SEC Comment Letter 0000000000-25-005825 to LINCOLN NATIONAL LIFE INSURANCE CO /IN/ (CIK 0000726865)
LINCOLN NATIONAL LIFE INSURANCE CO /IN/ (CIK 0000726865)
Date: June 3, 2025 · CIK: 0000726865 · Accession: 0000000000-25-005825
AI Filing Summary & Sentiment
File numbers found in text: 000-55871
Letter
June 3, 2025 Christopher Neczypor Executive Vice President and Chief Financial Officer The Lincoln National Life Insurance Company 1301 South Harrison Street Fort Wayne, IN 46802 Re:The Lincoln National Life Insurance Company Form 10-K for the Fiscal Year Ended December 31, 2024 File No. 000-55871 Dear Christopher Neczypor: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2024 Results of Consolidated Operations, page 47 1.We note your presentation here and elsewhere of an adjustment for net annuity product features, pre-tax as part of your reconciliation. We note that this adjustment is defined on page 157 and appears to be comprised of multiple items. Please revise your disclosures in future filings to provide additional details and quantification of the individual components that comprise this adjustment. To the extent that it is also presented as an adjustment for a non-GAAP measure, provide clear disclosure explaining why management believes the exclusion of the net annuity product features is meaningful and provides useful information to investors regarding the registrant's financial condition and results of operations. Notes to Consolidated Financial Statements 10. Separate Accounts, page 121 We note your disclosure showing Mutual funds and collective investment trusts as the majority investment category within separate accounts. In future filings and where 2.
June 3, 2025 Page 2 appropriate, please revise your disclosure to show mutual funds and collective investment trusts by investment objective or other meaningful groupings. Refer to ASC 944-80-55-17 Example 3. 12. Future Contract Benefits, page 126 3.We note your presentation of the "effect of actual variances from expected experience" within your summaries of changes in the present values of expected net premiums for LFPB on page 127, Group Protection on page 129, and UL and Other on page 130. To the extent material, please revise your disclosure in future filings to include a comparison and discussion of actual experience attributable to each of mortality, morbidity and lapses compared to what was expected for the period. For example, to the extent that there are significant favorable and/or unfavorable offsetting impacts associated with each assumption, consider quantifying or providing accompanying information to further discuss those effects of actual experience versus expected. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Lory Empie at 202-551-3714 or Robert Klein at 202-551-3847 with any questions. Sincerely, Division of Corporation Finance Office of Finance cc:Nancy Smith
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June 3, 2025
Christopher Neczypor
Executive Vice President and Chief Financial Officer
The Lincoln National Life Insurance Company
1301 South Harrison Street
Fort Wayne, IN 46802
Re:The Lincoln National Life Insurance Company
Form 10-K for the Fiscal Year Ended December 31, 2024
File No. 000-55871
Dear Christopher Neczypor:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2024
Results of Consolidated Operations, page 47
1.We note your presentation here and elsewhere of an adjustment for net annuity
product features, pre-tax as part of your reconciliation. We note that this adjustment is
defined on page 157 and appears to be comprised of multiple items. Please revise your
disclosures in future filings to provide additional details and quantification of the
individual components that comprise this adjustment. To the extent that it is also
presented as an adjustment for a non-GAAP measure, provide clear disclosure
explaining why management believes the exclusion of the net annuity product
features is meaningful and provides useful information to investors regarding the
registrant's financial condition and results of operations.
Notes to Consolidated Financial Statements
10. Separate Accounts, page 121
We note your disclosure showing Mutual funds and collective investment trusts as the
majority investment category within separate accounts. In future filings and where 2.
June 3, 2025
Page 2
appropriate, please revise your disclosure to show mutual funds and collective
investment trusts by investment objective or other meaningful groupings. Refer
to ASC 944-80-55-17 Example 3.
12. Future Contract Benefits, page 126
3.We note your presentation of the "effect of actual variances from expected
experience" within your summaries of changes in the present values of expected net
premiums for LFPB on page 127, Group Protection on page 129, and UL and Other
on page 130. To the extent material, please revise your disclosure in future filings to
include a comparison and discussion of actual experience attributable to each of
mortality, morbidity and lapses compared to what was expected for the period. For
example, to the extent that there are significant favorable and/or unfavorable
offsetting impacts associated with each assumption, consider quantifying or providing
accompanying information to further discuss those effects of actual experience versus
expected.
In closing, we remind you that the company and its management are responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of action by the staff.
Please contact Lory Empie at 202-551-3714 or Robert Klein at 202-551-3847 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Nancy Smith