Correspondence 0000726865-25-000457 from LINCOLN NATIONAL LIFE INSURANCE CO /IN/ (CIK 0000726865)
LINCOLN NATIONAL LIFE INSURANCE CO /IN/ (CIK 0000726865)
Date: June 12, 2025 · CIK: 0000726865 · Accession: 0000726865-25-000457
AI Filing Summary & Sentiment
File numbers found in text: 000-55871
Referenced dates: June 3, 2025
Letter
Document
June 12, 2025
VIA EDGAR CORRESPONDENCE
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Finance
100 F Street, NE
Washington, DC 20549
Attention: Lory Empie and Robert Klein
RE: The Lincoln National Life Insurance Company
Form 10-K for the Fiscal Year Ended December 31, 2024
File No. 000-55871
Ladies and Gentlemen:
This letter is in response to the letter dated June 3, 2025, from the staff of the Securities and Exchange Commission Division of Corporation Finance (the “Staff”) concerning the Form 10-K of The Lincoln National Life Insurance Company (the “Company,” “we” or “our”) for the year ended December 31, 2024. Our reply refers to the specific comments in the Staff’s letter.
The comments of the Staff are set forth in bold italicized text below, and the Company’s responses are set forth in plain text immediately following each comment. The Company’s proposed disclosure changes are set forth in underlined italicized text below.
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.
In response to the Staff’s comment, the Company will revise its disclosure in future filings to describe and quantify the individual components of this adjustment. Using the year ended December 31, 2024, as an example, we will include disclosure in footnote form within our tabular reconciliations substantially similar to the following:
Net annuity product features, pre-tax, in millions(1) 2,085
(1) Includes the following: changes in market risk benefits of $929 million; income allocated to support the cost of hedging or future benefits of $676 million; and changes in the fair value of the embedded derivative liabilities and the associated index options for our indexed annuity products of $480 million.
In addition, in response to the Staff’s comment, while the Company does not currently present net annuity product features, pre-tax, as an adjustment for a non-GAAP measure, to the extent the Company does so in the future, we will provide clear disclosure explaining why management believes the exclusion of net annuity product features is meaningful and provides useful information to investors.
Notes to Consolidated Financial Statements
10. Separate Accounts, page 121
2. We note your disclosure showing Mutual funds and collective investment trusts as the majority investment category within separate accounts. In future filings and where 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.
In response to the Staff’s comment, the Company will revise its disclosure in future filings and where appropriate to further disaggregate the mutual funds and collective investment trusts category in accordance with ASC 944-80-55-17 Example 3, in a manner substantially similar to the following (in millions) (disaggregated groupings identified in italicized text):
As of
December 31,
Mutual funds and collective investment trusts:
Equity funds:
Domestic $ 77,740
International 16,282
Other equity funds 1,403
Balanced funds 45,683
Bond funds 23,399
Money market funds 1,931
Other funds 1,321
Exchange-traded funds 336
Fixed maturity AFS securities 161
Cash and invested cash 12
Other investments 170
Total separate account assets $ 168,438
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 response to the Staff’s comment, the Company will revise its disclosure that follows each of its tabular liability presentations in future filings to instead include a footnote to the “effect of actual variances from expected experience” line item that discusses actual experience attributable to assumptions such as mortality, morbidity and lapses compared to expected experience for the period, in each case to the extent that such variance materially impacted the liability for the period. Using the year ended December 31, 2024, as an example, the Company will include disclosure substantially similar to the following:
LFPB: Traditional Life
Line item within the rollforward of present value of expected net premiums, in millions:
Effect of actual variances from expected experience(1) (45)
Line item within the rollforward of present value of expected future policy benefits, in millions:
Effect of actual variances from expected experience(1) (68)
(1) For the year ended December 31, 2024, the actual to expected reserve impact on expected net premiums was attributable primarily to mortality, which unfavorably impacted the liability by $60 million, which was partially offset by $15 million primarily related to policyholder behavior; the actual to expected reserve impact on expected future policy benefits was attributable primarily to mortality, which favorably impacted the liability by $96 million, which was partially offset by $28 million primarily related to policyholder behavior.
Liability for Future Claims: Group Protection
Line item within the rollforward of liability for future claims, in millions:
Effect of actual variances from expected experience(1) (345)
(1) Generally, the experience exhibited for the Group Protection business relates to morbidity and, to a lesser extent, mortality. Group Protection long-duration products have limited exposure to lapse risk, as the liabilities for future policyholder benefits are limited to those associated with claim reserves. For the year ended December 31, 2024, morbidity comprised substantially all of the favorable effect of actual variances from expected experience, as we experienced more favorable reported incidence and claim terminations than assumed.
Additional Liabilities for Other Insurance Benefits: UL and Other
Line item within the rollforward of additional liabilities for other insurance benefits, in millions:
Effect of actual variances from expected experience(1) 288
(1) For the year ended December 31, 2024, the actual to expected reserve impact was attributable to mortality, which unfavorably impacted the liability by $273 million, and other items that unfavorably impacted the liability by $15 million.
****
The Company acknowledges that the Company and its management are responsible for the accuracy and adequacy of its disclosures, notwithstanding any review, comments, action or absence of action by the Staff.
If you have any questions regarding our response, please contact Emily Pickard, Vice President, Head of GAAP and SEC Reporting, at (336) 691-3955.
Sincerely,
/s/ Adam M. Cohen
Show Raw Text
CORRESP
1
filename1.htm
Document
June 12, 2025
VIA EDGAR CORRESPONDENCE
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Finance
100 F Street, NE
Washington, DC 20549
Attention: Lory Empie and Robert Klein
RE: The Lincoln National Life Insurance Company
Form 10-K for the Fiscal Year Ended December 31, 2024
File No. 000-55871
Ladies and Gentlemen:
This letter is in response to the letter dated June 3, 2025, from the staff of the Securities and Exchange Commission Division of Corporation Finance (the “Staff”) concerning the Form 10-K of The Lincoln National Life Insurance Company (the “Company,” “we” or “our”) for the year ended December 31, 2024. Our reply refers to the specific comments in the Staff’s letter.
The comments of the Staff are set forth in bold italicized text below, and the Company’s responses are set forth in plain text immediately following each comment. The Company’s proposed disclosure changes are set forth in underlined italicized text below.
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.
1
In response to the Staff’s comment, the Company will revise its disclosure in future filings to describe and quantify the individual components of this adjustment. Using the year ended December 31, 2024, as an example, we will include disclosure in footnote form within our tabular reconciliations substantially similar to the following:
Net annuity product features, pre-tax, in millions(1) 2,085
(1) Includes the following: changes in market risk benefits of $929 million; income allocated to support the cost of hedging or future benefits of $676 million; and changes in the fair value of the embedded derivative liabilities and the associated index options for our indexed annuity products of $480 million.
In addition, in response to the Staff’s comment, while the Company does not currently present net annuity product features, pre-tax, as an adjustment for a non-GAAP measure, to the extent the Company does so in the future, we will provide clear disclosure explaining why management believes the exclusion of net annuity product features is meaningful and provides useful information to investors.
Notes to Consolidated Financial Statements
10. Separate Accounts, page 121
2. We note your disclosure showing Mutual funds and collective investment trusts as the majority investment category within separate accounts. In future filings and where 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.
2
In response to the Staff’s comment, the Company will revise its disclosure in future filings and where appropriate to further disaggregate the mutual funds and collective investment trusts category in accordance with ASC 944-80-55-17 Example 3, in a manner substantially similar to the following (in millions) (disaggregated groupings identified in italicized text):
As of
December 31,
2024
Mutual funds and collective investment trusts:
Equity funds:
Domestic $ 77,740
International 16,282
Other equity funds 1,403
Balanced funds 45,683
Bond funds 23,399
Money market funds 1,931
Other funds 1,321
Exchange-traded funds 336
Fixed maturity AFS securities 161
Cash and invested cash 12
Other investments 170
Total separate account assets $ 168,438
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.
3
In response to the Staff’s comment, the Company will revise its disclosure that follows each of its tabular liability presentations in future filings to instead include a footnote to the “effect of actual variances from expected experience” line item that discusses actual experience attributable to assumptions such as mortality, morbidity and lapses compared to expected experience for the period, in each case to the extent that such variance materially impacted the liability for the period. Using the year ended December 31, 2024, as an example, the Company will include disclosure substantially similar to the following:
LFPB: Traditional Life
Line item within the rollforward of present value of expected net premiums, in millions:
Effect of actual variances from expected experience(1) (45)
Line item within the rollforward of present value of expected future policy benefits, in millions:
Effect of actual variances from expected experience(1) (68)
(1) For the year ended December 31, 2024, the actual to expected reserve impact on expected net premiums was attributable primarily to mortality, which unfavorably impacted the liability by $60 million, which was partially offset by $15 million primarily related to policyholder behavior; the actual to expected reserve impact on expected future policy benefits was attributable primarily to mortality, which favorably impacted the liability by $96 million, which was partially offset by $28 million primarily related to policyholder behavior.
Liability for Future Claims: Group Protection
Line item within the rollforward of liability for future claims, in millions:
Effect of actual variances from expected experience(1) (345)
(1) Generally, the experience exhibited for the Group Protection business relates to morbidity and, to a lesser extent, mortality. Group Protection long-duration products have limited exposure to lapse risk, as the liabilities for future policyholder benefits are limited to those associated with claim reserves. For the year ended December 31, 2024, morbidity comprised substantially all of the favorable effect of actual variances from expected experience, as we experienced more favorable reported incidence and claim terminations than assumed.
4
Additional Liabilities for Other Insurance Benefits: UL and Other
Line item within the rollforward of additional liabilities for other insurance benefits, in millions:
Effect of actual variances from expected experience(1) 288
(1) For the year ended December 31, 2024, the actual to expected reserve impact was attributable to mortality, which unfavorably impacted the liability by $273 million, and other items that unfavorably impacted the liability by $15 million.
****
The Company acknowledges that the Company and its management are responsible for the accuracy and adequacy of its disclosures, notwithstanding any review, comments, action or absence of action by the Staff.
If you have any questions regarding our response, please contact Emily Pickard, Vice President, Head of GAAP and SEC Reporting, at (336) 691-3955.
Sincerely,
/s/ Adam M. Cohen
Adam M. Cohen
Senior Vice President, Chief Accounting Officer and Treasurer
cc: Christopher Neczypor, Executive Vice President and Chief Financial Officer
Emily Pickard, Vice President, Head of GAAP and SEC Reporting
5