June 3, 2025

Christopher Neczypor
Executive Vice President and Chief Financial Officer
Lincoln National Corporation
150 N. Radnor-Chester Road
Suite A305
Radnor, PA 19087

       Re: Lincoln National Corporation
           Form 10-K for the Fiscal Year Ended December 31, 2024
           File No. 001-06028
Dear Christopher Neczypor:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2024
Results of Consolidated Operations, page 55

1.     We note your presentation here and elsewhere of an adjustment for net
annuity
       product features, pre-tax as part of your reconciliation. We note that
this adjustment is
       defined on page 205 and appears to be comprised of multiple items.
Please revise your
       disclosures in future filings to provide additional details and
quantification of the
       individual components that comprise this adjustment. To the extent that
it is also
       presented as an adjustment for a non-GAAP measure (e.g., as part of your
definition
       of Adjusted Income in earnings releases on Form 8-K), provide clear
disclosure
       explaining why management believes the exclusion of the net annuity
product
       features is meaningful and provides useful information to investors
regarding the
       registrant's financial condition and results of operations.
Notes to Consolidated Financial Statements
10. Separate Accounts, page 162
 June 3, 2025
Page 2

2.     We note your disclosure showing Mutual funds and collective investment
trusts as the
       majority investment category within separate accounts. In future filings
and where
       appropriate, please revise your disclosure to show mutual funds and
collective
       investment trusts by investment objective or other meaningful groupings.
Refer
       to ASC 944-80-55-17 Example 3.
12. Future contract Benefits, page 167

3.     We note your presentation of the "effect of actual variances from
expected
       experience" within your summaries of changes in the present values of
expected net
       premiums for LFPB on page 168, Group Protection on page 170, and UL and
Other
       on page 171. To the extent material, please revise your disclosure in
future filings to
       include a comparison and discussion of actual experience attributable to
each of
       mortality, morbidity and lapses compared to what was expected for the
period. For
       example, to the extent that there are significant favorable and/or
unfavorable
       offsetting impacts associated with each assumption, consider quantifying
or providing
       accompanying information to further discuss those effects of actual
experience versus
       expected.
        In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

       Please contact Lory Empie at 202-551-3714 or Robert Klein at
202-551-3847 with
any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Finance
cc:   Nancy Smith