Correspondence 0001104659-24-125902 from PACIFIC LIFE INSURANCE CO (CIK 0001080429)
PACIFIC LIFE INSURANCE CO (CIK 0001080429)
Date: Dec. 5, 2024 · CIK: 0001080429 · Accession: 0001104659-24-125902
AI Filing Summary & Sentiment
File numbers found in text: 333-282283
Letter
Office of Insurance Products Division of Investment Management Washington, DC 20549-0506 RosenbergMi@sec.gov Re: Pacific Life Insurance Company Response to SEC comments on Registration Statement on Form N-4 for Pacific Protective Growth limited premium registered index-linked deferred annuity (File No. 333-282283)
Dear Mr. Rosenberg,
Pacific Life Insurance Company (the “Company,” “we,” and “our”) is providing responses to the comments received from the SEC staff (“Staff”) on December 3, 2024, in connection with the above-referenced pre-effective amendment to the registration statement on Form N-4, file no. 333-282283 (the “Registration Statement”), for certain limited premium registered index-linked deferred annuity contracts titled “Pacific Protective Growth,” filed by the Company on November 22, 2024, under the Securities Act of 1933, as amended.
We have restated each of the Staff’s comments below and followed each comment with the Company’s response. The Company will file this letter as correspondence filing via Edgar, and we will e-mail the Staff a courtesy copy. As agreed in our conversation, we will implement the changes in a subsequent 497 filing immediately after the Staff deems the registration statement effective.
Comments
1. In Appendix A: Interest Crediting Options Under the Contract, please state in a footnote or narrative after the table that if an investor exercises Performance Lock, they will not earn Index interest, but the Company will credit a fixed rate of interest until the end of the Term equal to the ILO Budget Rate subject to a 0% minimum guarantee.
Response: Revisions have been made to address the Staff’s comments.
2. In Appendix A: Interest Crediting Options Under the Contract, Pursuant to Form N-4, Item 17(b), please change the heading in the far-right hand column from “Guaranteed Minimum Crediting Strategy (for the life of the ILO)” to instead state:
Minimum Limit on Index Gain (for the life of the Index-Linked Option)
Response: Revisions have been made to address the Staff’s comments.
3. In accordance with the Comment above, please revise references in the prospectus and SAI from “Guaranteed Minimum Crediting Strategy Rate (for the life of the ILO)” to instead state, “Minimum Limit on Index Gain (for the life of the ILO).”
Response: Revisions have been made to address the Staff’s comments.
We appreciate the Staff’s review of and comments on this filing. If you have any questions or concerns, please do not hesitate to contact the undersigned at (949) 219-3268.
Sincerely,
/s/ Alison
Ryan
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CORRESP
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filename1.htm
ALISON RYAN
AVP & Managing
Assistant General Counsel II
Phone: 949-219-3268
Alison.Ryan@pacificlife.com
Via Correspondence and E-mail
December 5, 2024
Michael Rosenberg
Attorney - Adviser
Office of Insurance Products
Division of Investment Management
U.S. Securities & Exchange
Commission
100 F Street, NE
Washington, DC 20549-0506
RosenbergMi@sec.gov
Re:
Pacific Life Insurance Company
Response to SEC comments on Registration Statement
on Form N-4 for Pacific Protective Growth limited premium registered index-linked deferred annuity (File No. 333-282283)
Dear Mr. Rosenberg,
Pacific Life Insurance Company (the
“Company,” “we,” and “our”) is providing responses to the comments received from the SEC staff (“Staff”)
on December 3, 2024, in connection with the above-referenced pre-effective amendment to the registration statement on Form N-4,
file no. 333-282283 (the “Registration Statement”), for certain limited premium registered index-linked deferred annuity
contracts titled “Pacific Protective Growth,” filed by the Company on November 22, 2024, under the Securities Act of
1933, as amended.
We have restated each of the Staff’s
comments below and followed each comment with the Company’s response. The Company will file this letter as correspondence filing
via Edgar, and we will e-mail the Staff a courtesy copy. As agreed in our conversation, we will implement the changes in a subsequent
497 filing immediately after the Staff deems the registration statement effective.
Comments
1. In Appendix A: Interest Crediting Options
Under the Contract, please state in a footnote or narrative after the table that if an investor
exercises Performance Lock, they will not earn Index interest, but the Company will credit
a fixed rate of interest until the end of the Term equal to the ILO Budget Rate subject to
a 0% minimum guarantee.
Response:
Revisions have been made to address the Staff’s comments.
2. In Appendix A: Interest Crediting Options
Under the Contract, Pursuant to Form N-4, Item 17(b), please change the heading
in the far-right hand column from “Guaranteed Minimum Crediting Strategy (for the life
of the ILO)” to instead state:
Minimum Limit on Index
Gain (for the life of the Index-Linked Option)
Response:
Revisions have been made to address the Staff’s comments.
3. In accordance with the Comment above,
please revise references in the prospectus and SAI from “Guaranteed Minimum Crediting
Strategy Rate (for the life of the ILO)” to instead state, “Minimum Limit on
Index Gain (for the life of the ILO).”
Response:
Revisions have been made to address the Staff’s comments.
We appreciate the Staff’s review
of and comments on this filing. If you have any questions or concerns, please do not hesitate to contact the undersigned at (949) 219-3268.
Sincerely,
/s/ Alison
Ryan
Alison Ryan
AVP & Managing Assistant General Counsel
II
Pacific Life Insurance Company