Correspondence 0001104659-23-065427 from PACIFIC SELECT EXEC SEPARATE ACCT PACIFIC LIFE INS (CIK 0000832908)
PACIFIC SELECT EXEC SEPARATE ACCT PACIFIC LIFE INS (CIK 0000832908)
Date: May 26, 2023 · CIK: 0000832908 · Accession: 0001104659-23-065427
AI Filing Summary & Sentiment
File numbers found in text: 333-267433, 811-05563
Letter
Division of Investment Management U.S. Securities & Exchange Commission 100 F Street, NE Washington, DC 20549-0506 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 Ms. Choo:
On behalf of Pacific Life Insurance Company (“Pacific Life”), (hereinafter collectively referred to as “Registrants”), set forth below are responses to Staff comments received May 11, 2023, and subsequently received May 23, 2023, in connection with the above referenced Form N-6 filed September 15, 2022. All disclosure changes included in this response will be made to the registration statement referenced above.
Prospectus Comments
1. Staff Comment: SPECIAL TERMS. In response to previous comments 3 and 4, the Company revised the applicable definitions, please further revise the disclosure to clearly and explicitly explain the difference between the terms and the consequences of classifying Basic Face Amount and Face Amount and Coverage Layer and Basic Coverage Layer.
Response: We have revised the definitions to reflect that, for the purposes of this product and current prospectus, the Basic Life Coverage Layer will always equal the Coverage Layer. In addition, we have more clearly defined the applicable terms.
2. Staff Comment: DEATH BENEFITS - Death Benefit Options. Please revise so that an investor can more easily understand the benefits and drawbacks for each Death Benefit Option based on the factors listed in the introductory paragraph.
Response: We have made revisions to this section including the addition of a table that is intended to allow an investor to more easily understand the benefits and drawbacks of each Death Benefit Option.
Ms. Choo
May 26, 2023
Page 2
2(a). Staff Comment: In addition, please make clear how the Accumulated Value may impact the death benefit in each applicable Death Benefit Option.
Response: We have revised the table to identify the circumstance in which the Accumulated Value may impact the death benefit.
3. Staff Comment: OTHER BENEFITS AVAILABLE UNDER THE POLICY – No-Lapse Guarantee Rider. Please disclose the no lapse guarantee period here and in other appropriate locations in the prospectus. If the period is not the same for each Policy, please describe generally how the period is determined, provide a range of the durations, and direct investors to their specific no lapse guarantee period in their Policy.
Response: We made the requested modification.
We hope that the foregoing is responsive to the Staff’s comments. If you have any questions, please call me at (949) 258-2876. Thank you.
Sincerely,
/s/ Alison Ryan
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Alison
Ryan
AVP & Managing Assistant General Counsel
OGC
CMD Legal & Compliance
Phone: 949-219-3628
Mobile: 949-258-2876
Fax: 949-219-3706
Alison.Ryan@pacificlife.com
May 26, 2023
Yoon Choo
Attorney-Adviser
Division of Investment Management
U.S. Securities & Exchange Commission
100 F Street, NE
Washington, DC 20549-0506
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 Ms. Choo:
On behalf of Pacific Life Insurance Company (“Pacific Life”),
(hereinafter collectively referred to as “Registrants”), set forth below are responses to Staff comments received May 11,
2023, and subsequently received May 23, 2023, in connection with the above referenced Form N-6 filed September 15, 2022. All disclosure
changes included in this response will be made to the registration statement referenced above.
Prospectus Comments
1. Staff Comment: SPECIAL TERMS. In response to
previous comments 3 and 4, the Company revised the applicable definitions, please further revise the disclosure to clearly and explicitly
explain the difference between the terms and the consequences of classifying Basic Face Amount and Face Amount and Coverage Layer and
Basic Coverage Layer.
Response: We have revised the definitions to reflect that, for
the purposes of this product and current prospectus, the Basic Life Coverage Layer will always equal the Coverage Layer. In addition,
we have more clearly defined the applicable terms.
2. Staff Comment: DEATH BENEFITS - Death Benefit Options.
Please revise so that an investor can more easily understand the benefits and drawbacks for each Death Benefit Option based on the factors
listed in the introductory paragraph.
Response: We have made revisions to this section including the
addition of a table that is intended to allow an investor to more easily understand the benefits and drawbacks of each Death Benefit Option.
Ms. Choo
May 26, 2023
Page 2
2(a). Staff Comment: In addition, please make clear how
the Accumulated Value may impact the death benefit in each applicable Death Benefit Option.
Response: We have revised the table to identify the circumstance
in which the Accumulated Value may impact the death benefit.
3. Staff Comment: OTHER BENEFITS AVAILABLE UNDER THE
POLICY – No-Lapse Guarantee Rider. Please disclose the no lapse guarantee period here and in other appropriate locations in
the prospectus. If the period is not the same for each Policy, please describe generally how the period is determined, provide a range
of the durations, and direct investors to their specific no lapse guarantee period in their Policy.
Response: We made the requested modification.
We hope that the foregoing is responsive to the Staff’s comments.
If you have any questions, please call me at (949) 258-2876. Thank you.
Sincerely,
/s/ Alison Ryan
Alison Ryan