Correspondence 0001104659-23-043886 from PACIFIC SELECT EXEC SEPARATE ACCT PACIFIC LIFE INS (CIK 0000832908)
PACIFIC SELECT EXEC SEPARATE ACCT PACIFIC LIFE INS (CIK 0000832908)
Date: April 11, 2023 · CIK: 0000832908 · Accession: 0001104659-23-043886
AI Filing Summary & Sentiment
File numbers found in text: 333-233112, 811-05563
Letter
Division of Investment Management U.S. Securities & Exchange Commission 100 F Street, NE Washington, DC 20549-0506 Re: Post-Effective Amendment No. 6 to the Registration Statement for Pacific KeyExec VUL Flexible Premium Life Insurance Policy (File No. 333-233112) funded by Pacific Select Exec Separate Account (File Number 811-05563) of Pacific Life Insurance Company
Dear Mr. Williams:
On behalf of Pacific Life Insurance Company (“Pacific Life”), (hereinafter collectively referred to as “Registrants”), set forth below are responses to Staff comments received April 5, 2023, in connection with the above referenced Post-Effective Amendments, on Form N-6, filed February 10, 2023. All disclosure changes included in this response will be made to the registration statement referenced above.
Prospectus Comments
1. Staff Comment: Important Information You Should Consider About the Policy, Restrictions, Optional Benefits: Please shorten the description of the loan entry so that it is only a summary of the optional benefit.
Response: We made the requested modification.
2. Staff Comment: Fee Tables, Transaction Fees: In Footnote #2, please add to the end of the sentence “and we reserve the right to do so in the future”.
Response: We made the requested modification.
“We currently do not impose this charge and we reserve the right to do so in the future.”
3. Staff Comment: Death Benefits, Changing the Total Face Amount, Requesting and Increase in Rider Face Amount: In the beginning of the fifth bullet point, please insert “For policies issued on or after [May 1, 2023],” to provide more clarity that off-anniversary, unscheduled increase requests are not available for existing policies.
Ms. Samuel
April 11,
Page 2
Response: We made the requested modification.
“For policies issued on or after [May 1, 2023], an unscheduled increase to Rider Face Amount will be effective on the Monthly Payment Date on or after the increase was approved by us, or any other Monthly Payment Date you request, and we approve.”
4. Staff Comment: Other Benefits Available Under The Policy, Brief Description of Restriction/Limitations, Flex Coverage Rider: In the fourth bullet point, please clarify that unscheduled increases are only available to policies issued on or after May 1, 2023.
Response: We made the requested modification.
“Any unscheduled increase (available only to policies issued on or after [May 1, 2023]) or increase to your future scheduled increases, must be requested in writing, will be subject to satisfactory evidence of insurability and must be at least $1,000.”
I believe that the foregoing is responsive to Staff comments. If you have any questions, please call me at (949) 420-7078. Thank you.
Sincerely,
/s/ Thomas
C. Bilello
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Thomas
C. Bilello
Vice President & Associate General Counsel
OGC CMD Legal & Compliance
Phone: 949-420-7078
Fax: 949-219-3706
thomas.bilello@pacificlife.com
April 11, 2023
Sally Samuel
Branch Chief
Division of Investment Management
U.S. Securities & Exchange
Commission
100 F Street, NE
Washington, DC 20549-0506
Re: Post-Effective Amendment No. 6 to
the Registration Statement for Pacific KeyExec VUL Flexible Premium Life Insurance
Policy (File No. 333-233112) funded by Pacific Select Exec Separate Account (File Number
811-05563) of Pacific Life Insurance Company
Dear Mr. Williams:
On behalf of Pacific Life Insurance
Company (“Pacific Life”), (hereinafter collectively referred to as “Registrants”), set forth below are responses
to Staff comments received April 5, 2023, in connection with the above referenced Post-Effective Amendments, on Form N-6, filed
February 10, 2023. All disclosure changes included in this response will be made to the registration statement referenced above.
Prospectus Comments
1.
Staff Comment: Important Information You Should Consider About the Policy, Restrictions,
Optional Benefits: Please shorten the description of the loan entry so that it is only a summary of the optional benefit.
Response:
We made the requested modification.
2.
Staff Comment: Fee Tables, Transaction Fees: In Footnote #2, please add to the
end of the sentence “and we reserve the right to do so in the future”.
Response:
We made the requested modification.
“We currently do not impose this
charge and we reserve the right to do so in the future.”
3.
Staff Comment: Death Benefits, Changing the Total Face Amount, Requesting and Increase
in Rider Face Amount: In the beginning of the fifth bullet point, please insert “For policies issued on or after [May 1,
2023],” to provide more clarity that off-anniversary, unscheduled increase requests are not available for existing policies.
Ms. Samuel
April 11,
2023
Page 2
Response:
We made the requested modification.
“For policies issued on or after
[May 1, 2023], an unscheduled increase to Rider Face Amount will be effective on the Monthly Payment Date on or after the increase
was approved by us, or any other Monthly Payment Date you request, and we approve.”
4.
Staff Comment: Other Benefits Available Under The Policy, Brief Description of Restriction/Limitations,
Flex Coverage Rider: In the fourth bullet point, please clarify that unscheduled increases are only available to policies issued
on or after May 1, 2023.
Response:
We made the requested modification.
“Any unscheduled increase (available
only to policies issued on or after [May 1, 2023]) or increase to your future scheduled increases, must be requested in writing,
will be subject to satisfactory evidence of insurability and must be at least $1,000.”
I believe that the foregoing is responsive
to Staff comments. If you have any questions, please call me at (949) 420-7078. Thank you.
Sincerely,
/s/ Thomas
C. Bilello
Thomas
C. Bilello