SEC Comment Letter for LINCOLN NATIONAL CORP (LNC, LNC-PD) (CIK 0000059558) (LNC) — Jul 18, 2006
LINCOLN NATIONAL CORP (LNC, LNC-PD) (CIK 0000059558)
Date: July 18, 2006 · CIK: 0000059558 · Accession: 0000000000-06-033293
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-06028
Letter
Via Facsimile and U.S. Mail Mail Stop 6010 July 18, 2006 Frederick J. Crawford Senior Vice President and Chief Financial Officer Lincoln National Corporation 1500 Market Street, Suite 300 Philadelphia, PA 19102
Re: Lincoln National Corporation Form 10-K for the Fiscal Year Ended December 31, 2005 Filed March 15, 2006 File Number: 001-06028
Dear Mr. Crawford:
We have reviewed your June 16, 2006 re sponse to our oral comment given on June 2, 2006 and have the following comment . Where indicated, we think you should revise your document in response to this co mment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detailed as nece ssary in your explanation.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for the year ended December 31, 2005
Consolidated Financial Statements, page 106
Consolidated Statements of Cash Flows, page 111
1. We are not able to concur with the conc lusion in your response that the proposed revision does not materially change the statement of cash flows. Including the increase in funds withheld liability as a financing activity does not comply with
Frederick J. Crawford Lincoln National Corporation July 18, 2006 Page 2
the requirement in SFAS 95 to include only cash transactions in the statement of cash flows. Further, cash flows from operating activities is an important measure to investors. The effect in 2003 and 2004 of including the increase in funds withheld liability in net cash flows provided by operating activities is between five and ten percent and the effect in 2005 is 12 percent. We believe this increase is material for the three years presented. Please am end your Form 10-K for the year ended December 31, 2005 to reflect th ese changes as the correction of an error.
* * * *
As appropriate, please amend your filing and respond to this comment within 10 business days or tell us when you will provi de us with a response. You may wish to provide us with marked copies of the amendm ent to expedite our review. Please furnish a cover letter with your amendment that keys your response to our comment and provides any requested information. Detailed cover letters greatly facilitate our review. Please file the letter on EDGAR under the form type la bel CORRESP. Please understand that we may have additional comments after reviewing your amendment and response to our comment.
You may contact Vanessa R obertson, Staff Accountant, at (202) 551-3649 or Jim Atkinson, Accounting Branch Chief, at (202) 551-3674 if you have any questions regarding the comment. In th is regard, do not hesitate to contact me, at (202) 551-3679.
S i n c e r e l y ,
J i m B . R o s e n b e r g Senior Assistant Chief Accountant
Show Raw Text
Via Facsimile and U.S. Mail
Mail Stop 6010
July 18, 2006
Frederick J. Crawford
Senior Vice President and
Chief Financial Officer
Lincoln National Corporation
1500 Market Street, Suite 300
Philadelphia, PA 19102
Re: Lincoln National Corporation
Form 10-K for the Fiscal Year Ended December 31, 2005
Filed March 15, 2006
File Number: 001-06028
Dear Mr. Crawford:
We have reviewed your June 16, 2006 re sponse to our oral comment given on
June 2, 2006 and have the following comment . Where indicated, we think you should
revise your document in response to this co mment. If you disagree, we will consider
your explanation as to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as nece ssary in your explanation.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for the year ended December 31, 2005
Consolidated Financial Statements, page 106
Consolidated Statements of Cash Flows, page 111
1. We are not able to concur with the conc lusion in your response that the proposed
revision does not materially change the statement of cash flows. Including the increase in funds withheld liability as a financing activity does not comply with
Frederick J. Crawford
Lincoln National Corporation
July 18, 2006
Page 2
the requirement in SFAS 95 to include only cash transactions in the statement of
cash flows. Further, cash flows from operating activities is an important measure to investors. The effect in 2003 and 2004 of including the increase in funds
withheld liability in net cash flows provided by operating activities is between
five and ten percent and the effect in 2005 is 12 percent. We believe this increase
is material for the three years presented. Please am end your Form 10-K for the
year ended December 31, 2005 to reflect th ese changes as the correction of an
error.
* * * *
As appropriate, please amend your filing and respond to this comment within 10
business days or tell us when you will provi de us with a response. You may wish to
provide us with marked copies of the amendm ent to expedite our review. Please furnish a
cover letter with your amendment that keys your response to our comment and provides
any requested information. Detailed cover letters greatly facilitate our review. Please file
the letter on EDGAR under the form type la bel CORRESP. Please understand that we
may have additional comments after reviewing your amendment and response to our comment.
You may contact Vanessa R obertson, Staff Accountant, at (202) 551-3649 or Jim
Atkinson, Accounting Branch Chief, at (202) 551-3674 if you have any questions regarding the comment. In th is regard, do not hesitate to contact me, at (202) 551-3679.
S i n c e r e l y ,
J i m B . R o s e n b e r g
Senior Assistant Chief Accountant