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Correspondence 0000726865-25-000047 from LINCOLN LIFE & ANNUITY VARIABLE ANNUITY ACCOUNT H (CIK 0001045008)

LINCOLN LIFE & ANNUITY VARIABLE ANNUITY ACCOUNT H (CIK 0001045008)
Date: Jan. 31, 2025 · CIK: 0001045008 · Accession: 0000726865-25-000047

AI Filing Summary & Sentiment

File numbers found in text: 333-141756, 333-141763, 333-145531, 333-149449, 333-176213, 333-176216

Date
January 31, 2025
Author
/s/ Carolyn E. Augur
Form
CORRESP
Company
LINCOLN LIFE & ANNUITY VARIABLE ANNUITY ACCOUNT H (CIK 0001045008)

Letter

VIA EDGAR & email Division of Investment Management Re: Lincoln Life & Annuity Company of New York Lincoln Life & Annuity Variable Annuity Account H Post-Effective Amendment No. 26 (“Amendment”) File No. 333-176216

Dear Mr. Brodsky:

On behalf of Lincoln Life & Annuity Company of New York (“Lincoln”), enclosed are courtesy copies of the documents that were included in the above-referenced Amendment filed on January 31, 2025. As stated in the transmittal letter, the Amendment is a “template” filing (the “Template Filing”). A copy of the request pursuant to Rule 485(b)(1)(vii) to file certain post-effective amendments under paragraph (b) of Rule 485 was also filed on January 31, 2025.

The Template Filing reflects the addition of the Lincoln Market SelectSM Advantage, along with the launch of the “Select” version of the i4LIFE® Advantage Guaranteed Income Benefit. The Template Filing will allow substantially identical disclosure to be reflected in additional products offered by Lincoln, as outlined in the January 31, 2025, template request letter addressed to Ms. Varghese.

The Lincoln Market SelectSM Advantage living benefit rider will be available to existing contractowners beginning on or about May 19, 2025. Lincoln Market SelectSM Advantage provides:

•

Guaranteed periodic withdrawals up to the Guaranteed Annual Income amount which is based upon a guaranteed Income Base;

•

Automatic Annual Step-ups of the Income Base to the contract value if the contract value is equal to or greater than the Income Base;

•

Age-based increases to the Guaranteed Annual Income amount.

Additionally, the Template Filing introduces the “Select” version of the i4LIFE® Advantage Guaranteed Income Benefit. This version will be available to purchasers of the Lincoln Market SelectSM Advantage rider who wish to transition to i4LIFE® Advantage Guaranteed Income Benefit at some point in the future.

Please contact me at (860) 466-1111 with any questions or comments. Thank you for your assistance.

Sincerely,

/s/ Carolyn E. Augur

Carolyn E. Augur

Lincoln Financial

Legal Department

The Lincoln National Life Insurance Company

350 Church Street

Hartford, CT 06103

Carolyn E. Augur

Assistant Vice President

and Senior Counsel

Phone: 860-466-1111

Carolyn.Augur@LFG.com

VIA EDGAR & email

January 31, 2025

Thankam Varghese

Branch Chief

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-8629

Re: Lincoln Life & Annuity Company of New York

Request Pursuant to Rule 485(b)(1)(vii)

Prospectus Template and Replicate Filings

Dear Ms. Varghese:

In accordance with Rule 485(b)(1)(vii) under the Securities Act of 1933, as amended (the “1933 Act”), Lincoln Life & Annuity Company of New York (the “Company”) respectfully requests the approval of the Commission to file certain post-effective amendments to registration statements on Form N-4 for variable annuity contracts issued through the Company’s separate accounts (the “Replicate Filings”) under paragraph (b) of Rule 485.

The Company filed on January 31, 2025, under Rule 485(a)(1) of the 1933 Act, the following “template” or model variable annuity filing as described below:

•

Lincoln Life & Annuity Variable Annuity Account H, File No. 333-176216, Post-Effective Amendment No. 26 (the “Template Filing”).

In connection with this request, the Company represents that:

•

The disclosure changes in the Template Filing are substantially identical to disclosure changes that will be made in the Replicate Filings.

•

The Replicate Filings will incorporate changes made to the disclosure included in the Template Filing to resolve any staff comments thereon.

•

The Replicate Filings will not include any other changes that would otherwise render them ineligible for filing under Rule 485(b).

Disclosure Changes

The Template Filing introduces Lincoln Market SelectSM Advantage, a living benefit rider available to existing contractowners beginning on or about May 19, 2025. Lincoln Market SelectSM Advantage provides:

•

Guaranteed periodic withdrawals up to the Guaranteed Annual Income amount which is based upon a guaranteed Income Base;

•

Automatic Annual Step-ups of the Income Base to the contract value if the contract value is equal to or greater than the Income Base;

•

Age-based increases to the Guaranteed Annual Income amount.

Additionally, the Template Filing introduces the “Select” version of the i4LIFE® Advantage Guaranteed Income Benefit. This version will be available to purchasers of the Lincoln Market SelectSM Advantage rider who wish to transition to i4LIFE® Advantage Guaranteed Income Benefit at some point in the future.

The Company proposes to incorporate the changes listed above into the following Replicate Filings. Following each Securities Act filing number is the date the Replicate Filing was last subject to staff review outside of VASP reviews. The Company confirms that each Replicate Filing was updated in connection with VASP, which updated the registration statement to comply with Rule 498A and the revised Form N-4. These VASP changes were subject to Staff review.

Lincoln Life & Annuity Variable Annuity Account H

File No.

Date last subject to SEC review

File No. 333-141756

4/2/07

File No. 333-141763

6/15/18

Lincoln New York Account N for Variable Annuities

File No.

Date last subject to SEC review

File No. 333-145531

4/27/17

File No. 333-149449

11/26/08

File No. 333-176213

10/10/24

We understand that the Commission Staff will respond orally to this request. Please direct your reply to the undersigned at (860) 466-1111. Thank you for your assistance with and attention to this matter.

Sincerely,

Carolyn E. Augur

Carolyn E. Augur

Assistant Vice President and Senior Counsel,

The Lincoln National Life Insurance Company

Lincoln Life & Annuity Company of New York

cc: Aaron Brodsky, Esq.

Lincoln Financial

Legal Department

The Lincoln National Life Insurance Company

350 Church Street

Hartford, CT 06103

Carolyn E. Augur

Assistant Vice President

and Senior Counsel

Phone: 860-466-1111

Carolyn.Augur@LFG.com

VIA EDGAR & email

January 31, 2025

Thankam Varghese

Branch Chief

Division of Investment Management

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-8629

Re: Lincoln Life & Annuity Company of New York

Request Pursuant to Rule 485(b)(1)(vii)

Prospectus Template and Replicate Filings

Dear Ms. Varghese:

In accordance with Rule 485(b)(1)(vii) under the Securities Act of 1933, as amended (the “1933 Act”), Lincoln Life & Annuity Company of New York (the “Company”) respectfully requests the approval of the Commission to file certain post-effective amendments to registration statements on Form N-4 for variable annuity contracts issued through the Company’s separate accounts (the “Replicate Filings”) under paragraph (b) of Rule 485.

The Company filed on January 31, 2025, under Rule 485(a)(1) of the 1933 Act, the following “template” or model variable annuity filing as described below:

•

Lincoln Life & Annuity Variable Annuity Account H, File No. 333-176216, Post-Effective Amendment No. 26 (the “Template Filing”).

In connection with this request, the Company represents that:

•

The disclosure changes in the Template Filing are substantially identical to disclosure changes that will be made in the Replicate Filings.

•

The Replicate Filings will incorporate changes made to the disclosure included in the Template Filing to resolve any staff comments thereon.

•

The Replicate Filings will not include any other changes that would otherwise render them ineligible for filing under Rule 485(b).

Disclosure Changes

The Template Filing introduces Lincoln Market SelectSM Advantage, a living benefit rider available to existing contractowners beginning on or about May 19, 2025. Lincoln Market SelectSM Advantage provides:

•

Guaranteed periodic withdrawals up to the Guaranteed Annual Income amount which is based upon a guaranteed Income Base;

•

Automatic Annual Step-ups of the Income Base to the contract value if the contract value is equal to or greater than the Income Base;

•

Age-based increases to the Guaranteed Annual Income amount.

Additionally, the Template Filing introduces the “Select” version of the i4LIFE® Advantage Guaranteed Income Benefit. This version will be available to purchasers of the Lincoln Market SelectSM Advantage rider who wish to transition to i4LIFE® Advantage Guaranteed Income Benefit at some point in the future.

The Company proposes to incorporate the changes listed above into the following Replicate Filings. Following each Securities Act filing number is the date the Replicate Filing was last subject to staff review outside of VASP reviews. The Company confirms that each Replicate Filing was updated in connection with VASP, which updated the registration statement to comply with Rule 498A and the revised Form N-4. These VASP changes were subject to Staff review.

Lincoln Life & Annuity Variable Annuity Account H

File No.

Date last subject to SEC review

File No. 333-141756

4/2/07

File No. 333-141763

6/15/18

Lincoln New York Account N for Variable Annuities

File No.

Date last subject to SEC review

File No. 333-145531

4/27/17

File No. 333-149449

11/26/08

File No. 333-176213

10/10/24

We understand that the Commission Staff will respond orally to this request. Please direct your reply to the undersigned at (860) 466-1111. Thank you for your assistance with and attention to this matter.

Sincerely,
/s/ Carolyn E. Augur

Show Raw Text
CORRESP
1
filename1.htm

    Lincoln Financial

    Legal Department

    The Lincoln National Life Insurance Company

    350 Church Street

    Hartford, CT 06103

    Carolyn E. Augur

    Assistant Vice President

    and Senior Counsel

    Phone: 860-466-1111

    Carolyn.Augur@LFG.com

    VIA EDGAR & email

    January 31, 2025

    Aaron Brodsky

    Attorney-Adviser

    U.S. Securities and Exchange Commission

    Division of Investment Management

    Disclosure Review and Accounting Office

    100 F Street, NE

    Washington, DC 20549

    Re: Lincoln Life & Annuity Company of New York

    Lincoln Life & Annuity Variable Annuity Account H

    Post-Effective Amendment No. 26 (“Amendment”)

    File No. 333-176216

    Dear Mr. Brodsky:

    On behalf of Lincoln Life & Annuity Company of New York (“Lincoln”), enclosed are courtesy copies of the documents that were included in the
      above-referenced Amendment filed on January 31, 2025.  As stated in the transmittal letter, the Amendment is a “template” filing (the “Template Filing”).  A copy of the request pursuant to Rule 485(b)(1)(vii) to file certain post-effective amendments
      under paragraph (b) of Rule 485 was also filed on January 31, 2025.

    The Template Filing reflects the addition of the Lincoln Market
        SelectSM Advantage, along with the launch of the “Select” version of the i4LIFE® Advantage Guaranteed Income
      Benefit. The Template Filing will allow substantially identical disclosure to be reflected in additional products offered by Lincoln, as outlined in the January 31, 2025, template request letter addressed to Ms. Varghese.

    The Lincoln Market SelectSM Advantage
      living benefit rider will be available to existing contractowners beginning on or about May 19, 2025. Lincoln Market SelectSM
      Advantage provides:

              •

              Guaranteed periodic withdrawals up to the Guaranteed Annual Income amount which is based upon a guaranteed Income Base;

              •

              Automatic Annual Step-ups of the Income Base to the contract value if the contract value is equal to or greater than the Income
                Base;

              •

              Age-based increases to the Guaranteed Annual Income amount.

    Additionally, the Template Filing introduces the “Select” version of the i4LIFE® Advantage Guaranteed Income Benefit. This version will be available to purchasers of the Lincoln Market SelectSM Advantage rider who wish to transition to i4LIFE® Advantage Guaranteed Income Benefit at
      some point in the future.

    Please contact me at (860) 466-1111 with any questions or comments. Thank you for your assistance.

    Sincerely,

    /s/ Carolyn E. Augur

    Carolyn E. Augur

    Lincoln Financial

    Legal Department

    The Lincoln National Life Insurance Company

    350 Church Street

    Hartford, CT 06103

    Carolyn E. Augur

    Assistant Vice President

    and Senior Counsel

    Phone: 860-466-1111

    Carolyn.Augur@LFG.com

    VIA EDGAR & email

    January 31, 2025

    Thankam Varghese

    Branch Chief

    Division of Investment Management

    Securities and Exchange Commission

    100 F Street, NE

    Washington, DC 20549-8629

    Re: Lincoln Life & Annuity Company of New York

    Request Pursuant to Rule 485(b)(1)(vii)

    Prospectus Template and Replicate Filings

    Dear Ms. Varghese:

    In accordance with Rule 485(b)(1)(vii) under the Securities Act of 1933, as amended (the “1933 Act”), Lincoln Life & Annuity Company
      of New York (the “Company”) respectfully requests the approval of the Commission to file certain post-effective amendments to registration statements on Form N-4 for variable annuity contracts issued through the Company’s separate accounts (the
      “Replicate Filings”) under paragraph (b) of Rule 485.

    The Company filed on January 31, 2025, under Rule 485(a)(1) of the 1933 Act, the following “template” or model variable annuity filing as
      described below:

              •

              Lincoln Life & Annuity Variable Annuity Account H, File No. 333-176216, Post-Effective Amendment No. 26 (the “Template
                Filing”).

    In connection with this request, the Company represents that:

              •

              The disclosure changes in the Template Filing are substantially identical to disclosure changes that will be made in the
                Replicate Filings.

              •

              The Replicate Filings will incorporate changes made to the disclosure included in the Template Filing to resolve any staff
                comments thereon.

              •

              The Replicate Filings will not include any other changes that would otherwise render them ineligible for filing under Rule
                485(b).

    Disclosure Changes

    The Template Filing introduces Lincoln Market
        SelectSM Advantage, a living benefit rider available to existing contractowners beginning on or about May 19, 2025. Lincoln Market
        SelectSM Advantage provides:

              •

              Guaranteed periodic withdrawals up to the Guaranteed Annual Income amount which is based upon a guaranteed Income Base;

              •

              Automatic Annual Step-ups of the Income Base to the contract value if the contract value is equal to or greater than the Income
                Base;

              •

              Age-based increases to the Guaranteed Annual Income amount.

    Additionally, the Template Filing introduces the “Select” version of the i4LIFE® Advantage Guaranteed Income Benefit. This version will be available to purchasers of the Lincoln Market SelectSM Advantage rider who wish to transition to i4LIFE® Advantage Guaranteed
      Income Benefit at some point in the future.

    The Company proposes to incorporate the changes listed above into the following Replicate Filings. Following each Securities Act filing number is the date the
      Replicate Filing was last subject to staff review outside of VASP reviews. The Company confirms that each Replicate Filing was updated in connection with VASP, which updated the registration statement to comply with Rule 498A and the revised Form
      N-4. These VASP changes were subject to Staff review.

            Lincoln Life & Annuity Variable Annuity Account H

            File No.

            Date last subject to SEC review

            File No. 333-141756

            4/2/07

            File No. 333-141763

            6/15/18

            Lincoln New York Account N for Variable Annuities

            File No.

            Date last subject to SEC review

            File No. 333-145531

            4/27/17

            File No. 333-149449

            11/26/08

            File No. 333-176213

            10/10/24

    We understand that the Commission Staff will respond orally to this request.  Please direct your reply to the undersigned at (860)
      466-1111.  Thank you for your assistance with and attention to this matter.

    Sincerely,

    Carolyn E. Augur

    Carolyn E. Augur

    Assistant Vice President and Senior Counsel,

    The Lincoln National Life Insurance Company

    Lincoln Life & Annuity Company of New York

    cc: Aaron Brodsky, Esq.

      Lincoln Financial

      Legal Department

      The Lincoln National Life Insurance Company

      350 Church Street

      Hartford, CT 06103

      Carolyn E. Augur

      Assistant Vice President

      and Senior Counsel

      Phone: 860-466-1111

      Carolyn.Augur@LFG.com

      VIA EDGAR & email

      January 31, 2025

      Thankam Varghese

      Branch Chief

      Division of Investment Management

      Securities and Exchange Commission

      100 F Street, NE

      Washington, DC 20549-8629

      Re: Lincoln Life & Annuity Company of New York

      Request Pursuant to Rule 485(b)(1)(vii)

      Prospectus Template and Replicate Filings

      Dear Ms. Varghese:

      In accordance with Rule 485(b)(1)(vii) under the Securities Act of 1933, as amended (the “1933 Act”), Lincoln Life & Annuity Company
        of New York (the “Company”) respectfully requests the approval of the Commission to file certain post-effective amendments to registration statements on Form N-4 for variable annuity contracts issued through the Company’s separate accounts (the
        “Replicate Filings”) under paragraph (b) of Rule 485.

      The Company filed on January 31, 2025, under Rule 485(a)(1) of the 1933 Act, the following “template” or model variable annuity filing
        as described below:

                •

                Lincoln Life & Annuity Variable Annuity Account H, File No. 333-176216, Post-Effective Amendment No. 26 (the “Template
                  Filing”).

      In connection with this request, the Company represents that:

                •

                The disclosure changes in the Template Filing are substantially identical to disclosure changes that will be made in the
                  Replicate Filings.

                •

                The Replicate Filings will incorporate changes made to the disclosure included in the Template Filing to resolve any staff
                  comments thereon.

                •

                The Replicate Filings will not include any other changes that would otherwise render them ineligible for filing under Rule
                  485(b).

      Disclosure Changes

      The Template Filing introduces Lincoln Market
          SelectSM Advantage, a living benefit rider available to existing contractowners beginning on or about May 19, 2025. Lincoln Market
          SelectSM Advantage provides:

                •

                Guaranteed periodic withdrawals up to the Guaranteed Annual Income amount which is based upon a guaranteed Income Base;

                •

                Automatic Annual Step-ups of the Income Base to the contract value if the contract value is equal to or greater than the Income
                  Base;

                •

                Age-based increases to the Guaranteed Annual Income amount.

      Additionally, the Template Filing introduces the “Select” version of the i4LIFE® Advantage Guaranteed Income Benefit. This version will be available to purchasers of the Lincoln Market SelectSM Advantage rider who wish to transition to i4LIFE® Advantage
        Guaranteed Income Benefit at some point in the future.

      The Company proposes to incorporate the changes listed above into the following Replicate Filings. Following each Securities Act filing number is the date
        the Replicate Filing was last subject to staff review outside of VASP reviews. The Company confirms that each Replicate Filing was updated in connection with VASP, which updated the registration statement to comply with Rule 498A and the revised
        Form N-4. These VASP changes were subject to Staff review.

              Lincoln Life & Annuity Variable Annuity Account H

              File No.

              Date last subject to SEC review

              File No. 333-141756

              4/2/07

              File No. 333-141763

              6/15/18

              Lincoln New York Account N for Variable Annuities

              File No.

              Date last subject to SEC review

              File No. 333-145531

              4/27/17

              File No. 333-149449

              11/26/08

              File No. 333-176213

              10/10/24

      We understand that the Commission Staff will respond orally to this request.  Please direct your reply to the undersigned at (860)
        466-1111.  Thank you for your assistance with and attention to this matter.

      Sincerely,

      /s/ Carolyn E. Augur

      Carolyn E. Augur

      Assistant Vice President and Senior Counsel,

      The Lincoln National Life Insurance Company

      Lincoln Life & Annuity Company of New York

      cc: Aaron Brodsky, Esq.