SEC Division of Investment Management staff letter: John Hancock Stable Value Fund

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1940 Act Section 3(c)(11)
1933 Act Section 3(a)(2)
1934 Act Section 12(g)(2)(H)

Division of Investment Management
Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
Attention: Paul Cellupica, Esq.
Deputy Director and Chief Counsel

Re: John Hancock Stable Value Fund Collective Investment Trust

Dear Mr. Cellupica:

We are writing on behalf of (i) the John Hancock Stable Value Fund Collective Investment Trust (the "Trust"), a bank-maintained collective investment trust ("BCT") of which Global Trust Company ("GTC"), a non-depository trust company organized under the laws of the State of Maine, is the trustee (GTC, in its capacity as trustee of the Trust, the "Trustee"), and (ii) John Hancock Life Insurance Company (U.S.A.) ("JHUSA"), which has been retained as an advisor to the Trustee to assist the Trustee in its management of the Trust. The purpose of this letter is to request a letter from the staff (the "Staff") stating that it will not recommend enforcement action to the Securities and Exchange Commission (the "Commission") if, as more fully described below, certain Puerto Rico retirement plans described in section 1022(i)(1) of the Employee Retirement Income Security Act of 1974, as amended ("ERISA", and each such Puerto Rico plan, a "Puerto Rico-Only Plan"), participate, either directly or indirectly, in certain bank-maintained collective trust funds without registering such trust funds as investment companies under the Investment Company Act of 1940, as amended (the "1940 Act") in reliance on section 3(c)(11) thereof, and without registering the beneficial interests in such trust funds under the Securities Act of 1933, as amended (the "1933 Act") or the Securities Exchange Act of 1934, as amended (the "1934 Act"), in reliance on section 3(a)(2) of the 1933 Act, and section 12(g)(2)(H) of the 1934 Act.