SecProbe.io

November 14, 2022
BY EMAIL

Brandon J. Cage
Assistant Vice President, Counsel
Law Department
Pacific Life Insurance Company
700 Newport Center Drive
Newport Beach, California 92660

Re: Registration Statement on Form N-6 of Pacific Select Exec Separate Account (the
“Separate Account”) of Pacific Life Insurance Company (the “Company”) relating to
Pacific Legacy Survivorship VUL (File Nos. 811-05563 and 333-267433) (the
“Registration Statement”)

Dear Mr. Cage:

The staff has reviewed the Registration Statement on Form N-6 filed on September 15,
2022 by the Separate Account under the Securities Act of 1933, as amended (the “1933 Act”),
and the Investment Company Act of 1940, as amended.  All capitalized terms not otherwise
defined herein have the respective meanings given to them in the Registration Statement.
References to “Items” or “Instructions” herein are to Items and Instructions in Form N-6 and
references to “Rule” are to Rules under the 1933 Act.

GENERAL

1. Please confirm supplementally that all missing information and all exhibits will be filed
in pre-effective amendments to the Registration Statement. We may have additional
comments on such portions when you complete them in the pre-effective amendments, on
disclosures made in response to this letter, on information supplied supplementally, or on
exhibits filed in the pre-effective amendments.

2. Where a comment is made with regard to disclosure in one location of the Registration
Statement, it is applicable to all similar disclosure appearing elsewhere in the
Registration Statement. Please ensure that corresponding changes are made to all similar
disclosure.

3. Please clarify supplementally whether there are any guarantees or support agreements
with third parties to support any policy features or benefits, or whether the Company will
be solely responsible for any benefits or features associated with the Policy issued by the
Separate Account.

Brandon J. Cage
November 14, 2022
Page 2 of 14

4. Please be aware that the compliance date for the requirement to use the Inline eXtensible
Business Reporting Language (XBRL) format for the submission of certain required
disclosures in the variable contract statutory prospectus is January 1, 2023.  Filings made
on or after January 1, 2023 will be required to comply with these requirements.  [General
Instruction C.3.(h).]

PROSPECTUS

Table of Contents

5. In the electronic versions of the Prospectuses and SAI, please add hyperlinks to the
headings and subheadings in the Tables of Contents to link directly to the relevant
sections in the document.
Special Terms

6. Please explain in the defined term “Account Additions” what these are ( e.g., premiums
and additional credits).
7. The definition of “Account Deductions” states that deductions are taken proportionately
from the Fixed and Variable Account Values, but that the Company makes available
other ways to make deductions.  Please disclose the other ways to make deductions in an
appropriate location in the Prospectus and include a cross reference to the relevant
discussion in the definition.
8. In the definition of “Additional Credit,” please add that any such credit may be applied
beginning on the 11th Policy Anniversary.
9. Please revise the definition of “Basic Face Amount” and/or “Face Amount” to better
distinguish the intended substantive difference between the terms or eliminate one of the
terms.
10. Please revise the definition of “Basic Life Coverage Layer” and/or “Coverage Layer” to
better distinguish the intended substantive difference between the terms or eliminate one
of the terms.
11. In the definition of “Loan Account Value,” please add at the end of the third sentence,
“during which a Loan Account is outstanding” or a similar statement.
12. Please delete the second sentence of the definition of “Riders,” since no currently
available Rider offers additional life insurance coverage.
13. Please clarify in the definition of “Surrender Charge” that the charge will apply during
the first 20 years of any Basic Life Coverage Layer added to the Policy.

Brandon J. Cage
November 14, 2022
Page 3 of 14

Important Information You Should Consider About the Policy

14. Please confirm supplementally that the key information table cross-references in the
electronic version of the Prospectus will link directly to the location in the statutory
Prospectus where the subject matter is discussed in greater detail, or will provide a means
of facilitating access to that information through equivalent methods or technologies.
[Instruction 1(b) to Item 2.]
Fees and Expenses

—Transaction Charges
15. The Prospectus does not disclose a charge for Risk Class changes and the optional Riders
do not allow for requests to increase benefits.  Please remove the references to risk class
changes and for requests to increase benefits under an optional Rider in this section.
Please add a reference to charges imposed to exercise certain optional riders.
Risks
—Not a Short-Term Investment
16. Please add a statement that no withdrawals may be made during the first year of the
Policy.
— Contract Lapse
17. Please address the following comments in this section and under Principal Risks of
Investing in the Policy—Policy Lapse :
a. revise the discussion to include reference to the Short-Term No-Lapse Guarantee
Rider, explain that the Policy will not lapse if the Rider conditions are satisfied
and provide a cross reference to the relevant discussion in the Prospectus;
b. change “no death benefit will be paid” to “no death benefit or other benefits will
be paid”; and
c. disclose that the Insureds must apply for reinstatement and that there is no
guarantee that reinstatement will be approved or reapproved in the same Risk
Class.
Restrictions
—Investments
18. Please add that there is a $25 fee per transfer in excess of 12 transfers per Policy Year.
[Instruction 4(a) to Item 2.]

Brandon J. Cage
November 14, 2022
Page 4 of 14

—Optional Benefits
19. Please address the following comments:
a. disclose that some optional Riders must be elected at Policy issue, may be subject
to conditions to exercise or underwriting, and that your election of certain
optional Riders may result in restrictions on some Policy benefits [Instruction 4(b)
to Item 2];
b. if availability of some Riders varies by selling broker dealer, please so state in
each location that states that Riders may not be available in all states; and
c. since the Prospectus does not describe any restrictions on Investment Options,
please delete the statement that “[c]ertain optional benefits limit or restrict the
Investment Options that you may select under the Contract.”
Overview of the Policy
Purpose
20. Please tailor the disclosure in this section to reflect that the Policy covers the lives of two
Insureds.
21. In the last sentence of the section, please add “and Death Benefit Qualification Test”
immediately after “Death Benefit Option.”
Premiums
22. Please revise the discussion of Policy lapse in this section and under How Premiums
Work—Planned Premium Payments in light of the fact that the Short-Term No-Lapse
Guarantee Rider is a standard feature of the Policy.
Policy Features
—Death Benefit
23. The disclosure states that “[t]he death benefit proceeds equal the death benefit plus any
additional benefit provided by a rider less any outstanding loan or unpaid Policy
charges.”  No additional benefits are provided by any Rider in connection with the Death
Benefit.  Please remove the reference.
24. The disclosure states that “Policy charges vary depending on which Death Benefit Option
is selected.”  If Policy charges also vary depending on which Death Benefit Qualification
Test is selected, please so indicate in the disclosure.

Brandon J. Cage
November 14, 2022
Page 5 of 14

—Surrender
25. Please add “or benefits” immediately after “no life insurance coverage” in the third
sentence of this paragraph.
26. Please consider adding to the fourth sentence that tax consequences including a possible
tax penalty if surrendered before age 59½.
Fee Tables
Transaction Fees
—Maximum Sales Charge Imposed on Premiums (Load)
27. The first note to appear under Transaction Fees  is Note 3.  Please renumber the notes
sequentially starting with Note 1.
—Maximum surrender charge
28. In Note 1, please consider adding a cross reference to the discussion of the Surrender
Charge in Withdrawals, Surrenders and Loans—Surrendering Your Policy .
Periodic Charges Other Than Fund Operating Expenses
29. Please consider adding that the maximum charge under Administrative charge is also the
current charge.
30. Please remove the Policy Split Option Rider from this table.  This transactional charge is
covered under The Transaction Fees table.
31. Note 4 to the table states “[t]he Coverage charge on a current basis only applies for the
first 10 years of each Coverage Layer.”  Please disclose how the Coverage charge will be
calculated after the first 10 years of a Coverage Layer or provide a cross reference to the
relevant discussion in the Prospectus.
32. Note 6 which applies to all Optional Benefit Charges states that “[r]ider charges are based
on the Age and Risk Class of the person insured under the Rider on the effective date of
the Rider.”   If accurate, please revise so that the statement applies only to the Estate
Preservation Rider.

Brandon J. Cage
November 14, 2022
Page 6 of 14

Policy Basics
Owners, the Insureds, and Beneficiaries
—Owners
33. The disclosure states that “[y]ou can own a Policy by yourself or with someone else.”
Special Terms  defines “Owner” as “the person named on the application who makes the
decisions about the Policy.”  The preceding disclosure is identical to the disclosure that
the Company uses for its policies that cover a single insured.  Please tailor the ownership
disclosure throughout to reflect a Policy that covers two Insureds.  For example, please
add that if the Policy is owned by one Owner, the Owner can make all decisions
regarding the Policy and its benefits for both Insureds.  Please disclose whether the
application requires that both Insureds be affirmatively identified by the applicants as
Owners or whether both Insureds are deemed Owners, unless the application specifies a
different person as the Owner.  Also, disclose what happens when the application does
not indicate an Owner(s).
—The Insured
34. If the Company intends to use simplified underwriting or other underwriting methods that
would cause healthy individuals to pay higher cost of insurance rates than they would pay
under a substantially similar policy that is offered by the Company using different
underwriting methods, state that the cost of insurance rates are higher for healthy
individuals when this method of underwriting is used than under the substantially similar
policy.  [Instruction 2 to Item 7 (a).]
Illustrations
35. Please add “historical or” immediately before “a hypothetical gross rate of return” in the
third bullet point.
Telephone and Electronic Transactions
36. An investor may authorize the Company to accept telephone and electronic instructions
for certain transactions, including initiating loans. Can loan increases or repayments also
be authorized in this manner?  If so, please revise the disclosure.
Death Benefits
37. Please add a cross reference to the discussion in the Prospectus of the effect of
withdrawals under each Death Benefit Option.
The Death Benefit
38. The disclosure states that the “Policy’s Death Benefit depends on two choices you must
make: [the] Total Face Amount [and the] Death Benefit Option.”  The table under Death

Brandon J. Cage
November 14, 2022
Page 7 of 14

Benefit Qualification Test—Comparing the Death Benefit Qualification  Tests shows that
the Death Benefit is generally higher under the Cash Value Accumulation Test.  Please
revise the disclosure to include the choice of Death Benefit Qualification Test as a factor
affecting the Policy’s Death Benefit.
Death Benefit Options
39. Please add disclosure to the effect that the Death Benefit Option an investor chooses will
have an impact on the dollar value of the Death Benefit, the Accumulated Value, and the
cost of insurance charges an investor pays.
40. The disclosure states “[t]he Death Benefit Option you choose will generally depend on
which is more important to you: a larger Death Benefit or building the Accumulated
Value of your Policy.”  Please revise the disclosure to also include cost of insurance
charges as a consideration in choosing a Death Benefit Option.   Please also add
disclosure so that an investor understands the material pros and cons of each death benefit
option (e.g., under Option A, positive returns would result in a higher proportion of
Accumulated Value to the Death Benefit which would reduce the Net Amount at Risk,
which may lower the total fees and expenses under the Policy).
41. Please add a brief explanation under the illustration of Option A to the effect that the
Death Benefit remains constant and does not change as a Policy’ Accumulated Value
changes.
Changing Your Death Benefit Option
42. Please revise the second bullet to reflect three Death Benefit Options rather than two.
43. In the third bullet, please revise the reference to “any Death Benefit Option” to Death
Benefit Options A or B.”
Death Benefit Qualification Test
44. Please disclose the default Death Benefit Qualification Test when no choice is indicated
in the application.
45. Please briefly explain how each Death Benefit Qualification Test is calculated and the
effect of choosing the CVAT or GPT qualification test with each Death Benefit Option.
—Comparing the Death Benefit Qualification Tests
46. In the comparison chart, please disclose any anticipated differences in Policy charges
under the two tests

Brandon J. Cage
November 14, 2022
Page 8 of 14

Other Benefits Available Under the Policy
47. Please address the following comments regarding loans:
a. add a discussion of the risks of loans to Principal Risks of Investing in the Policy ;
and
b. given that loans are a benefit under the Contract, consider adding loans to the
table in Other Benefits Available Under the Policy .  If loans will not be added to
the table, please supplementally explain why it would not be appropriate to do so.
48. In the description of the Conversion Rider, please change “certain insurance coverages”
to “eligible coverage.”
49. In the last column of the description of the Enhanced Policy Split Option Rider, please
disclose the following:
a. the Rider may not be exercised after a certain number of Policy Years depending
on the ages of the Insureds; and
b. the Rider may only be exercised upon the occurrence of certain federal estate tax
law changes.
50. In the last column of the description of the Premier Living Benefits Rider 2, please
disclose that once the Rider is exercised, the Company will not allow any requested
increases in benefits under the Policy or any other Riders.
51. In the last column of the description of the Terminal Illness Rider—Last Survivor, please
consolidate the disclosure in the fourth and seventh bullet points.
52. In the description of the Terminal Illness Rider—Last Survivor, the disclosure states that
the rider is “[n]ot available for Policy’s issued with the Premier Living Benefits Rider 2,
unless the Insured(s) did not qualify for the Premier Living Benefits Rider 2.”  Please
reconcile this with the statement under the description of the Premier Living Benefits
Rider 2 that the Rider “[c]annot be issued with the Terminal Illness Rider—Last Survivor
if this rider names more than one eligible Insured.”
53. With respect to the Estate Preservation Rider, please address the following:
a. in the second column, please insert “equal to the Rider Face Amount”
immediately after “a death benefit;” and
b. add to the last column that if the Policy lapses, the Rider cannot be reinstated.

Brandon J. Cage
November 14, 2022
Page 9 of 14

Optional Riders and Benefits
Conversion Rid