Correspondence 0001104659-24-048653 from FARM BUREAU LIFE VARIABLE ACCOUNT (CIK 0000811713)
FARM BUREAU LIFE VARIABLE ACCOUNT (CIK 0000811713)
Date: April 18, 2024 · CIK: 0000811713 · Accession: 0001104659-24-048653
AI Filing Summary & Sentiment
File numbers found in text: 811-05068
Letter
CLINT MAY
Direct Line: 515-225-5597
E-Mail: Clint.May@fbfs.com
April 18, 2024
VIA EDGAR
Ms. Emily Rowland
Senior Counsel
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-8629
Re: Farm Bureau Life Insurance Company
Post-Effective Amendment No. 47 to Registration Statement on Form N-6
Farm Bureau Life Variable Account
File Nos. 33-12789; 811-05068
Ms. Rowland:
On behalf of Farm Bureau Life Insurance Company (the “Company”) and the Farm Bureau Life Variable Account (the “Account”), we have filed this letter as correspondence to the above-referenced Post-Effective Amendment No. 47 to the Form N-6 Registration Statement for the Account (the “Registration Statement”) with the Securities and Exchange Commission (the “Commission”) via EDGAR. This letter provides the Company’s responses to comments received from the staff (the “Staff”) of the Commission on the Registration Statement in a phone call with outside counsel for the Company on April 5, 2024. For the Staff’s convenience, each Staff comment is set forth in full below, followed by the Company’s response.
General
1. Comment: Please note that comments we give on disclosure in one section apply to other sections of the filing that contain the same or similar disclosure.
Response: The Company acknowledges the Staff comment.
Prospectus Cover Page
2. Comment: Please revise the first sentence to clarify that the Company is no longer offering the Policy to new purchasers.
Response: The Company has complied with the Staff comment.
Key Information Table (page 5)
3. Comment: In the “Ongoing Fees and Expenses (annual charges)” row, please confirm
Ms. Emily Rowland
April 18, 2024
Page 2
supplementally that the description of the ongoing fees and expenses in the legend preceding the Annual Fee table includes the mortality and expense risk charge or revise the disclosure to include the mortality and expense risk charge.
Response: The Company confirms that “administration and mortality risks” was intended to include the mortality and expense risk charge assessed under the Policy. The Company has revised the description of the ongoing fees and expenses to refer to “administration, mortality and expense risks,” for clarity.
Overview of the Policy (pages 9-11)
4. Comment: In the “Living Benefit (Accelerated Death Benefit) Rider” bullet, please capitalize “living benefit rider.”
Response: The Company has complied with the Staff comment.
5. Comment: In the “Automatic Rebalancing” bullet, please specify the maximum number of Investment Options to which Cash Value may be transferred under the automatic rebalancing program. In addition, please state that the automatic rebalancing program cannot be utilized in combination with the dollar cost averaging program, if true.
Response: The Company has complied with the Staff comment.
Principal Risks of Investing in the Policy (pages 16-18)
6. Comment: Please explain supplementally why the following language was deleted under the “Risk of Lapse” subsection: “Your Policy will generally not lapse at the end of a Grace Period if you make a premium payment that, when reduced by the premium expense charge, will be at least equal to three times the monthly charges under the Policy immediately preceding the Grace Period. You may reinstate a lapsed Policy subject to certain conditions.” If this disclosure is accurate and is not included elsewhere in the Prospectus, please restore this language.
Response: The Company removed the subject language from the “Risk of Lapse” section because it does not address the consequences of a Policy lapse or the factors that might contribute to a Policy lapse, and is therefore more appropriately discussed in the “Policy Lapse and Reinstatement” section on pages 25-26 of the Prospectus. The Company notes that this information appears in the third paragraph of the “Policy Lapse and Reinstatement” section on page 25.
Other Benefits (pages 49-50)
7. Comment: Please explain supplementally how the registrant intends to notify investors that the Asset Allocation Program is being discontinued.
Ms. Emily Rowland
April 18, 2024
Page 3
Response: On February 23, 2024, the Company filed a supplement to the statutory Prospectus dated May 1, 2023 pursuant to Rule 497(e) under the Securities Act of 1933 (the “1933 Act”) (Accession No. 0001104659-24-027057) and a supplement to the Updating Summary Prospectus (“USP”) dated May 1, 2023 pursuant to Rule 497(k) under the 1933 Act (Accession No. 0001104659-24-027061) describing the upcoming discontinuation of the Asset Allocation Program and the availability of the asset rebalancing program, as well as the anticipated reorganization of certain Investment Options available under the Policy. The supplement to the USP was mailed to current Policyowners and both supplements are available online at www.fbfs.com/variable-product-documents. The Company notes that the discontinuation of the Asset Allocation Program will also be described in the USP dated April 29, 2024 under the heading “Updated Information About Your Policy” in accordance with the requirements of Rule 498A under the 1933 Act.
Statement of Additional Information
8. Comment: Please explain supplementally why the “State Regulation of the Company” subsection was deleted from the “General Information About the Company” section.
Response: The Company notes that the Registration Statement was previously filed with the Commission on Form S-6 and was subject to the requirements of Form S-6. Although the subject information is not required under Form N-6, it was not deleted upon the conversion of the Registration Statement to Form N-6. The Company has determined that this disclosure is not necessary or useful for Policyowners to make informed decisions about their Policies; and that the disclosure is, in part, duplicative of the information contained in the description of the Company provided under the “Farm Bureau Life Insurance Company” subsection of the Statement of Additional Information. Accordingly, this subsection was removed.
Part C
9. Comment: Please include updated consents of Ernst & Young LLP and Eversheds Sutherland (US) LLP, respectively, as exhibits to the Registration Statement.
Response: The Company confirms that updated consents will be filed as exhibits in Post-Effective Amendment No. 48 to the Registration Statement.
* * *
Ms. Emily Rowland
April 18, 2024
Page 4
The Company believes that it has responded to all Staff comments. If you have any questions regarding this letter, please contact our counsel Thomas Bisset at 202-383-0118. We greatly appreciate the Staff’s efforts in assisting the Company with this filing.
Sincerely,
/s/ Clint May
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CLINT MAY
Direct Line: 515-225-5597
E-Mail: Clint.May@fbfs.com
April 18, 2024
VIA EDGAR
Ms. Emily Rowland
Senior Counsel
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-8629
Re: Farm Bureau Life Insurance Company
Post-Effective Amendment No. 47 to Registration
Statement on Form N-6
Farm Bureau Life Variable Account
File
Nos. 33-12789; 811-05068
Ms. Rowland:
On behalf of Farm Bureau Life
Insurance Company (the “Company”) and the Farm Bureau Life Variable Account (the “Account”), we have filed this
letter as correspondence to the above-referenced Post-Effective Amendment No. 47 to the Form N-6 Registration Statement for
the Account (the “Registration Statement”) with the Securities and Exchange Commission (the “Commission”) via
EDGAR. This letter provides the Company’s responses to comments received from the staff (the “Staff”) of the Commission
on the Registration Statement in a phone call with outside counsel for the Company on April 5, 2024. For the Staff’s convenience,
each Staff comment is set forth in full below, followed by the Company’s response.
General
1. Comment: Please note
that comments we give on disclosure in one section apply to other sections of the filing that contain the same or similar disclosure.
Response: The
Company acknowledges the Staff comment.
Prospectus Cover Page
2. Comment: Please revise the first sentence to clarify that the Company is no longer offering
the Policy to new purchasers.
Response: The
Company has complied with the Staff comment.
Key Information Table (page 5)
3. Comment: In the “Ongoing Fees and Expenses (annual charges)” row, please
confirm
Ms. Emily Rowland
April 18, 2024
Page 2
supplementally that the description
of the ongoing fees and expenses in the legend preceding the Annual Fee table includes the mortality and expense risk charge or revise
the disclosure to include the mortality and expense risk charge.
Response: The
Company confirms that “administration and mortality risks” was intended to include the mortality and expense risk charge assessed
under the Policy. The Company has revised the description of the ongoing fees and expenses to refer to “administration, mortality
and expense risks,” for clarity.
Overview of the Policy (pages 9-11)
4. Comment: In the “Living Benefit (Accelerated Death Benefit) Rider” bullet,
please capitalize “living benefit rider.”
Response: The
Company has complied with the Staff comment.
5. Comment: In the “Automatic Rebalancing” bullet, please specify the maximum
number of Investment Options to which Cash Value may be transferred under the automatic rebalancing program. In addition, please state
that the automatic rebalancing program cannot be utilized in combination with the dollar cost averaging program, if true.
Response: The
Company has complied with the Staff comment.
Principal Risks of Investing in the Policy
(pages 16-18)
6. Comment: Please explain supplementally why the following language was deleted under the
“Risk of Lapse” subsection: “Your Policy will generally not lapse at the end of a Grace Period if you make a premium
payment that, when reduced by the premium expense charge, will be at least equal to three times the monthly charges under the Policy immediately
preceding the Grace Period. You may reinstate a lapsed Policy subject to certain conditions.” If this disclosure is accurate and
is not included elsewhere in the Prospectus, please restore this language.
Response: The
Company removed the subject language from the “Risk of Lapse” section because it does not address the consequences of a Policy
lapse or the factors that might contribute to a Policy lapse, and is therefore more appropriately discussed in the “Policy Lapse
and Reinstatement” section on pages 25-26 of the Prospectus. The Company notes that this information appears in the third paragraph
of the “Policy Lapse and Reinstatement” section on page 25.
Other Benefits (pages 49-50)
7. Comment: Please explain supplementally how the registrant intends to notify investors
that the Asset Allocation Program is being discontinued.
Ms. Emily Rowland
April 18, 2024
Page 3
Response: On
February 23, 2024, the Company filed a supplement to the statutory Prospectus dated May 1, 2023 pursuant to Rule 497(e) under
the Securities Act of 1933 (the “1933 Act”) (Accession No. 0001104659-24-027057) and a supplement to the Updating Summary
Prospectus (“USP”) dated May 1, 2023 pursuant to Rule 497(k) under the 1933 Act (Accession No. 0001104659-24-027061)
describing the upcoming discontinuation of the Asset Allocation Program and the availability of the asset rebalancing program, as well
as the anticipated reorganization of certain Investment Options available under the Policy. The supplement to the USP was mailed to current
Policyowners and both supplements are available online at www.fbfs.com/variable-product-documents. The Company notes that the discontinuation
of the Asset Allocation Program will also be described in the USP dated April 29, 2024 under the heading “Updated Information
About Your Policy” in accordance with the requirements of Rule 498A under the 1933 Act.
Statement of Additional Information
8. Comment: Please explain supplementally why the “State Regulation of the Company”
subsection was deleted from the “General Information About the Company” section.
Response: The
Company notes that the Registration Statement was previously filed with the Commission on Form S-6 and was subject to the requirements
of Form S-6. Although the subject information is not required under Form N-6, it was not deleted upon the conversion of the
Registration Statement to Form N-6. The Company has determined that this disclosure is not necessary or useful for Policyowners to
make informed decisions about their Policies; and that the disclosure is, in part, duplicative of the information contained in the description
of the Company provided under the “Farm Bureau Life Insurance Company” subsection of the Statement of Additional Information.
Accordingly, this subsection was removed.
Part C
9. Comment: Please include updated consents of Ernst & Young LLP and Eversheds
Sutherland (US) LLP, respectively, as exhibits to the Registration Statement.
Response: The
Company confirms that updated consents will be filed as exhibits in Post-Effective Amendment No. 48 to the Registration Statement.
* * *
Ms. Emily Rowland
April 18, 2024
Page 4
The Company believes that it has responded to all
Staff comments. If you have any questions regarding this letter, please contact our counsel Thomas Bisset at 202-383-0118. We greatly
appreciate the Staff’s efforts in assisting the Company with this filing.
Sincerely,
/s/ Clint May
Clint May
Vice President, Assistant General Counsel
Farm Bureau Life Insurance Company
cc: Angel Crow
Thomas Bisset, Esq.
Timothy Graves, Esq.