SEC Comment Letter for LINCOLN NATIONAL CORP (LNC, LNC-PD) (CIK 0000059558) (LNC) — Nov 4, 2013
LINCOLN NATIONAL CORP (LNC, LNC-PD) (CIK 0000059558)
Date: Nov. 4, 2013 · CIK: 0000059558 · Accession: 0000000000-13-060564
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-06028
Letter
November 4 , 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 October 10, 2013 response to our September 26, letter and have the following comment.
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 applies to your facts and circu mstances, 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.
After reviewing the information provide d, we may raise additional comments and/or request that yo u amend your filing .
Management’s Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources , page 98
1. We acknowledge your response to prior comment 2. In your response, you indicate that if disconti nued your current captive strategy, the effect on your financial position and results of operations would not be material . The following is not clear to us from your response: Your basis for that conclusion ; Why your assumption that your current captive reinsurance structures remain in place is reasonable ; Why the potential short term effects are not material including the potential effect on the dividend capacity of your insurance subsidiaries to liqu idity and capital resources ; and Why the effect in the long term is not material or, at best , unknown as your strategy for mitigating the effect appears t o include sellin g other products.
Mr. Randal J. Freitag Lincoln National Corporation November 4 , 2013 Page 2
Please provide us proposed MD&A disclosure to be included in future periodic reports that explains the consequences of the uncertainty regarding continuing your captive strategy, and its expected effects on your conso lidated future results of operations and financial position. To the extent that you do not believe that disclosure is required, please provide us your analysis under Section 501.02 of the Financial Reporting Codification regarding prospective information that support s your conclusion. In particular, address the two assessments management must make regarding a known trend, demand, commitment, event or uncertainty.
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 comment . In this regard, do not hesitate to contact me at (202) 551 -3679.
Sincerely,
/s/ Jim B. Rosenberg
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November 4 , 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 October 10, 2013 response to our September 26, letter and have the following comment. 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 applies to your facts and circu mstances, 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. After reviewing the information provide d, we may raise additional comments and/or request that yo u amend your filing . Management’s Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources , page 98 1. We acknowledge your response to prior comment 2. In your response, you indicate that if disconti nued your current captive strategy, the effect on your financial position and results of operations would not be material . The following is not clear to us from your response: Your basis for that conclusion ; Why your assumption that your current captive reinsurance structures remain in place is reasonable ; Why the potential short term effects are not material including the potential effect on the dividend capacity of your insurance subsidiaries to liqu idity and capital resources ; and Why the effect in the long term is not material or, at best , unknown as your strategy for mitigating the effect appears t o include sellin g other products. Mr. Randal J. Freitag Lincoln National Corporation November 4 , 2013 Page 2 Please provide us proposed MD&A disclosure to be included in future periodic reports that explains the consequences of the uncertainty regarding continuing your captive strategy, and its expected effects on your conso lidated future results of operations and financial position. To the extent that you do not believe that disclosure is required, please provide us your analysis under Section 501.02 of the Financial Reporting Codification regarding prospective information that support s your conclusion. In particular, address the two assessments management must make regarding a known trend, demand, commitment, event or uncertainty. 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 comment . In this regard, do not hesitate to contact me at (202) 551 -3679. Sincerely, /s/ Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant