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Correspondence 0000726865-23-000492 from LINCOLN LIFE VARIABLE ANNUITY ACCOUNT N (CIK 0001048606)

LINCOLN LIFE VARIABLE ANNUITY ACCOUNT N (CIK 0001048606)
Date: Aug. 4, 2023 · CIK: 0001048606 · Accession: 0000726865-23-000492

AI Filing Summary & Sentiment

File numbers found in text: 333-222786

Date
August 4, 2023
Author
Nadine Rosin
Form
CORRESP
Company
LINCOLN LIFE VARIABLE ANNUITY ACCOUNT N (CIK 0001048606)

Letter

Division of Investment Management Securities and Exchange Commission Washington, DC 20549-8629 Re: Post-Effective Amendment No. 16 to the Registration Statement on Form N-4 for The Lincoln National Life Insurance Company File No. 333-222786

Dear Mr. Zapata:

This letter is in response to the comments received by telephone on July 31, 2023. All responses are how they appear within the prospectus. Corresponding changes will be applied to the other prospectuses of the registration statement, as applicable.

1.

Please add page numbers to the supplement that correspond with the underlying prospectuses.

Response: Since there are multiple prospectuses within the registration statement, it is difficult to specify the page numbers for all books and believe that it may be more confusing to the Contractowners to provide page numbers.

2.

Special Terms –

a.

Please clarify why there are two different crediting methods. Please clarify the distinction.

b.

Should the term Dual15 Plus Rate be defined under Crediting Method?

Response:

a. We have revised accordingly.

b. We have revised to accurately reflect the defined term Dual Rate.

3.

Risk Factors –

a.

Under Dual Performance Trigger Rate – Segment Value is not a defined term within the underlying prospectus.

b.

Under Dual15 Plus - Segment Ending Value is not a defined term within the underlying prospectus.

Response:.

a. We have revised to use the term to Segment Maturity Value, which is a defined term.

b. We have revised to use the term to Segment Maturity Value, which is a defined term.

4.

Investments of the Indexed Accounts (p. ) – Please add a disclosure indicating that the footnotes are located within the underlying prospectus and have not changed.

Response: Disclosure has been added.

5.

Crediting and Protection Methods sub-section chart

a.

Please replace the word “flat” within the heading of the first table to “zero”.

b.

Please clarify which chart the additional language will be located.

Response:

a.

The chart heading has been revised accordingly and revised for clarification.

b.

The additional language will be added under the first chart with the heading: “These are the Crediting Methods available when the index performance is positive (or zero for the Performance Trigger Rate; or zero or negative for the Dual Performance Trigger Rate and Dual15 Plus)”.

6.

Dual Performance Trigger Rates

a.

Within the first paragraph, last sentence – please clarify that the Dual Performance Trigger Rate for an Indexed Segment will not change mid-segment.

b.

Please clarify that the example is based on the initial performance rate.

Response:

a. If the Dual Performance Trigger Rate were to change it would only impact new investments and would not impact existing investments. We currently provide that it is determined at the beginning of each Indexed Term and would not, therefore, change mid-segment.

b. We have updated the chart accordingly.

7.

Dual15 Plus – Last paragraph – Unclear as to what this means, what is the initial and what is the subsequent rate? Also will need to add that it may not be available once expired.

Response: Clarification has been added.

8.

Protection Levels sub-section – Please provide where it will be added to the section.

Response: Additional language has been added to the supplement.

9.

Independent Registered Public Accounting Firm (p. ) – the language “and audited Financial statements to be included in subsequently filed documents will be” is not necessary and can be deleted.

Response: After reviewing this statement, our auditor has requested that we do not delete this language, even if perhaps it is not required.

10.

Appendix B (p. ) – Please clarity that the language will be added to the Fair Value of Replicating Portfolio of Options section and not the Derivative Asset Proxy section of Appendix B.

Response: This has been revised accordingly.

Comments pertaining to the Lincoln Level Advantage® B-Class Variable and Indexed-linked Annuity supplement and Lincoln Level Advantage® Advisory Class Variable and Indexed-linked Annuity:

1. Cover page and first page of prospectus: Please ensure that the legal name is used for both.

Response: Please be advised that all prospectuses will be updated to reflect to legal name as of post- ffective season of 2024.

2. Charges and Other Deductions – please restate within the supplement the section that is being replaced.

Response: This has been updated accordingly.

We intend to file the post-effective amendment on August 14, 2023, along with a request under Rule 461 for an accelerated effective date of August 14, 2023. Please advise if you believe this timetable is unreasonable.

Thank you for your attention to this filing, and your review and comments. Please call me at 860-466-2832 with any questions or additional comments.

Sincerely,
Nadine Rosin

Show Raw Text
CORRESP
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filename1.htm

    Law Department

    The Lincoln National Life Insurance Company

    350 Church Street

    Hartford, CT 06103

    Nadine Rosin

    Assistant Vice President

    and Senior Counsel

    Phone: 860-466-2832

    Nadine.Rosin@LFG.com

    VIA Email & EDGAR

    August 4, 2023

    Alberto Zapata

    Senior Counsel

    Disclosure Review and Accounting Office

    Division of Investment Management

    Securities and Exchange Commission

    100 F Street, NE

    Washington, DC 20549-8629

    Re:            Post-Effective Amendment No. 16 to the Registration Statement

    on Form N-4 for The Lincoln National Life Insurance Company

    File No. 333-222786

    Dear Mr. Zapata:

    This letter is in response to the comments received by telephone on July 31, 2023. All responses are how they appear within the prospectus.
      Corresponding changes will be applied to the other prospectuses of the registration statement, as applicable.

              1.

              Please add page numbers to the supplement that correspond with the underlying prospectuses.

    Response:  Since
      there are multiple prospectuses within the registration statement, it is difficult to specify the page numbers for all books and believe that it may be more confusing to the Contractowners to provide page numbers.

              2.

              Special Terms –

              a.

              Please clarify why there are two different crediting methods.  Please clarify the distinction.

              b.

              Should the term Dual15 Plus Rate be defined under Crediting Method?

    Response:

    a.    We have revised accordingly.

    b.    We have revised to accurately reflect the defined term Dual Rate.

              3.

              Risk Factors  –

              a.

              Under Dual Performance Trigger Rate – Segment Value is not a defined term within the underlying prospectus.

              b.

              Under Dual15 Plus - Segment Ending Value is not a defined term within the underlying prospectus.

    Response:.

     a.     We have revised to use the term to Segment Maturity Value, which is a defined term.

     b.    We have revised to use the term to Segment Maturity Value, which is a defined term.

              4.

              Investments
                    of the Indexed Accounts (p. ) – Please add a disclosure indicating that the footnotes are located within the underlying prospectus and have not changed.

    Response: Disclosure
      has been added.

              5.

              Crediting and Protection Methods sub-section chart

              a.

              Please replace the word “flat” within the heading of the first table to “zero”.

              b.

              Please clarify which chart the additional language will be located.

    Response:

              a.

              The chart heading has been revised accordingly and revised for clarification.

              b.

              The additional language will be added under the first chart with the heading:  “These are the Crediting Methods available when the
                index performance is positive (or zero for the Performance Trigger Rate; or zero or negative for the Dual Performance Trigger Rate and Dual15 Plus)”.

              6.

              Dual Performance Trigger Rates

              a.

              Within the first paragraph, last sentence – please clarify that the Dual Performance Trigger Rate for an Indexed Segment will not
                change mid-segment.

              b.

              Please clarify that the example is based on the initial performance rate.

    Response:

    a.   If the Dual Performance Trigger Rate were to change it would only impact new investments and would not impact existing
      investments. We currently provide that it is determined at the beginning of each Indexed Term and would not, therefore, change mid-segment.

           b.  We have updated the chart accordingly.

              7.

              Dual15 Plus  – Last paragraph
                – Unclear as to what this means, what is the initial and what is the subsequent rate?  Also will need to add that it may not be available once expired.

    Response:
      Clarification has been added.

              8.

              Protection Levels sub-section
                – Please provide where it will be added to the section.

    Response:
      Additional language has been added to the supplement.

              9.

              Independent Registered Public Accounting
                    Firm (p. ) – the language “and
                audited Financial statements to be included in subsequently filed documents will be” is not necessary and can be deleted.

    Response: After
      reviewing this statement, our auditor has requested that we do not delete this language, even if perhaps it is not required.

              10.

              Appendix B (p. ) – Please
                clarity that the language will be added to the Fair Value of Replicating Portfolio of Options section and not the Derivative Asset Proxy section of Appendix B.

    Response:  This has
      been revised accordingly.

    Comments pertaining to the Lincoln Level Advantage® B-Class Variable and Indexed-linked Annuity supplement and Lincoln Level Advantage® Advisory Class Variable and Indexed-linked Annuity:

    1.    Cover page and first page of prospectus:  Please ensure that the legal name is used for both.

            Response:  Please be advised that all
      prospectuses will be updated to reflect to legal name as of post- ffective season of 2024.

    2.   Charges and Other Deductions –
      please restate within the supplement the section that is being replaced.

           Response:  This has been updated
      accordingly.

    We intend to file the post-effective amendment on August 14, 2023, along with a request under Rule 461 for an accelerated effective date of
      August 14, 2023. Please advise if you believe this timetable is unreasonable.

    Thank you for your attention to this filing, and your review and comments. Please call me at 860-466-2832 with any questions or additional
      comments.

    Sincerely,

    Nadine Rosin

    Nadine Rosin

      THE LINCOLN NATIONAL LIFE INSURANCE COMPANY

      Lincoln Life Variable Annuity Account N

      Lincoln Level Advantage® B Share variable and index-linked annuity

      Lincoln
          Level Advantage® B Class variable and index-linked annuity

      Lincoln
          Level Advantage® Access variable and index-linked annuity

      Lincoln Level Advantage® Advisory variable and index-linked annuity

      Lincoln
          Level Advantage® Advisory Class variable and index-linked annuity

      Lincoln
          Level Advantage® Design Advisory variable and index-linked annuity

      Lincoln
          Level Advantage® Design B Share variable and index-linked annuity

      Lincoln
          Level Advantage® Select B Share variable and index-linked annuity

      Supplement dated June 16, 2023 to the prospectus dated May 1, 2023

      This supplement describes changes to the prospectus for your Lincoln Level Advantage® variable and index-linked annuity contract.  It is for informational purposes and requires no action on your part. All other provisions in your prospectus
        not discussed in this supplement remain unchanged.

      Overview

      Several new Indexed Accounts will be available for new Contracts beginning on or about
        August 21, 2023.  You can find complete details about all of the features of your Contract in your prospectus.  The following revisions are in the order in which they appear in your prospectus.

      Description of Changes

      The following terms have been added to the Special Terms section:

      Dual
          Performance Trigger Rate – The rate used, in part, to determine the Performance Rate for an Indexed Segment at the end of the Indexed Term if the Index performance is positive, negative or zero. A different Dual Performance Trigger Rate
        may be declared for each Indexed Segment and for each Death Benefit type.

      Dual15
          Plus – A Crediting Method that uses a Performance Cap and Dual Rate to determine the Performance Rate for and Indexed Segment at the end of the Indexed Term.

      Dual Rate
        - The rate used, in part, to determine the Performance Rate for an Indexed Segment of a Dual15 Plus Indexed Account at the end of the Indexed Term if the Index performance is positive, negative or zero. For Dual15 Plus Indexed Segments, the Dual
        Rate is 15%.

      The following term has been revised:

      Crediting
          Method – The method used in determining the Performance Rate for an Indexed Segment. There are several Crediting Methods including Performance Cap, Participation Rate, Performance Trigger Rate, Dual Performance Trigger Rate, Dual15 Plus,
        and Spread Rate.

      Risk Factors – In addition to those Risk Factors outlined in Risks of Investing in the Indexed Accounts section, the following potential risks are associated with Dual Performance Trigger Rate and Dual15 Plus Indexed Accounts and is added to the Risks of Investing in the Indexed
          Accounts section.

                •

                Gains in your Indexed Segment are limited by any applicable Dual Performance Trigger Rate. If the performance of the
                  Index is zero, positive, or negative, the Dual Performance Trigger Rate is used in determining the Segment Maturity Value. The Dual Performance Trigger Rate may be lower than the actual performance of the Index, which means that your
                  return could be lower than if you had invested directly in a fund based on the applicable Index. The Dual Performance Trigger Rate applies for the full term of the Indexed Segment. The Dual Performance Trigger Rate will be lower for
                  contracts with the Guarantee of Principal Death Benefit. Dual Performance Trigger Rates for new Segments will be declared at least 5 business days in advance of the beginning of a Segment.

                ●

                Gains in your Dual15 Plus Indexed Segment are limited by any applicable Performance Cap, which means that your return
                  could be lower than if you had invested directly in a fund based on the applicable Index. If the performance of the Index is zero, positive, or negative, a Dual Rate is used to determine the Segment Maturity Value. The Performance Cap
                  exists for the full term of the Indexed Segment. The Performance Cap will be lower for Contracts with the Guarantee of Principal Death Benefit. Performance Caps for new Segments will be declared at least 5 business days in advance of the
                  beginning of a Segment. Subsequent Performance Caps may differ from the Performance Cap used for new Contracts or for other Contracts issued at different times.

      Investments of the Indexed Accounts -The following discussion describes changes and additions to the sub-sections of the Investments of the Indexed Accounts section.

      The following Indexed Accounts are added to the list of available
        Indexed Accounts, available to new Contracts beginning on or about August 21, 2023:

      The
          following Indexed Accounts will be available for contracts purchased on or after August 21, 2023, subject to state availability.  (See your prospectus for the
        complete description of all footnotes.)

      1-Year Dual Performance Trigger Rate Indexed Account with Protection
        Level

                •

                S&P 500®, Dual Performance Trigger(1), 10% Protection

                •

                Russell 2000®, Dual Performance Trigger(2), 10% Protection

                •

                Capital Strength Net Fee IndexSM, Dual Performance Trigger(3), 10% Protection

                •

                First Trust American Leadership IndexSM, Dual Performance Trigger(4), 10% Protection

      6-Year Dual15 Plus Indexed Account

                •

                S&P 500®

                •

                Russell 2000®

                •

                Capital Strength Net Fee IndexSM

                •

                First Trust American Leadership IndexSM

      The first paragraph of the Crediting and Protection Methods sub-section
        is changed; it is replaced with the following paragraph:

      Different Crediting and Protection Methods are available for your Indexed Account and are listed in the chart
        below. Interest is credited for any performance earned or deducted for any loss only on the End Date of a Segment. If the End Date is not a Valuation Date, then the amount will be credited or deducted on the next business day.

      The heading for the first chart under Crediting and Protection Methods
        has been changed to:

      These are the Crediting Methods available
        when the index performance is positive (or zero for the Performance Trigger Rate; or zero or negative for the Dual Performance Trigger Rate and Dual15 Plus):

      The following additional language is added to the chart in the
        Crediting and Protection Methods sub-section “These are the Crediting Methods available when the index performance is positive (or zero for the Performance Trigger Rate; or zero or negative for the Dual Performance Trigger Rate and Dual15 Plus):”

              Dual Performance Trigger Rate

              You receive 1) the Dual Performance Trigger Rate if the Index performance is zero, positive, or
                negative within the Protection Level; or 2) the Index performance percentage plus the Protection Level plus the Dual Performance Trigger Rate if the Index performance is negative and beyond the Protection Level.

              Dual15 Plus

              You receive the 1) the Dual Rate if the Index performance is zero or positive and equal to or less
                than the Dual Rate; or 2) the Index performance up to the Performance Cap if the Index performance is higher than the Dual Rate; or 3) the Performance Cap if the Index performance is higher than the Performance Cap; or 4) the Index
                performance plus the Dual Rate if the Index performance is negative.

      The following sections are added as a new sub-sections immediately
        prior to the Protection Levels sub-section:

      Dual
          Performance Trigger Rates – The Dual Performance Trigger Rate is a rate of return for an Index Segment that we declare at the beginning of the Indexed Term. It is used, in part, to determine the Segment
        Maturity Value if the Index return for the Indexed Term is zero, positive, or negative. If Lincoln changes the Dual Performance Trigger Rate for an Indexed Segment, that change will only apply to new investments, and will not impact any current
        investments in that Indexed Account.

      The Dual Performance Trigger Rate may vary depending on the Death Benefit option, the
        Index, the Term, and the Protection Level.

      The initial Dual Performance Trigger Rate applies to the initial Indexed Term. Indexed
        Segments with a Guarantee of Principal Death Benefit will have lower Dual Performance Trigger Rates than Indexed Segments with the Account Value Death Benefit. The Company will declare, at its discretion, a Dual Performance Trigger Rate for each
        subsequent Indexed Term, if any. Subsequent Dual Performance Trigger Rates may differ from the Dual Performance Trigger Rate used for new Contracts or for other Contracts issued at different times.

      The Performance Rate is the percentage change in the Index Value from the Start Date to the
        End Date, adjusted by the Protection Level and the Dual Performance Trigger Rate. The Performance Rate can be positive, negative, or zero. The percentage