Correspondence 0000726865-23-000303 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: 0000726865-23-000303
AI Filing Summary & Sentiment
File numbers found in text: 333-249922, 811-08557
Letter
VIA EDGAR Division of Investment Management The Lincoln National Life Insurance Company File No: 333-249922; 811-08557; CIK: 0001048607 Post-Effective Amendment No.: 3 on Form N-6, Rule 485(a) Lincoln VULONE 2021
Dear Mr. Oh:
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:
We have updated certain sections within the prospectus that were not specifically commented on but were relevant to other comments that required updating.
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 (pgs. 9-10)
We have added additional disclosure regarding current investment restrictions pursuant to the comment to add disclosure about current investment restriction under Risks in the “Important Information You Should Consider About the Policy” table (pg. 7).
4.
Fee Table (p.10)
Please provide a narrative regarding Premium Tax within the prospectus.
Response: Pursuant to your request we have revised accordingly.
5.
Periodic Charges Other Than Annual Underlying Fund Fees and Operating Expenses (pgs. 11-14)
a.
Under Interest on Accelerated Benefit Lien, please add narrative.
Response: Per our conversation the 11b and 11c disclosure is within the narrative of the benefit.
b.
Under Lincoln LifeEnhance Accelerated Benefits Rider remove “Cost of Insurance” .
Response: Pursuant to your request, we have revised accordingly.
c.
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.
d.
Under Footnote #3 – please confirm charge.
Response: We have confirmed the charge and no update is required.
6.
Annual Fund Expenses (p. 14)
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. 15-17)
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. 23-27)
Please add a narrative for Premium Tax.
Response: Pursuant to your request, we have revised accordingly.
9.
Other Benefits Available Under the Policy (pgs. 34-38)
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.
Under the No-Lapse Enhancement Rider – although we did not receive a specific comment on this section, we have added additional disclosure pursuant to the comment to add current investment restrictions to the “Important Information You Should Consider About the Policy” table (pg. 7).
c.
Please change Premium Reserve Rider to Standard as it is issued with the policy.
Response: Pursuant to your request, we have revised accordingly.
d.
Please change Automatic Rebalancing to Standard.
Response: After careful consideration, this should remain Optional.
10.
No-Lapse Enhancement Rider (pgs. 58-63)
a.
We have added additional disclosure after the first paragraph pursuant to the comment to move the narrative under Appendix A “Current Investment Restrictions for Optional Benefits” within the body of the rider. We have also amended language regarding current investment restrictions.
b.
Allocation Requirements: Please move narrative under Appendix A “Current Investment Restrictions for Optional Benefits” within the body of the rider. Also, amend language regarding imposing restrictions.
Response: Pursuant to your request, we have revised all paragraphs accordingly and have additionally made provisions from the comments to include current investment restrictions.
11.
Overloan Protection Rider (pgs. 63-64)
Please explain what the adverse tax consequences are.
Response: The exercising of this rider does not cause tax consequences. This statement is warning the owner to monitor their policy to ensure they continue to meet the rider eligibility requirements. It is the failure to meet eligibility for the Rider that causes the tax consequences. We have revised accordingly.
12.
Automatic Rebalancing (pg. 67)
Please be more specific as to where the owner can cross-reference the requirements pursuant to Item 18, Instruction F.
Response: Pursuant to your request, we have revised accordingly.
13.
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 the Average Annual Total Returns have been updated.
Response: All 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 – No-Lapse Enhancement 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. 15-17) and the “No-Lapse Enhancement Rider” (pgs. 58-63).
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.
A courtesy copy of this Registration Statement will be forwarded under separate cover to our Reviewer.
Please contact me at (336) 691-3892 with any questions or comments about this filing.
Sincerely,
/s/Jassmin McIver-Jones
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filename1.htm
Jassmin McIver-Jones
Assistant Vice President, Legal
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. Sonny Oh
U.S. Securities and Exchange Commission
Division of Investment Management
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: 333-249922; 811-08557; CIK: 0001048607
Post-Effective Amendment No.: 3 on Form N-6, Rule 485(a)
Lincoln VULONE 2021
Dear Mr. Oh:
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:
We have updated certain sections within the prospectus that were not specifically commented on but were relevant to other comments that
required updating.
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 (pgs. 9-10)
We have added additional disclosure regarding current investment restrictions pursuant to the comment to add disclosure about current investment
restriction under Risks in the “Important Information You Should Consider About the Policy” table (pg. 7).
4.
Fee Table (p.10)
Please provide a narrative regarding Premium Tax within the prospectus.
Response: Pursuant to your request we have revised accordingly.
5.
Periodic Charges Other Than Annual Underlying Fund Fees and Operating Expenses (pgs. 11-14)
a.
Under Interest on Accelerated Benefit Lien, please add narrative.
Response: Per our conversation the 11b and 11c disclosure is
within the narrative of the benefit.
b.
Under Lincoln LifeEnhance Accelerated Benefits Rider remove “Cost of Insurance” .
Response: Pursuant to your request, we have revised accordingly.
c.
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.
d.
Under Footnote #3 – please confirm charge.
Response: We have confirmed the charge and no update is
required.
6.
Annual Fund Expenses (p. 14)
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. 15-17)
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. 23-27)
Please add a narrative for Premium Tax.
Response: Pursuant to your
request, we have revised accordingly.
9.
Other Benefits Available Under the Policy (pgs. 34-38)
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.
Under the No-Lapse Enhancement Rider – although we did not receive a specific comment on this section, we have added
additional disclosure pursuant to the comment to add current investment restrictions to the “Important Information You Should Consider About the Policy” table (pg. 7).
c.
Please change Premium Reserve Rider to Standard as it is issued with the policy.
Response: Pursuant to your request, we have revised accordingly.
d.
Please change Automatic Rebalancing to Standard.
Response: After careful consideration, this should remain
Optional.
10.
No-Lapse Enhancement Rider (pgs. 58-63)
a.
We have added additional disclosure after the first paragraph pursuant to the comment to move the narrative under Appendix A “Current Investment
Restrictions for Optional Benefits” within the body of the rider. We have also amended language regarding current investment restrictions.
b.
Allocation Requirements: Please move narrative under Appendix A “Current Investment Restrictions for Optional Benefits” within the body of the rider.
Also, amend language regarding imposing restrictions.
Response: Pursuant to your request, we have revised all
paragraphs accordingly and have additionally made provisions from the comments to include current investment restrictions.
11.
Overloan Protection Rider (pgs. 63-64)
Please explain what the adverse tax consequences are.
Response: The exercising of this rider does not cause tax
consequences. This statement is warning the owner to monitor their policy to ensure they continue to meet the rider eligibility requirements. It is the failure to meet eligibility for the Rider that causes the tax consequences. We have revised
accordingly.
12.
Automatic Rebalancing (pg. 67)
Please be more specific as to where the owner can cross-reference the requirements pursuant to Item 18, Instruction F.
Response: Pursuant to your
request, we have revised accordingly.
13.
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 the Average Annual Total Returns have been updated.
Response: All 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 – No-Lapse Enhancement 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. 15-17) and the “No-Lapse Enhancement Rider” (pgs. 58-63).
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.
A courtesy copy of this Registration Statement will be forwarded under separate cover to our Reviewer.
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 VULONE 2021
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 VULONE 2021 Flexible Premium Variable Life Policy issued by us, The Lincoln National Life
Insurance Company.
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
10
Other Benefits Available
Under the Policy
11
Buying the Policy
15
Contents
Page
Premiums
15
Allocation of Net
Premium Payments
15
Planned Premiums;
Additional Premiums
16
How your policy can
lapse
16
Reinstatement of a
Lapsed Policy
17
Making withdrawals:
accessing the money in
your policy
17
Partial Surrender
18
Additional
information about fees
19
Appendix A: Funds
Available Under the policy
A - 1
Appendix B: Current
Investment Restrictions for
Optional Benefits –
No-Lapse Enhancement
Rider
B - 1
2
SPECIAL TERMS
The following terms may appear in your prospectus and are defined below:
Accelerated Benefit—A portion of the death benefit paid when eligibility requirements are met and/or certified, or upon the occurrence of one or more qualifying events, as described in the Accelerated Benefits Rider.
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 excess of the policy value. It is determined by multiplying the Policy's Net Amount at Risk by the Cost of Insurance rate.
Death Benefit Proceeds—The amount payable to the Beneficiary upon the death of the Insured. Loans, loan interest, Partial Surrenders, and overdue charges, if any, are deducted prior to payment of the Death Benefit Proceeds. Riders may impact the amount payable as Death Benefit Proceeds in your Policy.
Debt—The sum of
all outstanding loans and accrued interest. May also be referred to as Indebtedness in your Policy.
Fi