Law Department
The Lincoln National Life Insurance Company
350 Church Street
Hartford, CT 06103
Nadine Rosin
Assistant Vice President
and Senior Counsel
Phone: 860-466-2832
Nadine.Rosin@LFG.com
VIA Email & EDGAR
January 21, 2022
Jaea Hahn
Senior Counsel
U.S. Securities and Exchange Commission
Division of Investment Management
Disclosure Review and Accounting Office
100 F Street, NE
Washington, DC 20549
Re: The Lincoln National Life Insurance Company
Post-Effective Amendment No. 5
File Nos. 333-238932
Dear Ms. Hahn:
This letter provides our response to comments received by telephone on January 7, 2022 regarding the above-referenced filing. The attached supplement is blacklined to address your comments. Corresponding changes will be made to the other supplements in the filing, as applicable. Specifically,
1. | Investments of the Indexed Account: |
a. | Consider adding a description of how the index provider describes “large-capitalization companies" and “internet industry.” |
b. | The second sentence of this paragraph is grammatically incorrect. Please correct. |
Response: Additional disclosure has been added to provide a more complete description of the index, including, “the level of the First Trust American Leadership Index incorporates an embedded 0.65% annual fee. The fee is not related to the annuity,”
2. | Risk Factors: Consider adding a concentration risk. |
Response: The index does not have a concentration risk. Its diversity is an aspect that sets it apart from other indices.
In addition, the following information has been added to the filing:
a. | “Information Incorporated by Reference” – This section was added to update the listing of financial filings submitted by the Company during 2021. |
b. | “Distribution of the Contracts – Compensation Paid to Other Parties” – This section was added to the supplements that discuss the addition of the First Trust American Leadership Index. |
We intend to submit another POS AM filing on February 1, 2022, along with a request to accelerate the effective date of that filing to February 4, 2022. Please call me at 860-466-2832 with any questions or additional comments.
Sincerely,
Nadine Rosin
Nadine Rosin