Fund does not formally distinguish between foreign
and emerging market securities and respectfully declines to make any changes in response to this comment. With respect to risk
disclosure, the Trust notes that “Emerging-market risk” is included as a sub-risk of “Foreign securities risk”
in the Fund’s prospectus.

 15. Comment — The Fund states under “Fund summary — Principal investment strategies”
that it is managed with “the goal of aligning long-term volatility of the portfolio” with a benchmark index. Please
explain this in Plain English.

Response — In response
to the Staff’s comment, the Trust has revised the disclosure to add the following sentence:

“The manager seeks
to manage the Fund’s overall performance volatility within a range as reflected by the Bloomberg Barclays Global Aggregate
Bond Index hedged to USD over the medium- to long-term.”

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 16. Comment — The Fund states under “Fund summary — Principal investment strategies”
that it will invest using, among other techniques, sector rotation. Please disclose whether the Fund intends to concentrate in
any given sector and, if applicable, please disclose this in the principal investment strategies and risks.

Response — In response
to the Staff’s comment, the Trust notes that it does not intend to concentrate in any given sector.

 17. Comment — Under “Fund summary — Principal risks,” the Staff notes
that the principal risks appear in alphabetical order. Please reorder the risks to prioritize the risks that are most likely to
adversely affect the Fund’s net asset value, yield and total return. Please note that after listing the most significant
risks to the Fund, the remaining risks may be alphabetized. See Dalia Blass, Keynote Address - ICI Securities Law Developments
Conference, October 25, 2018, available at: https://www.sec.gov/news/speech/speech-blass-102518# and ADI-2019-08 - Improving
Principal Risks Disclosure.

Response — The Trust
respectfully submits that the current order of the principal risks is in compliance with the requirements of Form N-1A, which does
not require listing the principal risks of investing in a fund in any particular order. The Trust further notes that the alphabetical
ordering convention of its “Principal risks” is consistent across the John Hancock complex. However, in order to clarify
for shareholders that they should not make any assumptions regarding the significance of the risk factors based on their current
order, the Trust has revised the introductory disclosure under the heading “Fund summary — Principal risks” as
follows:

The fund’s
main risks are listed below in alphabetical order, not in order of importance.

 18. Comment — The disclosure under “Fund summary — Principal risks,”
includes “Equity securities risk.” Please add disclosure relating to investments in equity securities to the Fund’s
principal investment strategies.

Response —In response
to the Staff’s comment, the Trust has added the following sentence to its principal investment strategies:

“The fund may invest in securities
that at times may have equity-like characteristics including, but not limited to, convertible securities, contingent convertible
bonds (“CoCos”), or preferred equity. Additionally, the fund may hold equities received as part of a corporate action.”

 19. Comment — The disclosure under “Fund summary — Principal risks,”
includes “Floating rate loans risk.” Please add disclosure relating to investments in floating rate loans to the Fund’s
principal investment strategies.

Response —In response
to the Staff’s comment, the Trust has made the requested change.

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 20. Comment — The Staff notes that the disclosure in the first two paragraphs under “Fund
summary — Past performance” discusses performance information and should be moved to be located within the “Fund
summary — Past performance — A note on performance” section.

Response — In response
to the Staff’s comment, the Trust notes that certain nonstandard disclosures detailing a recent change in subadviser are
shown in the “Fund summary — Past performance” introduction. The Trust notes that under “Fund summary —
Past performance,” it will move the first paragraph to appear within the “Fund summary — Past performance —
A note on performance” section, as requested by the Staff. The Trust notes that it will delete the second paragraph under
“Fund summary — Past performance,” since those changes are now effective and will be reflected in the final filing.
The Trust notes that after these disclosure changes are made, the disclosure for the “Fund summary — Past performance”
will then match the standard John Hancock complex-wide disclosure for this section of the prospectus.

 21. Comment — Under “Fund summary — Past performance,” please explain
supplementally how the Bloomberg Barclays Global Aggregate Bond Index (USD Hedged) Index is an appropriate broad-based securities
market index given the Fund’s principal investment strategies, in particular with respect to the fact that the Fund still
has exposure to foreign currencies and securities.

Response — In response
to the Staff’s comment, the Trust notes that while at times the fund may have significant exposure to foreign securities
and currencies, the portfolio is managed to have its volatility in line with its stated benchmark, as stated in the Fund’s
principal investment strategies. The unhedged version of the benchmark carries a higher volatility due to currency effects. Therefore,
the Trust believes the current benchmark is appropriate and that it would be misleading to shareholders to indicate the portfolio
would be managed to match the volatility profile of the unhedged version of the benchmark.

 22. Comment — Under “Fund summary — Past performance,” please delete
the sentence that reads: “All figures assume dividend reinvestment.” This statement is not required by Item 4(b)(2)(i)
of F