SEC Comment Letter for LINCOLN NATIONAL CORP (LNC, LNC-PD) (CIK 0000059558) (LNC) — Apr 15, 2008
LINCOLN NATIONAL CORP (LNC, LNC-PD) (CIK 0000059558)
Date: April 15, 2008 · CIK: 0000059558 · Accession: 0000000000-08-019508
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-06028
Letter
Via Facsimile and U.S. Mail Mail Stop 6010 April 15, 2008 Frederick J. Crawford Sr. Vice President and Ch ief Financial Officer Lincoln National Corporation 150 N. Radnor Chester Road, Suite A305 Radnor Pennsylvania 19087
Re: Lincoln National Corporation Form 10-K for Fiscal Year Ended December 31, 2007 Filed February 29, 2008 File No. 001-06028
Dear Mr. Crawford:
We have reviewed your filing and have the following comment. In our comment, we ask you to provide us with information to better understand your disclosure. Where a comment requests you to revise disclosure, the information you provide should show us what the revised disclosure will look like a nd identify the annual or quarterly filing, as applicable, in which you intend to first incl ude it. If you do not believe that revised disclosure is necessary, e xplain the reason in your res ponse. After reviewing the information provided, we may raise additional comments and/or request that you amend your filing.
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 filings. 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.
Frederick J. Crawford Lincoln National Corporation April 15, 2008 Page 2 Form 10-K – December 31, 2007
Item 8. Financial Statements and Supplementary Data
Notes To Consolidated Financial Statements
5. Derivative Instruments
All Other Derivative Instruments
Call Options (based on S&P 500 Index), page 162
1. Your disclosure related to these call opti ons seems to indicate that you record the fair value of the index option before it is actually purchased. Please provide us your analysis of the applicable authoritativ e literature that supports this treatment or revise the disclosure to clarify your description of this investment strategy.
* * * *
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provide the request ed information. Detailed le tters greatly facilitate our review. Please furnish the letter to us via EDGAR under the form type label CORRESP.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certain that the filings include all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comment, please provide , in your letter, a statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in the filings; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and • the company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States.
Frederick J. Crawford Lincoln National Corporation April 15, 2008 Page 3 In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filings or in response to our comments on your filings.
Please contact James Peklenk, Staff A ccountant, at (202) 551-3661, 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.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief
Accountant
Show Raw Text
Via Facsimile and U.S. Mail
Mail Stop 6010
April 15, 2008
Frederick J. Crawford
Sr. Vice President and Ch ief Financial Officer
Lincoln National Corporation
150 N. Radnor Chester Road, Suite A305
Radnor Pennsylvania 19087
Re: Lincoln National Corporation
Form 10-K for Fiscal Year Ended December 31, 2007
Filed February 29, 2008
File No. 001-06028
Dear Mr. Crawford:
We have reviewed your filing and have the following comment. In our comment,
we ask you to provide us with information to better understand your disclosure. Where a
comment requests you to revise disclosure, the information you provide should show us
what the revised disclosure will look like a nd identify the annual or quarterly filing, as
applicable, in which you intend to first incl ude it. If you do not believe that revised
disclosure is necessary, e xplain the reason in your res ponse. After reviewing the
information provided, we may raise additional comments and/or request that you amend
your filing.
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 filings. 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.
Frederick J. Crawford
Lincoln National Corporation
April 15, 2008 Page 2
Form 10-K – December 31, 2007
Item 8. Financial Statements and Supplementary Data
Notes To Consolidated Financial Statements
5. Derivative Instruments
All Other Derivative Instruments
Call Options (based on S&P 500 Index), page 162
1. Your disclosure related to these call opti ons seems to indicate that you record the
fair value of the index option before it is actually purchased. Please provide us your analysis of the applicable authoritativ e literature that supports this treatment
or revise the disclosure to clarify your description of this investment strategy.
* * * *
Please respond to this comment within 10 business days or tell us when you will
provide us with a response. Please furnish a letter that keys your response to our
comment and provide the request ed information. Detailed le tters greatly facilitate our
review. Please furnish the letter to us via EDGAR under the form type label CORRESP.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filings to be certain that the filings include all information required under the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In connection with responding to our comment, please provide , in your letter, a
statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in the
filings;
• staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
Frederick J. Crawford
Lincoln National Corporation
April 15, 2008 Page 3
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.
Please contact James Peklenk, Staff A ccountant, at (202) 551-3661, 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.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief
Accountant