Correspondence 0000726865-24-000191 from LINCOLN LIFE FLEXIBLE PREMIUM VARIABLE LIFE ACCOUNT M (CIK 0001048607)
LINCOLN LIFE FLEXIBLE PREMIUM VARIABLE LIFE ACCOUNT M (CIK 0001048607)
Date: May 7, 2024 · CIK: 0001048607 · Accession: 0000726865-24-000191
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File numbers found in text: 333-276970, 811-08557
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CORRESP
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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
May 7, 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
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 May 6, 2024. The attached prospectus pages for Lincoln MoneyGuard Market Advantage® 2024 are blacklined to reflect the changes requested.
1.
Special Terms: (pgs.
3-5) Please add all additional terms within the Rider Charges section to the Special Terms section.
Response: We have revised accordingly and provided all additional terms.
2.
Rider Charges – (p. 27). Please describe
the Base and Excess Charge rates.
Response: We have revised
accordingly.
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,
/s/Jassmin McIver-Jones
Jassmin McIver-Jones
SPECIAL TERMS
The following terms may appear in your prospectus and are defined below:
7-Pay Test—A test
that compares actual paid Premium in the first seven years against a pre-determined Premium amount as defined in 7702A of the Code.
1933 Act—The Securities
Act of 1933, as amended.
1940 Act—The Investment
Company Act of 1940, as amended.
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.
Administrative Fee—The
fee which compensates the Company for administrative expenses associated with policy issue and ongoing policy maintenance including Premium billing and collection, policy value calculation, confirmations, periodic reports and other similar matters.
Attained Age—An
Insured’s Issue Age (shown in the Policy Specifications) plus the number of completed Policy Years.
Base
LTC Limit Value— Is the initial LTC Benefit Limit on the Policy Date (as shown on your
Policy Specifications) that increases and decreases with the Specified Amount after the
Policy Date.
Beneficiary—The
person(s) 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.
Chronically
Ill—Long-Term Care Benefits Rider—The Insured has been certified within the preceding 12 months as being unable to either perform (without substantial assistance) at least two activities of daily living for at least 90 consecutive days
(i.e. bathing, continence, dressing, eating, toileting and transferring); or requires substantial supervision due to severe cognitive impairment.
Code—Internal Revenue
Code of 1986, as amended.
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.
Covered
Services—Services that are eligible for reimbursement under the Long-Term Care Benefits Rider.
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.
Eligible
Policy—A Policy with the Benefit Transfer Rider or another rider issued by us that allows the use of the policy’s Death Benefit Proceeds to purchase an additional death benefit and long-term care benefit under the Beneficiaries own
Eligible Policy. The policy and rider must both be in-force to be considered an Eligible Policy.
Fixed
Account—An allocation option under the Policy, which is a part of our General Account, to which we credit a guaranteed minimum interest rate.
Fixed
Account Value—An amount equal to the value of amounts allocated or transferred to the Fixed Account, plus interest credited, and less any deductions or Partial Surrenders.
Full
Surrender—The withdrawal of all applicable policy values.
Good
Order—The actual receipt of the requested transaction in writing (or other form subject to our consent) along with all information and supporting legal documentation necessary to effect the transaction.
Grace
Notice—Written notice to you (or any assignee or other designee of record) that your Policy will terminate unless we receive payment of Premiums (or payment of Debt on Policy Loans). The Grace Notice will state the amount of Premium
Payment (or payment of Debt on Policy Loans) that must be paid to avoid termination of your Policy.
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Grace
Period—The period during which you may make Premium Payments (or repay Debt) to prevent Policy Lapse. That period is the later of (a) 31 days after the Grace Notice was mailed, and (b) 61 days after the Monthly Anniversary Day on which the
Policy enters the Grace Period.
Indemnity Choice Option—Long-Term
Care Benefits Rider – 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.
Insured—The
person on whose life the Policy is issued.
Licensed Health Care
Practitioner—Long-Term
Care Benefits Rider – A physician, as defined in Section 1861(r)(1) of the Social Security Act, a registered
professional nurse, licensed social worker, or other individual who meets such requirements as may be prescribed by the Secretary of the Treasury. The health care practitioner must be acting within the scope of his/her license when providing any
Covered Service or performing necessary functions or actions and cannot be an immediate family member.
Loan Account (Loan Collateral
Account)—The account in which policy Debt accrues once it is transferred out of the Sub-Accounts and/or the Fixed Account. The Loan Account is part of our General Account.
Loan
Account Value—An amount equal to any outstanding Policy Loans, including any interest charged on the loans. This amount is held in the Company’s General Account.
LTC Base Charge Rate—is theIsa monthly charge for the benefit based on Specifiedbase benefit of
the Long- AmountTerm Care Benefits Rider (as shown in your Policy Specifications).
LTC Benefit Limit—Is the benefit amount available under the Long-Term Care Benefits Rider on any date after the Policy Date.
LTC
Excess Charge Rate—is theIsa charge for additional benefits based on the excess benefits of the Long-Term Care Benefits Rider. It is charged in any months
when the Policy’Accumulation Values Accumulation Value is sufficient to provide
additional LTC benefits above the base benefit to the extent the LTC Benefit Limit is
greater than the Base LTC Limit Value (as shown on your Policy Specifications).
Market
Benefit Floor—a value used to calculate your LongIs the Accumulation Value amount at which-Term Care benefits time the LTC Benefit Limit would exceed the Base LTC Limit Value.
Market
LTC Limit Value—Is the portion of the LTC Benefit Limit Value that increases and decreases
daily based on the Policy’s Accumulation Value increasing and decreasing.
Market
Timing Procedures—Policies and procedures from time to time adopted by us as an effort to protect our Owners and the funds from potentially harmful trading activity.
Modified
Endowment Contract (MEC)—A life insurance policy that meets the requirements of Section 7702 and fails the “7-Pay Test” of 7702A of the Code. If the policy is a MEC, withdrawals and loans from your Policy will be treated first as income
and then as a recovery of Premium Payments.
Monthly
Anniversary Day—The Policy Date and the same day of each month thereafter. If the day that would otherwise be a Monthly Anniversary Day is non- existent for that month, or is not a Valuation Day, then the Monthly Anniversary Day is the
next Valuation Day. The Monthly Deductions are made on the Monthly Anniversary Day.
Monthly
Deduction—The amount of the monthly charges for the Cost of Insurance Charge, the Administrative Fee, and charges for riders to your Policy.
Net
Amount at Risk—The death benefit minus the greater of zero or the Accumulation Value. The Net Amount at Risk may vary with investment performance, Premium Payment patterns, and charges.
Net
Premium Payment—An amount equal to the Premium Payment, minus the Premium Load.
Non-Guaranteed
Elements (NGEs)—Any element within this Policy that affects the costs or values of the Policy and which may be changed at our discretion after this Policy is issued. NGEs include the Cost of Insurance Rates, Mortality and Expense Risk
(“M&E”) Charge, Asset Charge, Premium Load, Monthly Administrative Fee, Partial Surrender Fee, and interest rate used to credit the Fixed Account.
Owner—The
person or entity designated as Owner in the Policy Specifications unless a new Owner is thereafter named, and we receive written notification of such change.
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Partial
Surrender—A withdrawal of a portion of your policy values.
Planned
Premium—The amount of periodic Premium (as shown in the Policy Specifications) you have chosen to pay the Company on a scheduled basis. This is the amount for which we send a Premium reminder notice.
Policy
Anniversary—The same date (month and day) each Policy Year equal to the Policy Date, or the next Valuation Day if the Policy Anniversary is not a Valuation Day or is nonexistent for the year.
Policy
Date—The date (shown on the Policy Specification pages) on which life insurance begins if the necessary Premium has been paid.
Policy
Lapse—The day on which coverage under the Policy ends as described in the Grace Period.
Policy Loan—The
amount you have borrowed against the Surrender Value of your Policy.
Policy
Loan Interest—The charge made by the Company to cover the cost of your borrowing against your Policy.
Policy
Month— The period from one Monthly Anniversary Day up to, but not including, the next Monthly Anniversary Day.
Policy
Specifications—The pages of the Policy which show your benefits, Premium, costs, and other policy information.
Policy
Year—Twelve month period(s) beginning on the Policy Date and extending up to but not including the next Policy Anniversary.
Premium
(Premium Payment)—The amount paid to us for a life insurance policy.
Premium
Load—A deduction from each Premium Payment which covers certain policy-related state and federal tax liabilities as well as a portion of the sales expenses incurred by the Company.
Protected
LTC Benefit Value—When the Value Protection Rider is in force, it is used as one of the factors to determine the LTC Benefit Limit under the Long-Term Care Benefits Rider.
Purchase
Date—The date we approve a Beneficiary’s Election to use Death Benefit Proceeds, under the Benefit Transfer Rider or a similar rider by us, to purchase the Rider Benefit or similar benefit under an Eligible Policy.
Reduction
in Specified Amount—A decrease in the Specified Amount of your Policy.
Reimbursement
Option—Long-Term Care Benefits Rider – 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.
Rider
Benefit—A death benefit and long-term care benefit purchased under the Benefit Transfer Rider.
Right to
Examine Period—The period during which the Policy may be returned to us for cancellation.
SAI—Statement of
Additional Information.
SEC—The Securities and
Exchange Commission.
Separate
Account Value (Variable Accumulation Value)—An amount equal to the values in the Sub- Accounts.
Specified
Amount (Initial Specified Amount)—The amount chosen by you which is used to determine the amount of death benefit and the amount of rider benefits, if any. The Specified Amount chosen at the time of issue is the “Initial Specified Amount”.
The Specified Amount may be increased or decreased after issue if allowed by and described in the Policy.
Sub-Account(s)—Divisions
of the Separate Account created by the Company to which you may allocate your Net Premium Payments and among which you may transfer Separate Account Values.
Surrender
Charge—The charge we may make if you request a Full Surrender of your Policy or request a Reduction in Specified Amount. The Surrender Charge is in part a deferred sales charge and in part a recovery of certain first year administrative
costs. A schedule of Surrender Charges is included in each Policy.
Surrender
Value—An amount equal to the Accumulation Value less any applicable Surrender Charge, less Debt.
Underlying
Fund—The mutual fund the shares of which are purchased for all amounts you allocate or transfer to a Sub-Account.
Valuation
Day—Each day on which the New York Stock Exchange is open and trading is unrestricted.
Valuation Period—The
time between Valuation Days.
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will never be calculated at a rate higher than the maximum Cost of Insurance Charge shown in “Table II: Periodic Charges Other Than Fund Operating Expenses” in this prospectus.
Mortality and Expense Risk Charge
We may assess a monthly Mortality and Expense Risk Charge (“M&E”) as a percentage of
the Policy’s Separate Account Value as of the date the Monthly Deduction is made. The mortality risk assumed is that the Insured may live for a shorter period than we originally estimated. The expense risk assumed is that those expenses incurred in
issuing and administering the Policies that are supported by the policies Separate Account value will be greater than we originally estimated. The charge is guaranteed n