SecProbe.io

CORRESP
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  Brittany S. Speas

  Counsel

  The Lincoln National Life Insurance Company

  100 N. Greene Street

  Greensboro, North Carolina 27401

  Telephone: (743) 867-0064

  Brittany.speas@lfg.com

  VIA EDGAR

  April 24, 2024

  Mr. Alberto Zapata

  Senior Counsel

  Disclosure Review and Account Office

  Division of Investment Management

  Securities and Exchange Commission

  Room 8634; Mail Stop 8629

  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: 333-276970; 811-08557; CIK: 0001048607

        Pre-Effective Amendment No. 1 to the Initial Registration Statement, Form N-6

        Lincoln  MoneyGuard Market Advantage® (2024)

  Dear Mr. Zapata:

  This letter is in response to the comments received by telephone April 15, 2024.  The attached prospectus pages for Lincoln MoneyGuard Market Advantage® (2024) are blacklined to reflect the changes requested.

            1.

            Periodic Charges Other Than
                  Annual Underlying fund Fees and Operating Expenses – sub-section “Optional Benefit Charges” footnote *– (p. 13) .  How does the cost vary on whether a person has the right to purchase the Optional Inflation Protection? If this
              is described elsewhere, please indicate where?

  Response: We have revised accordingly and provided the section of the prospectus where this is described in further detail.

            2.

            Rider Charges – (p. 27).  Please indicate what
              the Base and Excess Charge rates are and what they cover.  Please explain the distinction between the Indemnity Choice Option or Reimbursement Option.

  Response: We have revised accordingly
    indicating they are based on individual characteristics of the Insured and have provided the section that fully describes each charge and how it applies to either the Indemnity Choice Option or the Reimbursement Option in further detail.

            3.

            Long-Term Care Benefits Rider – sub-section “Benefit
                  Payment Options”  – (p. 36).  Please bold the last sentence of the second paragraph.  If this is stated previously- please bold there as well.

  Response: We have bolded this sentence
    as requested.  This is the only time this statement appears in the prospectus.

  Thank you for your attention to this filing, and your review and comments. Please call me at the number provided above with any
    questions or additional comments.

  Sincerely,

  Brittany S. Speas

  Brittany S. Speas

            Charge

            When Charge is Deducted

            Amount Deducted

            Policy Loan Interest

            Annually

            A percentage of the amount held in the Loan Account:2

            •3.00%

            Optional Benefit Charges

            Long-Term Care Benefits Rider*

            Base Charge Rate

            Monthly

            As a dollar amount per $1,000 of Base LTC Limit Value:

            •Maximum: $2.44965 per $1,000

            •Minimum: $0.0977 per $1,000

            •Maximum Charge for a Representative Insured (male, age
                45): $1.12301 per $1,000

            Long-Term Care Benefits Rider*

            Excess Charge Rate

            Monthly

            As a dollar amount per $1,000 of highest LTC Limit Value minus Base LTC Limit Value:

            •Maximum: $1.53822 per $1,000

            •Minimum: $0.06651 per $1,000

            •Maximum Charge for a Representative Insured (male, age
                45): $0.81886 per $1,000

            Benefit Transfer Rider Loan

            Annually

            A percentage of the Loan balance amount against the Rider’s Cash Surrender Value:

            •4%

          *

            These charges and costs vary based on individual characteristics of the Insured and Right to Purchase Optional Inflation Protection election shown in the Policy Specifications. The
              charges and costs shown in the table may not be representative of the charges and costs that a particular Owner will pay. You may obtain more information about the particular charges that would apply to you by requesting a personalized policy
              illustration from your registered representative. Please see the “Long-Term Care Benefit Rider” subsection “Right to Purchase Optional Inflation Protection” of this prospectus for more information.

    1    Guaranteed
        at an effective annual rate of 1.50% in Policy Years 1-10 and 1.50% in Policy Years 11 and beyond.

          2

            Although deducted annually, interest accrues daily. As described in the section headed “Policy Loans”, when you request a Policy Loan, amounts equal to the amount of the loan you
              request are withdrawn from the Sub- Accounts and the Fixed Account in proportion to their respective values. Such amount is transferred to the Loan Account, which is part of the Company’s General Account. Amounts in the Loan Account are
              credited interest at an effective annual rate guaranteed not to be less than 1% in all Policy Years. Taking into account the Asset Charge, the net cost of your Policy Loan is 3.50% in Policy Years 1-10 and 3.50% in Policy Years 11 and beyond.

    The next table shows the minimum and maximum total operating expenses
      charged by the Underlying Funds that you may pay periodically during the time that you own the Policy. A complete list of Underlying Funds available under the Policy, including their annual expenses, may be found in Appendix A: Funds Available Under
      the Policy.

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    Policy
      Loan Interest

    If you borrow against your Policy, interest will be charged to the Loan Account Value. The
      annual effective interest rate is 3% in all years. The amount of your loan, plus any accrued but unpaid interest, is added to your outstanding Policy Loan balance. We will credit 1% interest on the Loan Account Value in all Policy Years.

    Rider Charges

    The following paragraphs describe the charges for the riders listed below. The features of
      the riders available with this Policy and any limitations on the selection of riders are discussed in the section headed “Riders”.

    Long-Term Care Benefits Rider. There is a monthly rider charge on any Monthly Anniversary Day on which the Insured is not
      receiving LTC benefits. It is equal to (a) multiplied by (b) plus (c) multiplied by (d) where:

              (a)

              is the LTC Base Charge Rate shown in the Policy Specifications;

              (b)

              is the Base LTC Limit Value on the Policy’s Monthly Anniversary Day, divided by 1,000;

              (c)

              is the LTC Excess Charge Rate shown in the Policy Specifications; and

              (d)

              is the LTC Benefit Limit on the Policy’s Monthly Anniversary Day minus the Base LTC Limit Value on
                the Policy’s Anniversary Day, divided by 1,000.

    As of the date a claim is approved, and for the duration of the claim, (d) above will read as follows:

              (d)

              is the greater of the Base LTC Limit Value or the Protected LTC Limit Value, if any, on the
                Policy’s Monthly Anniversary Day, minus the Base LTC Limit Value on the Policy’s Monthly Anniversary Day, divided by 1,000.

    Rider charges and costs vary based on individual characteristics of the Insured. Please
      refer to the “Long-Term Care Benefit Rider” of this prospectus for more information and benefit options available.

    YOUR INSURANCE POLICY

    Your Policy is a life insurance contract that provides for a death benefit payable on the
      death of the Insured. The Policy and the application constitute the entire contract between you and Lincoln Life.

    The Policy includes Policy Specifications pages. These pages provide important information
      about your Policy such as: the identity of the Insured and Owner; Policy Date; the Initial Specified Amount; issue age; Planned Premium Payment; Surrender Charges; expense charges and fees; and guaranteed maximum cost of insurance rates.

    Note: The
      Policy Specifications pages (and any specifications pages relating to riders you may purchase) reference certain dates that are very important in understanding when your coverage begins and ends, when certain benefits become available and when
      certain rights or obligations arise or terminate. Generally, terms such as “Policy Date”, “Effective Date” or “Policy Effective Date” (or “Rider Date”, “Rider Effective Date”) refer to the date that coverage under the Policy (or rider) becomes
      effective and is the date from which Policy Years, Policy Anniversary and ages are determined. Terms such as “Issue Date” or “Policy Issue Date” (or “Rider Issue Date”) generally refer to when we print or produce the Policy (or rider), but such dates
      may have importance beyond that date. For example, the period of time we may have to contest a claim submitted in the first couple years of the Policy will typically start on the date the Policy is issued and not the date the Policy goes into effect.
      Please read your Policy carefully and make sure you understand which dates are important and why.

    When your Policy is delivered to you, you should review it promptly to confirm that it
      reflects the information you provided in your application. If not, please notify us immediately.

    The Policy is nonparticipating. This means that no dividends are payable to you. In
      addition, your Policy does not share in the profits or surplus earnings of the Company.

    Before purchasing the Policy to replace, or to be funded with proceeds from an existing life
      insurance policy or annuity, make sure you understand the potential impact. The Insured will need to prove current insurability and

    27

              1.

              the sum of costs incurred and actually paid by the Insured for Covered Services for the calendar
                month which have not already been reimbursed by us; or

              2.

              the Indemnity Choice Option amount.

              b.

              the amount you request;

              c.

              the Maximum Monthly LTC Benefit amount under the Reimbursement Option or the Indemnity Choice
                Option, as applicable; or

              d.

              the LTC Benefit Limit.

    A benefit paid under this Rider will be first used to repay a portion of any outstanding
      Debt under the Policy, as described in the “Reduction of Benefit Payments Due to Debt” provision.

    This Rider will pay benefits for Covered Services received in a state or jurisdiction,
      including other than the state of issue, if benefits would have been paid in the state of issue, irrespective of any differences in facility licensing, certification, registration requirements, provider name or similar requirements.

    Benefit Payment Options: If the Insured has met all Benefit Conditions listed in the “Eligibility” provision of this Rider, Benefit Payment Options will be available for seven days per week.

    Upon the initial long-term care claim, the Owner must elect one of two Benefit Payment
      Options, as described below. Once the Benefit Payment Option has been chosen, the election is irrevocable and cannot be changed for the life of the Rider.

    Each option affects the amount of your benefit payments and claim administration
      differently. As shown on the Policy Specifications, the Indemnity Choice Option provides a modified Monthly Maximum LTC Benefit Amount compared to the Reimbursement Option.

    Reimbursement Option – The Owner elects to receive benefit payments based on receipts for
      Covered Services that are submitted during the claim occurrence. The total benefit payments in any month cannot be greater than the Maximum Monthly LTC Benefit Amount for the Reimbursement Option.

    Indemnity Choice Option – The Owner elects an Indemnity benefit payment that will be paid
      each month during the claim occurrence without regard to the number of days of services received or the actual expenses incurred.

    The Indemnity Choice Option Limit is the specific benefit payment amount requested which
      cannot be greater than the Maximum Monthly LTC Benefit Amount, times the Indemnity Choice Factor as shown in the Policy Specifications.

    Subject to the terms and conditions of this Rider, we will pay an amount not to exceed the
      applicable Maximum Monthly LTC Benefit no less frequently than once each calendar month until the LTC Benefit Limit equals zero:

              a.

              to reimburse costs incurred and actually paid by the Insured for any Covered Service or
                combination of Covered Services; and/or

              b.

              to pay the requested Indemnity Choice Option benefit.

    With the exception of Caregiver Training, any amounts paid in a calendar month for the
      Indemnity Choice Option, and/or to reimburse any Covered Service or combination of Covered Services will reduce the following dollar for dollar: that month’s Maximum Monthly LTC Benefit, the LTC Benefit Limit, the Base LTC Limit Value, and the
      Protected LTC Limit Value, if any. Benefits paid for Caregiver Training do not reduce any of these amounts. Benefits under this Rider while this Rider is In Force will continue to be available for the Covered Services listed in the “Covered Services”
      section of this Rider as long as the LTC Benefit Limit is greater than zero.

    In any calendar month in which you are eligible to receive benefits under this Rider, the
      maximum amount available as a benefit under this Rider is equal to the lesser of:

              a.

              an amount equal to your election, chosen at the time of initial claim:

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