Correspondence 0000726865-23-000299 from LINCOLN LIFE FLEXIBLE PREMIUM VARIABLE LIFE ACCOUNT M (CIK 0001048607)
LINCOLN LIFE FLEXIBLE PREMIUM VARIABLE LIFE ACCOUNT M (CIK 0001048607)
Date: April 18, 2023 · CIK: 0001048607 · Accession: 0000726865-23-000299
AI Filing Summary & Sentiment
File numbers found in text: 333-248990, 811-08557
Letter
VIA EDGAR The Lincoln National Life Insurance Company File No: 333-248990; 811-08557; CIK: 0001048607 Post-Effective Amendment No: 9 on Form N-6, Rule 485(a) Lincoln MoneyGuard Market Advantage®
Dear Mr. Zapata:
This is in response to your recent comments in the order in which they were received. A strikethrough version of the prospectus containing these revisions will be provided under separate cover.
1.
General Comments:
a.
Please confirm all state variations are discussed within the prospectus.
Response: We have confirmed all material state variations are discussed within the prospectus.
We have also updated certain sections within the prospectus that were not specifically commented on but felt for disclosure purposes needed to be addressed.
2.
Important Information You Should Consider About the Policy table (pgs. 6-8)
a.
Please remove the narrative under the table. This should be a global change.
Response: Pursuant to your request we have removed the narrative under the table and updated per the Form N-6.
b.
Please add additional disclosure under Investments within the Restrictions section of the table.
Response: Pursuant to your request we have revised the disclosure accordingly.
3.
Overview of the Policy – subsection: What are the primary Features and options that the Policy offers (Tax Treatment) (pg. 9)
Please add applicable tax language regarding consequences in the event of a surrender if owner is under age 591/2.
Response: Pursuant to your request, we have revised accordingly.
4.
Fee Table (pgs. 10-11)
a.
Please break out the Premium Tax as a separate line item and provide a narrative within the prospectus.
Response: Pursuant to your request, we have revised accordingly.
b.
Please confirm footnote #1 is accurate.
Response: Pursuant to your request, we have revised accordingly.
5.
Periodic Charges Other Than Annual Underlying Fund Fees and Operating Expenses (pgs. 11-12)
Under Long-Term Care Rider please move the “*” to the first column after the rider name.
Response: Pursuant to your request, we have revised accordingly.
6.
Annual Fund Expenses (p. 12)
Please consider significantly shortening the footnote and refer owner to the underlying fund prospectus for more information.
Response: Pursuant to your request, we have revised accordingly
7.
Principal Risks of Investing in the Policy (pgs. 13-15)
a.
We have included a section titled “Investment Restriction Compliance” for additional disclosure per the comment to move narrative under Appendix A “Current Investment Restrictions for Optional Benefits” within the body of the rider. Also, amended language regarding imposing restrictions.
8.
Policy Charges and Fees (pgs. 21-25)
a.
Premium Load; Net Premium – please explain supplementally if expenses will vary along with how and why they would vary and the impact.
Response: This may vary per distribution channel, but will not exceed the maximum shown in the “Fee Table”.
b.
Please add a narrative for Premium Tax.
Response: Pursuant to your request, we have revised accordingly.
9.
Other Benefits Available Under the Policy (pgs. 30-38)
a.
Please group all the Standard benefits and Optional benefits together per Item 11b. If possible, please list as they appear in the prospectus.
Response: Pursuant to your request, we have revised accordingly. Please be aware due to these changes there may be significant blacklining within the prospectus.
b.
Please change Premium Reserve Rider to Standard as it is issued with the policy.
Response: Pursuant to your request, we have revised accordingly.
c.
Please change Automatic Rebalancing to Standard.
Response: After careful consideration, this should remain Optional.
d.
Under the Long-Term Care Benefits Rider (pgs. 31-40)
•
Please explain substantial/hands-on reference along with the term Medical.
Response: Hands-on was added to the definition due to a California request. Also, California asked us to add their state’s program name of Medi-CAL along with the generic Medicare. As of this date, there have been no California sales.
•
Please explain that LNL not paying costs due to owner already being reimbursed by Medicare/Medi-CAL.
Response: That is correct, LNL is not paying because it has already been paid.
•
Elimination Period, does this only apply to California.
Response: This applies to all owners. It was added to the Special Terms section for clarification purposes.
•
Under Impact of Benefit Payments on Policy Values: please add “greater than” within the parenthetical (greater than or equal to the Policy’s Specified Amount if issued in the Sate of California). Also, indicate that the added language relates to California.
Response: Pursuant to your request, we have revised accordingly.
•
Reinstatement of Rider: Does the 5-month special provision only applicable to California.
Response: Yes, the 5-month special provision is only applicable to California. Pursuant to your request, we have revised accordingly.
e.
Value Protection Rider:
•
Please confirm allocation requirements are imposed to reduce the risk of investment losses is captured in the key information table.
Response: We confirm this is captured in the key information table.
•
Allocation Requirement: Please move narrative under Appendix A “Current Investment Restrictions for Optional Benefits” within the body of the rider.
Response: Pursuant to your request, we have updated accordingly
10.
Policy Loans (pg. 55-56): Regarding the last paragraph “ Please note that there may be adverse tax consequences in the event that your Policy Lapses with an outstanding loan balance. Please direct the owner to where it is discussed further in the prospectus.
Response: Pursuant to your request, we have revised accordingly.
11.
Appendix A: Funds Available Under the Policy
a.
Please provide specific information on current and added restrictions.
Response: Pursuant to your request, we have revised accordingly.
b.
Please ensure all funds have been assigned a tier and the Average Annual Total Returns have been updated.
Response: All funds have been reviewed and are assigned to a tier and percentages have been updated. Please be aware due to these changes there may be significant blacklining within the prospectus.
c.
Please create an Appendix B to address - Current Investment Restrictions for Optional Benefits – Value Protection Rider and separate the fund names in the tiers for clarity.
Response: Pursuant to your request, we have revised accordingly.
d.
Please move allocation restrictions from the appendix into the rider description.
Response: Pursuant to your request, we have revised accordingly and updated disclosure under “Principal Risks of Investing in the Policy” (pgs. 13-15) and the “Value Protection Rider” (pgs. 46-48).
Comments on the ISP – Carry through all comments on the statutory prospectus
Cover page: Please ensure that 10-day language is carried over from the cover page of the statutory prospectus.
Response: Pursuant to your request, we have revised accordingly.
Please contact me at (336) 691-3892 with any questions or comments about this filing.
Sincerely,
/s/Jassmin McIver-Jones
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CORRESP
1
filename1.htm
Jassmin McIver-Jones
Assistant Vice President
The Lincoln National Life Insurance Company
100 N. Greene Street
Greensboro, North Carolina 27401
Telephone: (336)691-3892
Jassmin.McIver-Jones@LFG.com
VIA EDGAR
April 14, 2023
Mr. Alberto Zapata
U.S. Securities and Exchange Commission
100 F Street, N. E.
Washington, DC 20549-0506
Re: Lincoln Life Flexible Premium Variable Life Account M
The Lincoln National Life Insurance Company
File No: 333-248990; 811-08557; CIK: 0001048607
Post-Effective Amendment No: 9 on Form N-6, Rule 485(a)
Lincoln MoneyGuard Market Advantage®
Dear Mr. Zapata:
This is in response to your recent comments in the order in which they were received. A strikethrough version of the prospectus containing these revisions will be
provided under separate cover.
1.
General Comments:
a.
Please confirm all state variations are discussed within the prospectus.
Response: We have confirmed all material state variations are
discussed within the prospectus.
We have also updated certain sections within the prospectus that were not specifically commented on but felt for disclosure purposes needed to
be addressed.
2.
Important Information You Should Consider About the Policy table (pgs. 6-8)
a.
Please remove the narrative under the table. This should be a global change.
Response: Pursuant to your request we have removed the narrative
under the table and updated per the Form N-6.
b.
Please add additional disclosure under Investments within the Restrictions section of the table.
Response: Pursuant to your request we have revised the disclosure
accordingly.
3.
Overview of the Policy – subsection: What are the primary Features and options that the Policy offers (Tax Treatment) (pg. 9)
Please add applicable tax language regarding consequences in the event of a surrender if owner is under age 591/2.
Response: Pursuant to your request,
we have revised accordingly.
4.
Fee Table (pgs. 10-11)
a.
Please break out the Premium Tax as a separate line item and provide a narrative within the prospectus.
Response: Pursuant to your request, we have revised
accordingly.
b.
Please confirm footnote #1 is accurate.
Response: Pursuant to your request, we have revised
accordingly.
5.
Periodic Charges Other Than Annual Underlying Fund Fees and Operating Expenses (pgs. 11-12)
Under Long-Term Care Rider please move the “*” to the first column after the rider name.
Response: Pursuant to your request, we have revised accordingly.
6.
Annual Fund Expenses (p. 12)
Please consider significantly shortening the footnote and refer owner to the underlying fund prospectus for more information.
Response: Pursuant to your request, we have revised accordingly
7.
Principal Risks of Investing in the Policy (pgs. 13-15)
a.
We have included a section titled “Investment Restriction Compliance” for additional disclosure per the comment to move narrative under Appendix A “Current
Investment Restrictions for Optional Benefits” within the body of the rider. Also, amended language regarding imposing restrictions.
8.
Policy Charges and Fees (pgs. 21-25)
a.
Premium Load; Net Premium – please explain supplementally if expenses will vary along with how and why they would vary and the impact.
Response: This may vary per distribution channel, but will not
exceed the maximum shown in the “Fee Table”.
b.
Please add a narrative for Premium Tax.
Response: Pursuant to your request,
we have revised accordingly.
9.
Other Benefits Available Under the Policy (pgs. 30-38)
a.
Please group all the Standard benefits and Optional benefits together per Item 11b. If possible, please list as they appear in the prospectus.
Response: Pursuant to your request, we have revised accordingly.
Please be aware due to these changes there may be significant blacklining within the prospectus.
b.
Please change Premium Reserve Rider to Standard as it is issued with the policy.
Response: Pursuant to your request, we have revised accordingly.
c.
Please change Automatic Rebalancing to Standard.
Response: After careful consideration, this should remain
Optional.
d.
Under the Long-Term Care Benefits Rider (pgs. 31-40)
•
Please explain substantial/hands-on reference along with the term Medical.
Response: Hands-on was added to the definition due to a
California request. Also, California asked us to add their state’s program name of Medi-CAL along with the generic Medicare. As of this date, there have been no California sales.
•
Please explain that LNL not paying costs due to owner already being reimbursed by Medicare/Medi-CAL.
Response: That is correct, LNL is not paying because it has
already been paid.
•
Elimination Period, does this only apply to California.
Response: This applies to all owners. It was added to the
Special Terms section for clarification purposes.
•
Under Impact of Benefit Payments on Policy Values: please add “greater than” within the parenthetical (greater than or equal to the Policy’s Specified
Amount if issued in the Sate of California). Also, indicate that the added language relates to California.
Response: Pursuant to your request, we have revised
accordingly.
•
Reinstatement of Rider: Does the 5-month special provision only applicable to California.
Response: Yes, the 5-month special provision is only applicable
to California. Pursuant to your request, we have revised accordingly.
e.
Value Protection Rider:
•
Please confirm allocation requirements are imposed to reduce the risk of investment losses is captured in the key information table.
Response: We confirm this is captured in the
key information table.
•
Allocation Requirement: Please move narrative under Appendix A “Current Investment Restrictions for Optional Benefits” within the body of the rider.
Response: Pursuant to your request, we have updated accordingly
10.
Policy Loans (pg. 55-56): Regarding the last paragraph “ Please note that
there may be adverse tax consequences in the event that your Policy Lapses with an outstanding loan balance. Please direct the owner to where it is discussed further in the prospectus.
Response: Pursuant to your request, we have revised
accordingly.
11.
Appendix A: Funds Available Under the Policy
a.
Please provide specific information on current and added restrictions.
Response: Pursuant to your request, we have revised accordingly.
b.
Please ensure all funds have been assigned a tier and the Average Annual Total Returns have been updated.
Response: All funds have been reviewed and are assigned to a tier
and percentages have been updated. Please be aware due to these changes there may be significant blacklining within the prospectus.
c.
Please create an Appendix B to address - Current Investment Restrictions for Optional Benefits – Value Protection Rider and separate the fund names in
the tiers for clarity.
Response: Pursuant to your request, we have revised accordingly.
d.
Please move allocation restrictions from the appendix into the rider description.
Response: Pursuant to your request, we have revised accordingly
and updated disclosure under “Principal Risks of Investing in the Policy” (pgs. 13-15) and the “Value Protection Rider” (pgs. 46-48).
Comments on the ISP – Carry through all comments on the statutory prospectus
Cover page: Please ensure that 10-day language is carried over from the cover page of the statutory prospectus.
Response: Pursuant to your request, we have revised accordingly.
Please contact me at (336) 691-3892 with any questions or comments about this filing.
Sincerely,
/s/Jassmin McIver-Jones
Jassmin McIver-Jones
Assistant Vice President
Lincoln MoneyGuard Market Advantage®
Summary Prospectus for New Investors
May 1, 2023
The Lincoln National Life Insurance Company
Lincoln Life Flexible Premium Variable Life Account M
This summary prospectus summarizes key features of the Lincoln MoneyGuard Market Advantage® Flexible Premium Variable Life Policy issued by us, The Lincoln National
Life Insurance Company.
This Policy is available through third-party financial intermediaries who charge an
advisory fee for their services. The fee is paid directly to the third-party financial intermediary from the Owner. The advisory fee is in addition to Policy fees and expenses. We do not receive any portion of this fee. Lincoln does not pay commissions to third-party financial intermediaries because such intermediaries receive compensation in connection with
the Policy through a contract between the third-party financial intermediaries and the Owner.
Before you invest, you should review the prospectus, which contains more information
about the Policy’s features, benefits, and risks. You can find the prospectus and other information about the Policy online at www.lfg.com/VULprospectus. You can also obtain this information at no cost by calling 1-800-487-1485 or by sending an email request to CustServSupportTeam@lfg.com.
The prospectus gives you information about the Policy that you should know before you
decide to buy a Policy and make Premium Payments. You should also review the prospectuses for the funds and keep all prospectuses for future reference. All prospectuses and other shareholder reports will be made available on www.lfg.com/VULprospectus. If you wish to receive future shareholder reports in paper, free of charge, please call us at
1-800-487-1485, send an email request to CustServSupportTeam@lfg.com, or contact your registered representative. Your election to receive reports in paper will
apply to all funds available under your Policy.
* * * * * * * * * * * *
YOU MAY CANCEL YOUR POLICY WITHIN THE FREE LOOK PERIOD WITHOUT PAYING
FEES OR PENALTIES
If you are a new investor in the Policy, you may cancel your Policy within 10 days of
receiving it without paying fees or penalties. In some states,
this cancellation period may be longer. Upon cancellation, you will receive either a full refund of the amount you paid with your application or your
total contract value. You should review the prospectus, or consult with your investment professional, for additional information about the specific cancellation terms that apply.
* * * * * * * * * * * *
Additional information about certain investment products, including variable life
insurance policies, has been prepared by the Securities and Exchange Commission’s staff and is available at Investor.gov.
The Securities and Exchange Commission has not approved or disapproved
the contract or passed upon the adequacy of this Summary Prospectus. Any representation to the contrary is a criminal offense.
Table of Contents
Contents
Page
SPECIAL TERMS
3
Important Information You
Should Consider
About the Policy
5
Overview of the policy
8
What is the purpose of the
Policy?
8
When do I have to pay
Premiums and how do
they get invested?
8
What are the primary
features and options
that the Policy Offers?
8
Standard DEATH BENEFITS
9
Death Benefit Proceeds
9
Death Benefit Qualification
Test
9
Payment of Death Benefit
Proceeds
9
Other Benefits Available
Under the Policy
10
Contents
Page
Buying the Policy
11
Premiums
11
Allocation of Net
Premium Payments
11
Planned Premiums;
Additional Premiums
12
How your policy can
lapse
12
Reinstatement of a
Lapsed Policy
13
Making withdrawals:
accessing the money in
your policy
13
Partial Surrender
14
Additional information
about fees
14
Appendix A: Funds
Available Under the policy
A - 1
Appendix B: Current
Investment Restrictions for
Optional Benefits – Value
Protection Rider
B - 1
2
SPECIAL TERMS
The following terms may appear in your prospectus and are defined below:
Accumulation Value (Total Account Value)—An amount equal to the sum of the Fixed Account Value, the
Separate Account Value, and the Loan Account Value.
Attained Age—An
Insured’s Issue Age (shown in the Policy Specifications) plus the number of completed Policy
Years.
Beneficiary—The
person designated to receive the Death Benefit Proceeds.
Cash Value Accumulation Test—A provision of the Code that requires that the death benefit be sufficient to prevent the Accumulation Value from ever exceeding the net single Premium required to fund the future benefits under the Policy.
Cost of Insurance Charge—This charge is the portion of the Monthly Deduction designed to compensate the Company for the anticipated cost of paying death benefits in exc