Correspondence 0001683863-23-003284 from John Hancock Funds II (CIK 0001331971)
John Hancock Funds II (CIK 0001331971)
Date: April 18, 2023 · CIK: 0001331971 · Accession: 0001683863-23-003284
AI Filing Summary & Sentiment
File numbers found in text: 811-00560, 811-21779, 811-23418
Letter
VIA EDGAR Division of Investment Management Securities and Exchange Commission Attention: Mindy Rotter John Hancock GA Mortgage Trust Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended December 31, 2021; File No. 811-23418 Open End Funds John Hancock Investment Trust Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended March 31, 2022; File No. 811-23418 John Hancock Funds II Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended July 31, 2022 and Form N-CSR Annual Reports to Shareholders ("Form N-CSR") August 31, 2022; File No. 811-00560 and 811-21779
Dear Ms. Rotter:
This letter responds to the comments of the Staff of the Securities and Exchange Commission ("SEC"), which were conveyed to us by telephone on March 24, 2023 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.
Open End Funds
1.Comment: For those funds that had exposure to derivatives during the last fiscal year end but did not discuss the effect of derivatives in Management's Discussion of Fund Performance (MDFP), please confirm that such usage did not have a material impact on performance or explain why the MDFP did not include a discussion regarding the derivative usage (Count # from Annex A - 3, 4, 8, 9, 15, and 21).
•3 – John Hancock Funds II Emerging Markets Debt Fund
•4 - John Hancock Funds II Emerging Markets Fund
•8 - John Hancock Funds II International Small Company Fund
•9 - John Hancock Funds II Multi-Asset High Income Fund
•15 - John Hancock Funds II Floating Rate Income Fund
•21 - John Hancock Funds II High Yield Fund
Securities and Exchange Commission
April 14, 2023
Page 2 of 7
Response: We confirm that derivatives usage for the identified funds did not have a material impact on performance.
2.Comment: The performance graph for John Hancock GA Mortgage Trust begins 1/14/2019, the total returns chart, Financial Highlights, and report of Independent Registered Accounting Firm report has 1/11/2019.
Response: This was a typographical error in the performance graph, and it was corrected in the most recent annual report as of 12/31/2022 filed on March 7, 2023. The fund's performance figures were not impacted as a result of this date revision.
3.Comment: Portfolio objective noted in the prospectus versus the disclosure in the MDFP is not consistent for the John Hancock Fund II Fundamental Global Franchise Fund, please explain the difference.
Response: Disclosure of investment objective on page 2 and within Organization note is consistent with the prospectus. Commentary within the MDFP is not a statement of the Fund's investment objective and policies but rather the view of the portfolio manager of the Fund's performance over the specified period. This does not and is not intended to reflect any change in the investment objective and policies of the Fund and the Fund is managed in accordance with these.
4.Comment: John Hancock Funds II Emerging Market Debt Fund has been identified in the annual report as a non-diversified fund; however it appears the fund is operating as a diversified fund. If fund has been operation as diversified for more than three years, please confirm that the fund will receive shareholder approval prior to changing its status back to non-diversified.
Response: We confirm the John Hancock Funds II Emerging Markets Debt Fund is a non-diversified fund. The fund has not operated as a diversified fund for more than three years.
5.Comment: The Staff was unable to find any information about the John Hancock GA Mortgage Trust on the Registrants' website. Please explain in correspondence where a shareholder is able to review fund documents and fund information. If located on the website, please provide a direct link in response.
Response: The fund is only sold in private placements to qualified institutional investors. Therefore, the fund is not listed on advisor's website.
6.Comment: John Hancock Funds II Multi-Index Preservation Funds - Class I total returns in the performance chart do not agree to the total returns in the Financial Highlights, please explain the difference and consider including a note in the notes to the performance chart going forward.
Response: The Financial Highlights total return for Class I is presented since class inception (stub period) while total return figures in the performance table shows a full year utilizing the most similar class for the period before Class I opened (Class 1 in this instance) as disclosed in Footnote 1 "Class I shares were first offered on 10/21/21. Returns prior to this date are those of Class 1 shares that have not been adjusted for class-specific expenses; otherwise, returns would vary."
7.Comment: Average annual total returns as of 7/31/2022 for John Hancock Funds II Multi-Asset Absolute Return Fund (page 2 of report) uses a blended benchmark of 30% MSCI All Country World Index and 70% Bloomberg Global Aggregate Bond USD Hedged Index. The MDFP narrative notes that the fund declined modestly and underperformed the return of the primary benchmark (Intercontinental Exchange (ICE) Bank of America (BofA) 0-3 Month U.S. Treasury Bill Index). The total returns for the period 7/31/22 table and the performance graph include all three indices.Please explain the differences in the disclosure.
Response: The benchmark presented in the bar graph on page 2 is the fund's secondary benchmark. The MDFP discusses performance against the fund's primary benchmark, ICE Bank of America 0-3 Month U.S. Treasury Bill
Securities and Exchange Commission
April 14, 2023
Page 3 of 7
Index, and the performance tables and line graph present the fund's primary benchmark as well as the secondary benchmark for comparative purposes.
8.Comment: Please confirm current Form N-CSR will be used going forward, the most recent version of the form can be found on the SEC website which includes Item 4(i) and Item 4(j) that are required to be addressed whether the response is N/A. Applies across the fund complex. Form was updated in January 2022.
Response: We confirm and will use the updated form effective immediately for all future filings.
* * *
We hope that these foregoing responses adequately address the Staff's comments. If you have any questions, please do not hesitate to contact me at (617) 543-9634.
Sincerely,
/s/ Salvatore Schiavone Salvatore Schiavone Treasurer
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filename1.htm
March 2023 comments
John Hancock Group of Funds
200 Berkeley Street
Boston, Massachusetts 02116
April 14, 2023
VIA EDGAR
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Mindy Rotter
Re: Closed End Fund
John Hancock GA Mortgage Trust Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended December 31, 2021; File No. 811-23418
Open End Funds
John Hancock Investment Trust Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended March 31, 2022; File No. 811-23418
John Hancock Funds II Form N-CSR Annual Reports to Shareholders ("Form N-CSR") for the Period Ended July 31, 2022 and Form N-CSR Annual Reports to Shareholders ("Form N-CSR") August 31, 2022; File No. 811-00560 and 811-21779
Dear Ms. Rotter:
This letter responds to the comments of the Staff of the Securities and Exchange Commission ("SEC"), which were conveyed to us by telephone on March 24, 2023 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.
Open End Funds
1.Comment: For those funds that had exposure to derivatives during the last fiscal year end but did not discuss the effect of derivatives in Management's Discussion of Fund Performance (MDFP), please confirm that such usage did not have a material impact on performance or explain why the MDFP did not include a discussion regarding the derivative usage (Count # from Annex A - 3, 4, 8, 9, 15, and 21).
•3 – John Hancock Funds II Emerging Markets Debt Fund
•4 - John Hancock Funds II Emerging Markets Fund
•8 - John Hancock Funds II International Small Company Fund
•9 - John Hancock Funds II Multi-Asset High Income Fund
•15 - John Hancock Funds II Floating Rate Income Fund
•21 - John Hancock Funds II High Yield Fund
Securities and Exchange Commission
April 14, 2023
Page 2 of 7
Response: We confirm that derivatives usage for the identified funds did not have a material impact on performance.
2.Comment: The performance graph for John Hancock GA Mortgage Trust begins 1/14/2019, the total returns chart, Financial Highlights, and report of Independent Registered Accounting Firm report has 1/11/2019.
Response: This was a typographical error in the performance graph, and it was corrected in the most recent annual report as of 12/31/2022 filed on March 7, 2023. The fund's performance figures were not impacted as a result of this date revision.
3.Comment: Portfolio objective noted in the prospectus versus the disclosure in the MDFP is not consistent for the John Hancock Fund II Fundamental Global Franchise Fund, please explain the difference.
Response: Disclosure of investment objective on page 2 and within Organization note is consistent with the prospectus. Commentary within the MDFP is not a statement of the Fund's investment objective and policies but rather the view of the portfolio manager of the Fund's performance over the specified period. This does not and is not intended to reflect any change in the investment objective and policies of the Fund and the Fund is managed in accordance with these.
4.Comment: John Hancock Funds II Emerging Market Debt Fund has been identified in the annual report as a non-diversified fund; however it appears the fund is operating as a diversified fund. If fund has been operation as diversified for more than three years, please confirm that the fund will receive shareholder approval prior to changing its status back to non-diversified.
Response: We confirm the John Hancock Funds II Emerging Markets Debt Fund is a non-diversified fund. The fund has not operated as a diversified fund for more than three years.
5.Comment: The Staff was unable to find any information about the John Hancock GA Mortgage Trust on the Registrants' website. Please explain in correspondence where a shareholder is able to review fund documents and fund information. If located on the website, please provide a direct link in response.
Response: The fund is only sold in private placements to qualified institutional investors. Therefore, the fund is not listed on advisor's website.
6.Comment: John Hancock Funds II Multi-Index Preservation Funds - Class I total returns in the performance chart do not agree to the total returns in the Financial Highlights, please explain the difference and consider including a note in the notes to the performance chart going forward.
Response: The Financial Highlights total return for Class I is presented since class inception (stub period) while total return figures in the performance table shows a full year utilizing the most similar class for the period before Class I opened (Class 1 in this instance) as disclosed in Footnote 1 "Class I shares were first offered on 10/21/21. Returns prior to this date are those of Class 1 shares that have not been adjusted for class-specific expenses; otherwise, returns would vary."
7.Comment: Average annual total returns as of 7/31/2022 for John Hancock Funds II Multi-Asset Absolute Return Fund (page 2 of report) uses a blended benchmark of 30% MSCI All Country World Index and 70% Bloomberg Global Aggregate Bond USD Hedged Index. The MDFP narrative notes that the fund declined modestly and underperformed the return of the primary benchmark (Intercontinental Exchange (ICE) Bank of America (BofA) 0-3 Month U.S. Treasury Bill Index). The total returns for the period 7/31/22 table and the performance graph include all three indices.Please explain the differences in the disclosure.
Response: The benchmark presented in the bar graph on page 2 is the fund's secondary benchmark. The MDFP discusses performance against the fund's primary benchmark, ICE Bank of America 0-3 Month U.S. Treasury Bill
Securities and Exchange Commission
April 14, 2023
Page 3 of 7
Index, and the performance tables and line graph present the fund's primary benchmark as well as the secondary benchmark for comparative purposes.
8.Comment: Please confirm current Form N-CSR will be used going forward, the most recent version of the form can be found on the SEC website which includes Item 4(i) and Item 4(j) that are required to be addressed whether the response is N/A. Applies across the fund complex. Form was updated in January 2022.
Response: We confirm and will use the updated form effective immediately for all future filings.
* * *
We hope that these foregoing responses adequately address the Staff's comments. If you have any questions, please do not hesitate to contact me at (617) 543-9634.
Sincerely,
/s/ Salvatore Schiavone Salvatore Schiavone Treasurer
John Hancock Group of Funds
Securities and Exchange Commission
April 14, 2023
Page 4 of 7
Annex A
Count
Series ID
FYE
File #
Series Name
Registrant Name
1
S000023552
8/31/2022
811-21779
Alternative Asset Allocation Fund
John Hancock Funds II
2
S000003311
8/31/2022
811-21779
Blue Chip Growth Fund
John Hancock Funds II
3
S000027304
8/31/2022
811-21779
Emerging Markets Debt Fund
John Hancock Funds II
4
S000017260
8/31/2022
811-21779
Emerging Markets Fund
John Hancock Funds II
5
S000003317
8/31/2022
811-21779
Equity Income Fund
John Hancock Funds II
6
S000037602
8/31/2022
811-21779
Fundamental Global Franchise
John Hancock Funds II
Fund
7
S000040959
8/31/2022
811-21779
Global Equity Fund
John Hancock Funds II
8
S000009779
8/31/2022
811-21779
International Small Company
John Hancock Funds II
Fund
9
S000045160
8/31/2022
811-21779
Multi-Asset High Income Fund
John Hancock Funds II
10
S000003360
8/31/2022
811-21779
New Opportunities Fund
John Hancock Funds II
11
S000003356
8/31/2022
811-21779
Real Estate Securities Fund
John Hancock Funds II
12
S000003363
8/31/2022
811-21779
Small Cap Growth Fund
John Hancock Funds II
13
S000009819
8/31/2022
811-21779
Small Cap Value Fund
John Hancock Funds II
14
S000009820
8/31/2022
811-21779
Strategic Income Opportunities
John Hancock Funds II
Fund
15
S000020234
8/31/2022
811-21779
Floating Rate Income Fund
John Hancock Funds II
16
S000003319
8/31/2022
811-21779
Opportunistic Fixed Income Fund
John Hancock Funds II
17
S000003312
8/31/2022
811-21779
Capital Appreciation Fund
John Hancock Funds II
18
S000030799
8/31/2022
811-21779
Capital Appreciation Value Fund
John Hancock Funds II
19
S000003313
8/31/2022
811-21779
Core Bond Fund
John Hancock Funds II
20
S000034046
8/31/2022
811-21779
Health Sciences Fund
John Hancock Funds II
Securities and Exchange Commission
April 14, 2023
Page 5 of 7
21
S000003320
8/31/2022
811-21779
High Yield Fund
John Hancock Funds II
22
S000055170
8/31/2022
811-21779
International Strategic Equity
John Hancock Funds II
Allocation Fund
23
S000024677
8/31/2022
811-21779
Mid Value Fund
John Hancock Funds II
24
S000009815
8/31/2022
811-21779
Science & Technology Fund
John Hancock Funds II
25
S000055171
8/31/2022
811-21779
U.S. Sector Rotation Fund
John Hancock Funds II
26
S000069425
8/31/2022
811-21779
Multimanager 2065 Lifetime
John Hancock Funds II
Portfolio
27
S000053254
8/31/2022
811-21779
Multimanager 2060 Lifetime
John Hancock Funds II
Portfolio
28
S000044502
8/31/2022
811-21779
Multimanager 2055 Lifetime
John Hancock Funds II
Portfolio
29
S000013659
8/31/2022
811-21779
Multimanager 2050 Lifetime
John Hancock Funds II
Portfolio
30
S000013658
8/31/2022
811-21779
Multimanager 2045 Lifetime
John Hancock Funds II
Portfolio
31
S000013657
8/31/2022
811-21779
Multimanager 2040 Lifetime
John Hancock Funds II
Portfolio
32
S000013656
8/31/2022
811-21779
Multimanager 2035 Lifetime
John Hancock Funds II
Portfolio
33
S000013655
8/31/2022
811-21779
Multimanager 2030 Lifetime
John Hancock Funds II
Portfolio
34
S000013654
8/31/2022
811-21779
Multimanager 2025 Lifetime
John Hancock Funds II
Portfolio
35
S000013653
8/31/2022
811-21779
Multimanager 2020 Lifetime
John Hancock Funds II
Portfolio
36
S000013652
8/31/2022
811-21779
Multimanager 2015 Lifetime
John Hancock Funds II
Portfolio
37
S000013649
8/31/2022
811-21779
Multimanager 2010 Lifetime
John Hancock Funds II
Portfolio
38
S000069424
8/31/2022
811-21779
Multi-Index 2065 Preservation
John Hancock Funds II
Portfolio
39
S000053253
8/31/2022
811-21779
Multi-Index 2060 Preservation
John Hancock Funds II
Portfolio
40
S000044501
8/31/2022
811-21779
Multi-Index 2055 Preservation
John Hancock Funds II
Portfolio
Securities and Exchange Commission
April 14, 2023
Page 6 of 7
41
S000028818
8/31/2022
811-21779
Multi-Index 2050 Preservation
John Hancock Funds II
Portfolio
42
S000028817
8/31/2022
811-21779
Multi-Index 2045 Preservation
John Hancock Funds II
Portfolio
43
S000028826
8/31/2022
811-21779
Multi-Index 2040 Preservation
John Hancock Funds II
Portfolio
44
S000028825
8/31/2022
811-21779
Multi-Index 2035 Preservation
John Hancock Funds II
Portfolio
45
S000028824
8/31/2022
811-21779
Multi-Index 2030 Preservation
John Hancock Funds II
Portfolio
46
S000028823
8/31/2022
811-21779
Multi-Index 2025 Preservation
John Hancock Funds II
Portfolio
47
S000028821
8/31/2022
811-21779
Multi-Index Income Preservation
John Hancock Funds II
Portfolio
48
S000069423
8/31/2022
811-21779
Multi-Index 2065 Lifetime
John Hancock Funds II
Portfolio
49
S000053255
8/31/2022
811-21779
Multi-Index 2060 Lifetime
John Hancock Funds II
Portfolio
50
S000044503
8/31/2022
811-21779
Multi-Index 2055 Lifetime
John Hancock Funds II
Portfolio
51
S000042855
8/31/2022
811-21779
Multi-Index 2050 Lifetime
John Hancock Funds II
Portfolio
52
S000042854
8/31/2022
811-21779
Multi-Index 2045 Lifetime
John Hancock Funds II
Portfolio
53
S000042853
8/31/2022
811-21779
Multi-Index 2040 Lifetime
John Hancock Funds II
Portfolio
54
S000042852
8/31/2022
811-21779
Multi-Index 2035 Lifetime
John Hancock Funds II
Portfolio
55
S000042851
8/31/2022
811-21779
Multi-Index 2030 Lifetime
John Hancock Funds II
Portfolio
56
S000042850
8/31/2022
811-21779
Multi-Index 2025 Lifetime
John Hancock Funds II
Portfolio
57
S000042849
8/31/2022
811-21779
Multi-Index 2020 Lifetime
John Hancock Funds II
Portfolio
58
S000042848
8/31/2022
811-21779
Multi-Index 2015 Lifetime
John Hancock Funds II
Portfolio
59
S000042847
8/31/2022
811-21779
Multi-Index 2010 Lifetime
John Hancock Funds II
Portfolio
60
S000043433
8/31/2022
811-21779
Multi-Index Lifestyle Aggressive
John Hancock Funds II
Portfolio
Securities and Exchange Commission
April 14, 2023
Page 7 of 7
61
S000043436
8/31/2022
811-21779
Multi-Index Lifestyle Growth
John Hancock Funds II
Portfolio
62
S000043434
8/31/2022
811-21779
Multi-Index Lifestyle Balanced
John Hancock Funds II
Portfolio
63
S000043437
8/31/2022
811-21779
Multi-Index Lifestyle Moderate
John Hancock Funds II
Portfolio
64
S000043435
8/31/2022
811-21779
Multi-Index Lifestyle
John Hancock Funds II
Conservative Portfolio
65
S000029556
7/31/2022
811-21779
Absolute Return Currency Fund
John Hancock Funds II
66
S000032685
7/31/2022
811-21779
Fundamental All Cap Core Fund
John Hancock Funds II
67
S000035066
7/31/2022
811-21779
Multi-Asset Absolute Return
John Hancock Funds II
Fund
68
S000061352
3/31/2022
811-00560
John Hancock Diversified Real
John Hancock Investment Trust
Assets Fund
69
S000072133
3/31/2022
811-00560
John Hancock Mid Cap Growth
John Hancock Investment Trust
Fund
70
CEF0010705
12/31/2021
811-23418
John Hancock GA Mortgage Trust
John Hancock GA Mortgage Trust