Correspondence 0001193125-24-102562 from Northwestern Mutual Variable Life Account II (CIK 0001359314)
Northwestern Mutual Variable Life Account II (CIK 0001359314)
Date: April 19, 2024 · CIK: 0001359314 · Accession: 0001193125-24-102562
AI Filing Summary & Sentiment
File numbers found in text: 333-233805, 811-21933
Letter
Terry R. Young
Assistant General Counsel
720 East Wisconsin Avenue
Milwaukee, WI 53202-4797
(414) 665-2092 office
terryyoung@northwesternmutual.com
VIA EDGAR and Electronic Mail
April 19, 2024
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Northwestern Mutual Variable Life Account II (“Registrant”)
Variable Universal Life Plus – NY File Nos. 811-21933; 333-233805
EDGAR CIK 0001359314
Post-Effective Amendment to Registration Statements on Form N-6
To Whom It May Concern:
I am submitting this letter on behalf of The Northwestern Mutual Life Insurance Company (the “Company”) and its above-named Registrant, to respond to the Commission staff’s comments on Post-Effective Amendment No. 5 for the Registrant (“Amendment”), which was filed pursuant to Rule 485(a)(1) on February 29, 2024, as referenced in your email dated April 1, 2024. In addition, Registrant will make certain other changes to disclosure in the Registration Statement to include any missing information and make routine and other clarifying changes, as appropriate.
Unless otherwise obvious from the context, the response in this supplemental letter, which will accompany the Amendment filing, is marked to show proposed changes in response to your comments.
The following is a summary of the Commission staff’s comment and our proposed response.
COVER PAGE/FACING SHEET
Comment
1. Beginning with reports transmitted to investors on or after July 4, 2024 [which would be the fund’s next shareholder report], Rule 30e-3 is no longer available for the underlying portfolio’s shareholder reports. Accordingly, please remove the Rule 30e-3 disclosure on the cover page.
Response:
Registrant has removed the Rule 30e-3 disclosure language from the cover page.
* * *
We believe that the Amendment is complete and responds to all Commission staff comments and greatly appreciate their assistance. Please call the undersigned with any questions or comments or if I can do anything to assist in completing your review.
Very truly yours,
/s/ Terry R. Young
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CORRESP 1 filename1.htm CORRESP Terry R. Young Assistant General Counsel 720 East Wisconsin Avenue Milwaukee, WI 53202-4797 (414) 665-2092 office terryyoung@northwesternmutual.com VIA EDGAR and Electronic Mail April 19, 2024 Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Northwestern Mutual Variable Life Account II (“Registrant”) Variable Universal Life Plus – NY File Nos. 811-21933; 333-233805 EDGAR CIK 0001359314 Post-Effective Amendment to Registration Statements on Form N-6 To Whom It May Concern: I am submitting this letter on behalf of The Northwestern Mutual Life Insurance Company (the “Company”) and its above-named Registrant, to respond to the Commission staff’s comments on Post-Effective Amendment No. 5 for the Registrant (“Amendment”), which was filed pursuant to Rule 485(a)(1) on February 29, 2024, as referenced in your email dated April 1, 2024. In addition, Registrant will make certain other changes to disclosure in the Registration Statement to include any missing information and make routine and other clarifying changes, as appropriate. Unless otherwise obvious from the context, the response in this supplemental letter, which will accompany the Amendment filing, is marked to show proposed changes in response to your comments. The following is a summary of the Commission staff’s comment and our proposed response. COVER PAGE/FACING SHEET Comment 1 1. Beginning with reports transmitted to investors on or after July 4, 2024 [which would be the fund’s next shareholder report], Rule 30e-3 is no longer available for the underlying portfolio’s shareholder reports. Accordingly, please remove the Rule 30e-3 disclosure on the cover page. Response: Registrant has removed the Rule 30e-3 disclosure language from the cover page. * * * We believe that the Amendment is complete and responds to all Commission staff comments and greatly appreciate their assistance. Please call the undersigned with any questions or comments or if I can do anything to assist in completing your review. Very truly yours, /s/ Terry R. Young Terry R. Young Assistant General Counsel 2