0000898432-20-000695.txt : 20201026 0000898432-20-000695.hdr.sgml : 20201026 20200731150510 ACCESSION NUMBER: 0000898432-20-000695 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20200731 FILER: COMPANY DATA: COMPANY CONFORMED NAME: JOHN HANCOCK VARIABLE INSURANCE TRUST CENTRAL INDEX KEY: 0000756913 IRS NUMBER: 000000000 STATE OF INCORPORATION: MA FISCAL YEAR END: 0630 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: C/O JOHN HANCOCK FUNDS STREET 2: 200 BERKELEY STREET CITY: BOSTON STATE: MA ZIP: 02116 BUSINESS PHONE: 617-663-3000 MAIL ADDRESS: STREET 1: C/O JOHN HANCOCK FUNDS STREET 2: 200 BERKELEY STREET CITY: BOSTON STATE: MA ZIP: 02116 FORMER COMPANY: FORMER CONFORMED NAME: JOHN HANCOCK TRUST DATE OF NAME CHANGE: 20050124 FORMER COMPANY: FORMER CONFORMED NAME: MANUFACTURERS INVESTMENT TRUST DATE OF NAME CHANGE: 19971022 FORMER COMPANY: FORMER CONFORMED NAME: NASL SERIES FUND INC DATE OF NAME CHANGE: 19881030 CORRESP 1 filename1.htm
 
K&L GATES LLP
STATE STREET FINANCIAL CENTER
ONE LINCOLN STREET
BOSTON, MA 02111-2950
T 617.261.3100  F 617.261.3175

July 31, 2020
VIA EDGAR
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Sonny Oh
Christina DiAngelo Fettig


Re:
John Hancock Variable Insurance Trust (the “Trust”) — File No. 333-239598
Registration Statement on Form N-14
Dear Mr. Oh and Ms. Fettig:
On behalf of the Trust, we submit this letter in response to additional comments received via email on July 31, 2020 from Christina DiAngelo Fettig of the accounting staff of the Securities and Exchange Commission (the “SEC”), and by telephone on July 31, 2020, from Sonny Oh of the SEC disclosure review staff, each with respect to the registration statement on Form N-14 (the “Registration Statement”) relating to the registration of shares of John Hancock Global Trust, a series of the Trust (the “Acquiring Fund”), in connection with the reorganization of John Hancock Global Equity Trust (the “Acquired Fund” and, together with the Acquiring Fund, the “Funds”), also a series of the Trust, with and into the Acquiring Fund (the “Reorganization”). The Registration Statement was filed with the SEC on July 1, 2020, accession no. 0001133228-20-004248.
With respect to comments received from Mr. Oh and Ms. Fettig, the Trust responds as follows:
Comment 1 — Please confirm that changes responsive to the staff’s additional comments on the Registration Statement will be made in a Rule 497 definitive filing.
Response to Comment 1 — The Trust confirms that it will make changes responsive to all of the staff’s additional comments in a Rule 497 definitive filing. In addition, the Trust has included changed pages of the Registration Statement reflecting responses to the staff's comments in Appendix A, hereto.
_____________________________________________________


Securities and Exchange Commission
July 31, 2020
Page 2 of 3

The Trust, on behalf of the Acquiring Fund, intends to file a definitive Registration Statement that will reflect the above response to the staff’s additional comments. If you have any questions, please contact me at (617) 951-9053.
Sincerely,
/s/ Abigail P. Hemnes                        
Abigail P. Hemnes
 
cc:
Betsy Anne Seel, Assistant Secretary of the Trust
   
Harsha Pulluru, Assistant Secretary of the Trust


Securities and Exchange Commission
July 31, 2020
Page 3 of 3

Appendix A

Registration Statement Changed Pages