SEC Comment Letter for LINCOLN NATIONAL CORP (LNC, LNC-PD) (CIK 0000059558) (LNC) — Sep 26, 2013
LINCOLN NATIONAL CORP (LNC, LNC-PD) (CIK 0000059558)
Date: Sept. 26, 2013 · CIK: 0000059558 · Accession: 0000000000-13-053212
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-06028
Letter
September 2 6, 2013 Via E -mail Mr. Randal J. Freitag Executive Vice President and Chief Financial Officer Lincoln National Corporation 150 N. Radnor Chester Road, Suite A305 Radnor, Pennsylvania 19087
Re: Lincoln National Corporation Form 10 -K for the Fiscal Year Ended December 31, 2012 Filed March 1, 2013 File No. 001-06028
Dear Mr. Freitag :
We have reviewed your August 2 8, 2013 response to our July 31, 2013 letter and have the following comment s.
Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe the comment s apply to your facts and circumstance s, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comment s.
After reviewing the information provide d, we may raise additional comments and/or request that you amen d your filing .
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Reinsurance, page 97
1. Given the magnitude of your reinsurance recoverable assets in relation to your equity, please provide us proposed revised disclosure to be included in future periodic reports that specifically indicates how you manage your associated credit risk. In your disclosure, at a minimum, please include the following concepts provided in your response to prior comment 1: The criteri a you use to qualify new reinsurers; How you monitor the financial strength ratings of existing reinsurers; and The amount of collateral you hold against these recoverable assets and how you have account ed for this collateral, including where it is classif ied on your balance sheet.
Mr. Randal J. Freitag Lincoln National Corporation September 2 6, 2013 Page 2
Liquidity and Capital Resources, page 98
2. Please refer to your response to prior comment 2. Please provide us a more robust response to our request in the last bullet of our comment that tells us the expected effects on your financial position and results of operations if you discontinue this strategy. In this regard, your response should tell u s the aspect(s) of and magnitude to your financial position and results of operations, including the impact of writin g less business to comply with Regulation XXX and AG38, or that you would not expect any material effects.
You may contact Ibolya Ignat, Staff Accountant, at (202) 551 -3656 or Mark Brunhofer, Senior Staff Accountant, at (202) 551 -3638 if you have questions regarding the comments. In this regard, do not hesitate to contact me at (202) 551 -3651 .
Sincerely,
/s/ Joel Parker
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September 2 6, 2013 Via E -mail Mr. Randal J. Freitag Executive Vice President and Chief Financial Officer Lincoln National Corporation 150 N. Radnor Chester Road, Suite A305 Radnor, Pennsylvania 19087 Re: Lincoln National Corporation Form 10 -K for the Fiscal Year Ended December 31, 2012 Filed March 1, 2013 File No. 001-06028 Dear Mr. Freitag : We have reviewed your August 2 8, 2013 response to our July 31, 2013 letter and have the following comment s. Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe the comment s apply to your facts and circumstance s, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comment s. After reviewing the information provide d, we may raise additional comments and/or request that you amen d your filing . Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Reinsurance, page 97 1. Given the magnitude of your reinsurance recoverable assets in relation to your equity, please provide us proposed revised disclosure to be included in future periodic reports that specifically indicates how you manage your associated credit risk. In your disclosure, at a minimum, please include the following concepts provided in your response to prior comment 1: The criteri a you use to qualify new reinsurers; How you monitor the financial strength ratings of existing reinsurers; and The amount of collateral you hold against these recoverable assets and how you have account ed for this collateral, including where it is classif ied on your balance sheet. Mr. Randal J. Freitag Lincoln National Corporation September 2 6, 2013 Page 2 Liquidity and Capital Resources, page 98 2. Please refer to your response to prior comment 2. Please provide us a more robust response to our request in the last bullet of our comment that tells us the expected effects on your financial position and results of operations if you discontinue this strategy. In this regard, your response should tell u s the aspect(s) of and magnitude to your financial position and results of operations, including the impact of writin g less business to comply with Regulation XXX and AG38, or that you would not expect any material effects. You may contact Ibolya Ignat, Staff Accountant, at (202) 551 -3656 or Mark Brunhofer, Senior Staff Accountant, at (202) 551 -3638 if you have questions regarding the comments. In this regard, do not hesitate to contact me at (202) 551 -3651 . Sincerely, /s/ Joel Parker Joel Parker Accounting Branch Chief