July 26, 2024

VIA E-mail

Mr. Christopher Sechler, Esq.
Manulife Private Credit Plus Fund
200 Berkeley Street
Boston, MA 02116

        Re:     Manulife Private Credit Plus Fund
                File Nos. 333-280481 and 811-23896

Dear Mr. Sechler:

        On June 26, 2024, Manulife Private Credit Plus Fund (the    Fund   )
filed a registration
statement on Form N-2. We have reviewed the registration statement and have
provided our
comments below. Where a comment is made with regard to disclosure in one
location, it is
applicable to all similar disclosure appearing elsewhere in the registration
statement. All
capitalized terms not otherwise defined herein have the meaning given to them
in the registration
statement.

Investment Strategies, page 1

   1.    Please confirm in your response that the Fund will not invest more
than 15% of its net
         assets in hedge funds and/or private equity funds that rely on
Sections 3(c)(1) or 3(c)(7)
         of the 1940 Act.

Fees and Expenses, page 8

   2.    Please confirm in your response that the fees presented represent
current fees in
         accordance with Form N-2, Item 3.

   3.    Please explain in your response whether the Advisor may recoup from
the Fund any
         waived amounts or reimbursed expenses. If yes, please revise footnote
5 to the fee table
         to include such disclosure that explains the recoupment arrangement.

Example, page 9

   4.    The fee table does not appear to disclose a redemption fee for any of
the share classes
         presented. Please explain in correspondence the following disclosures
noted in the
         expense example:
 Mr. Christopher Sechler, Esq.
Manulife Private Credit Plus Fund
July 26, 2024
Page 2


           a.    The following example illustrates the expenses that you would
pay on a $1,000
              investment in Shares, for the time periods indicated and then
redeem or hold all of
              your Shares at the end of those periods.
           b. The expense example columns are labeled    Sold    and    Not
sold    for all share
              classes presented and all amounts are the same for each share
class disclosed.

Financial Highlights, page 11

   5.    Please confirm in your response that a hyperlink to the Fund   s
financial statements will
         be provided in a pre-effective amendment.

Risk Factors, page 15

   6.    Please reorder the risk factors so that they are in order of relative
importance. See ADI
         2019-08 - Improving Principal Risks Disclosure, available on the
Commission   s
         website.

Credit and Counterparty Risk, page 16

   7.    Please identify non-investment grade bonds as    junk    bonds, as
they are commonly
         known.

Portfolio Management Information, page 62

   8.    Please revise this section to include a 5-year business history per
Item 9.1.c of
         Form N-2.

The Subadvisory Agreement, page 63

   9.    Please disclose the subadvisory fee.

Repurchases of Share, page 72

   10.   Please revise disclosure in the last sentence of the second paragraph
of this subsection
         to provide that payment in repurchase offers will be made promptly
after the expiration
         of the repurchase offer in accordance with Rule 13e-4 under the 1934
Act. This
         comment also applies to the last sentence of the second paragraph of
the next
         subsection.

Declaration of Trust

   11.   Please disclose the exclusive federal forum provision in Section
2.11(b) of this exhibit
         and the corresponding risks (e.g., that shareholders may have to bring
suit in an
         inconvenient and less favorable forum and that there is question
regarding the
 Mr. Christopher Sechler, Esq.
Manulife Private Credit Plus Fund
July 26, 2024
Page 3


             enforceability of this provision since the 1940 Act permits
shareholder to bring claims
             arising from that Act in both state and federal courts).

      12.    Please disclose the provision of Section 2.11(d) of this exhibit
(relating to the
             requirement of a pre-suit demand with respect to derivative
claims).

      13.    Please revise this exhibit to state that Section 2.11(g) does not
apply to claims arising
             under the federal securities laws. Please also disclose in an
appropriate location in the
             prospectus the provision and that the provision does not apply to
claims arising under
             the federal securities laws.

Signatures

      14.    Please advise why Manulife Private Credit Fund is executing the
Form N-2.

                                            *   *    *    *   *

       We note that portions of the filing are incomplete. We may have
additional comments on
such portions when you complete them, on disclosures made in response to this
letter, on
information supplied in your response letter, or on exhibits added in any
amendments.

       A response to this letter should be in the form of an amendment. The
amendment should
be accompanied by a supplemental letter that includes your responses to each of
these comments.
Where no change will be made in the filing in response to a comment, please
indicate this fact in
your supplemental letter and briefly state the basis for your position.

        We remind you that the Fund and its management are responsible for the
accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action, or
absence of
action by the staff.

            Should you have any questions, please contact me at (202) 551-3503.

                                                          Sincerely,

                                                          /s/ David L. Orlic

                                                          David L. Orlic
                                                          Senior Counsel



cc:         Pablo Javier Man, K&L Gates LLP
            Michael J. Spratt, Assistant Director, U.S. Securities and Exchange
Commission
            Jennifer B. McHugh, Senior Special Counsel, U.S. Securities and
Exchange Commission