JOHN HANCOCK TRUST
601 Congress Street
Boston, MA 02210-2805

April 6, 2011

VIA EDGAR

Alison White, Esq.
Senior Counsel
Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Re: John Hancock Trust / Post-Effective Amendment to Form N-1A
Registration Statement (Filed February 10, 2011) (File Nos. 2-94157; 811-4146)

Dear Ms. White:

This letter responds to the additional comments of the staff of the Securities and Exchange Commission (“Commission”), which were conveyed to me, Assistant Secretary of John Hancock Trust (“JHT” or the “Registrant”), by telephone on April 5, 2011 with respect to post-effective amendment No. 93 to the registration statement of JHT on Form N-1A (the “Amendment”) which was filed with the Commission via EDGAR on February 10, 2011. Capitalized terms used and not defined herein have the meanings given them in the Amendment.

The staff’s comments are set forth below. Changes in response to the staff’s comments as described below will be made in JHT’s filing pursuant to Rule 497 under the Securities Act of 1933, as amended.

Comment 1. Your response to SEC Comments dated April 4, 2011 states that JHT’s frequent trading policy does not apply to purchases and redemptions of shares of other JHT funds by the Lifestyle PS Series and this fact will be noted in the prospectus. This letter also states that Registrant believes that potential frequent trading is a Principal Risk for the Strategic Allocation Trust and the Bond PS Series and will disclose this risk in the prospectus for these two funds but that Registrant does not believe that frequent trading is a Principal Risk for other JHT funds. Please explain why frequent trading is not a Principal Risk for these other JHT funds.

          Response. Registrant does not believe frequent trading is a Principal Risk for JHT funds other than the JHT Strategic Allocation Trust and the JHT Bond PS Series. The JHT Lifestyle PS Series when redeeming shares of underlying funds anticipates redeeming assets first from the Bond PS Series and the Strategic Allocation Trust and only redeeming assets from other JHT funds (the “Other JHT Funds”) in the case of large redemption requests. Registrant believes that redemptions from Other JHT Funds will occur infrequently and only in extreme market situations. Registrant will include disclosure to this effect in the prospectus.

 *  *  * 

The Registrant acknowledges the following:

- it is responsible for the adequacy and accuracy of the disclosure in the Amendment;

- staff comments or changes to disclosure in response to staff comments on the Amendment do not foreclose the Commission from taking any action with respect to the Amendment; and

- it may not assert staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.

Please call me at 617-663-2166 if you have any questions.

Very truly yours,

/s/ Betsy Anne Seel Betsy Anne Seel,

Senior Counsel and Assistant Secretary

2