Lincoln New York Account N For Variable Annuities CORRESP Correspondence with SEC

Law Department

The Lincoln National Life Insurance Company

1300 South Clinton Street

Fort Wayne, IN 46802

Mary Jo Ardington

Associate General Counsel

Phone: 260-455-3917

Fax: 260-455-5135

MaryJo.Ardington@LFG.com

VIA EDGAR & email

August 8, 2011

Alison White

Office of Insurance Products

Division of Investment Management

Securities and Exchange Commission

Room 8634; Mail Stop 8629

100 F Street, NE

Washington, DC 20549-8629

Re:	Lincoln New York Account N for Variable Annuities

Lincoln Life & Annuity Company of New York

File No. 333-175691

Dear Ms. White:

This letter is in response to your comments of August 8, 2011.

1. Comment: The overview chart referenced in “Summary of Common Questions” and “Living Benefit Riders” sections was not filed on EDGAR.

Response: The chart is included in this correspondence filing.

2. Comment: The SAI was not included in the most recent EDGAR filing. Please be sure the Interest Adjustment section has been removed, and file the revised SAI on EDGAR.

Response: The revised SAI is included in this correspondence filing.

3. Comment: Additional Services – Dollar Cost Averaging: Remove the disclosure relating to the charge for this service. In the alternative, add the charge to the Expense Table.

Response: The language relating to the charge has been removed. The revised page is included in this correspondence filing.

Please call me at 260-455-3917 with further comments and questions.

Sincerely,

Mary Jo Ardington

Associate General Counsel

 <PAGE>

Surrenders and Withdrawals

Before the Annuity Commencement Date, we will allow the surrender of the
contract or a withdrawal of the contract value upon your written request on an
approved Lincoln distribution request form (available from the Servicing
Office), subject to the rules discussed below. Surrender or withdrawal rights
after the Annuity Commencement Date depend on the annuity payout option
selected.

The amount available upon surrender/withdrawal is the contract value less any
applicable charges, fees, and taxes at the end of the valuation period during
which the written request for surrender/withdrawal is received in good order at
the Servicing Office. If we receive a surrender or withdrawal request in good
order at or after 4:00 p.m., New York time, we will process the request using
the accumulation unit value computed on the next valuation date. The minimum
amount which can be withdrawn is $300. Unless a request for withdrawal
specifies otherwise, withdrawals will be made from all subaccounts within the
VAA and from the fixed account in the same proportion that the amount of
withdrawal bears to the total contract value. See Fixed Side of the Contract.
Unless prohibited, surrender/withdrawal payments will be mailed within seven
days after we receive a valid written request at the Servicing Office. The
payment may be postponed as permitted by the 1940 Act.

If you request a lump sum surrender and your surrender value is over $10,000,
your money will be placed into a SecureLine (Reg. TM) account in your name.
SecureLine (Reg. TM) is a service we offer to help you manage your surrender
proceeds. With SecureLine (Reg. TM), an interest bearing draft account is
established from the proceeds payable on a policy or contract administered by
us. You are the owner of the account, and are the only one authorized to
transfer proceeds from the account. Instead of mailing you a check, we will
send a checkbook so that you will have access to the account by writing a
check. You may choose to leave the proceeds in this account, or you may begin
writing checks right away. If you decide you want the entire proceeds
immediately, you may write one check for the entire account balance. The
SecureLine (Reg. TM) account is part of our general account. It is not a bank
account and it is not insured by the FDIC or any other government agency. As
part of our general account, it is subject to the claims of our creditors. We
receive a benefit from all amounts left in the SecureLine (Reg. TM) account.
You may request that surrender proceeds be paid directly to you instead of
applied to a SecureLine (Reg. TM) account.

Interest credited in the SecureLine (Reg. TM) account is taxable as ordinary
income in the year such interest is credited, and is not tax deferred. We
recommend that you consult your tax advisor to determine the tax consequences
associated with the payment of interest on amounts in the SecureLine (Reg. TM)
account. The balance in your SecureLine (Reg. TM) account starts earning
interest the day your account is opened and will continue to earn interest
until all funds are withdrawn. Interest is compounded daily and credited to
your account on the last day of each month. The interest rate will be updated
monthly and we may increase or decrease the rate at our discretion. The
interest rate credited to your SecureLine (Reg. TM) account may be more or less
than the rate earned on funds held in our general account. The interest rate is
not necessarily that offered by the fixed account. There are no monthly fees.
You may be charged a fee if you stop a payment or if you present a check for
payment without sufficient funds.

The tax consequences of a surrender/withdrawal are discussed later in this
booklet. See Federal Tax Matters -  Taxation of Withdrawals and Surrenders.


Additional Services


These are the additional services available to you under your contract:
dollar-cost averaging (DCA), automatic withdrawal service (AWS),
cross-reinvestment service and portfolio rebalancing. In order to take
advantage of one of these services, you will need to complete the appropriate
election form that is available from our Servicing Office. For further detailed
information on these services, please see Additional Services in the SAI.


Dollar-cost averaging allows you to transfer amounts from the DCA fixed
account, if available, or certain variable subaccounts into the variable
subaccounts on a monthly basis or in accordance with other terms we make
available.

You may elect to participate in the DCA program at the time of application or
at anytime before the annuity commencement date by completing an election form
available from us. The minimum amount to be dollar cost averaged is $1,500 over
any period between six and 60 months. Once elected, the program will remain in
effect until the earlier of:
 o the Annuity Commencement Date;
 o the value of the amount being DCA'd is depleted; or
 o you cancel the program by written request or by telephone if we have your
telephone authorization on file.

We reserve the right to restrict access to this program at any time.

A transfer made as part of this program is not considered a transfer for
purposes of limiting the number of transfers that may be made, or assessing any
charges which may apply to transfers. Upon receipt of an additional purchase
payment allocated to the DCA fixed account, the existing program duration will
be extended to reflect the end date of the new DCA program. However, the
existing interest crediting rate will not be extended. The existing interest
crediting rate will expire at its originally scheduled expiration date and the
value remaining in the DCA account from the original amount as well as any
additional purchase payments will be credited with interest at the standard DCA
rate at the time. If you cancel the DCA program, your remaining contract value
in the DCA program will


28

Overview of Living Benefit Riders

We offer a number of optional Living Benefit riders that, for an additional fee, offer certain guarantees, if certain conditions are met. These Living Benefit riders are described briefly below. Please see the more detailed description in the prospectus discussion for each rider, as well as the Charges and Other Deductions section of the prospectus, for important information on the costs, restrictions, and availability of each rider. Please consult your registered representative as to whether any Living Benefit rider is appropriate for you based on factors such as your investment objectives, risk tolerance, liquidity needs, and time horizon. Not all riders or features are available in all states or with your contract. Please consult your registered representative for the availability of any particular rider.

	Lincoln SmartSecurity® Advantage	Lincoln Lifetime IncomeSM Advantage 2.0	i4LIFE® Advantage	i4LIFE® Advantage Guaranteed Income Benefit (Version 4)
1. Overview	Designed to guarantee that if you make your first withdrawal on or after the date you reach age 65, you are guaranteed income for your life (and your spouse’s, under Joint Life version), even after the entire amount of purchase payments has been returned to you through periodic withdrawals. If lifetime withdrawals are not in effect, you may make periodic withdrawals of the Guaranteed Amount.	Designed to guarantee that if you make your first withdrawal on or after the date you reach age 55 you are guaranteed income for your life (and your spouse’s, under Joint Life version). Also includes age-based increases to the withdrawal amount.	Designed to provide an income program that combines variable lifetime income payments and a death benefit with the ability to make withdrawals during an Access Period.	Designed to use the Account Value* established under i4LIFE® Advantage (if i4LIFE® Advantage Guaranteed Income Benefit is elected) or the greater of the Income Base or Account Value under Lincoln Lifetime IncomeSM Advantage 2.0 (for prior purchasers of Lincoln Lifetime IncomeSM Advantage 2.0) to provide a minimum payout floor for i4LIFE® Advantage Regular Income Payments, regardless of investment performance. * Can instead use the remaining Guaranteed Amount under Lincoln SmartSecurity® Advantage.
2. Current Fee	0.65% (Single Life) or 0.80% (Joint Life) of Guaranteed Amount	Single life option 1.05% of Income Base Joint life option 1.25% of Income Base	Varies based on product and death benefit option (assessed as a % of Account Value)	1) 0.65% added to the i4LIFE® Advantage charge (0.85% if joint life option is chosen) 2) For purchasers of Lincoln Lifetime IncomeSM Advantage 2.0, 1.05% (single life option) or 1.25 (joint life option) which is the total charge for i4LIFE® Advantage with the Guaranteed Income Benefit initially (assessed as a % of the Lincoln Lifetime IncomeSM Advantage 2.0 Income Base or Account Value, if greater). This charge is in addition to the daily mortality and expense risk and administrative charge for your death benefit option on your base contract.
3. Guaranteed Maximum Fee	1.50% of Guaranteed Amount	2.00% of Income Base	Same as current fee	1) 2.00% added to the i4LIFE® Advantage charge (assessed as a % of Account Value) 2) 2.00% charge for i4LIFE® Advantage Guaranteed Income Benefit for purchasers of Lincoln Lifetime IncomeSM Advantage 2.0. (assessed as a % of the Lincoln Lifetime IncomeSM Advantage 2.0 Income Base or Account Value, if greater). This charge is in addition to the daily mortality and expense risk and administrative charge for your death benefit option on your base contract.

4. Withdrawals Permitted	Yes - 5% annually Excess Withdrawals may significantly reduce your guaranteed payments.	Yes – Age-based (4-5%) annually Excess Withdrawals may significantly reduce your guaranteed payments.	Yes, during Access Period	Excess Withdrawals may significantly reduce your guaranteed payments.
5. Payments for Life	Yes (if conditions are met)	Yes (if conditions are met)	Yes (if conditions are met)	Yes (if conditions are met)
6. Potential Increases to Guaranteed Amount, Income Base, or Guaranteed Income Benefit (as applicable)	Purchase payments Automatic Annual Step-Ups (if conditions are met)	Purchase payments 5% Enhancements Automatic Annual Step-Ups (if conditions are met)	N/A	Automatic Annual Step-Ups (if conditions are met)
7. Investment Requirements	Yes	Yes	None	Yes
8. Ability to Make Additional Purchase Payments if Contract Value is greater than zero	Yes, after the first rider anniversary, if cumulative purchase payments are over $100,000 and prior Home Office approval is provided	Yes—may impact the charge (Cumulative purchase payments in excess of $100,000 require Home Office approval.)	Yes, for qualified contracts, during the Access Period, unless i4LIFE® Advantage Guaranteed Income Benefit has been elected	No
9. Spousal Continuation	Yes	No	No	No
10. Ability to Cancel Rider	Yes, after 5 years following the later of rider effective date or contractowner-elected step-up	Yes, after 5 Years	Qualified contracts may terminate the rider prior to the end of the Access Period. Nonqualified contracts may not terminate the rider.	Yes, at any time if i4LIFE® Advantage Guaranteed Income Benefit is elected Yes, after 5 years following the rider effective date for Lincoln Lifetime IncomeSM Advantage 2.0 (if purchasers of Lincoln Lifetime IncomeSM Advantage 2.0 elect the Guaranteed Income Benefit)
11. Nursing Home Benefit	No	Yes (subject to state availability)	No	No
12. May Elect Other Living Benefit Riders	No	No	Limited to Guaranteed Income Benefit	Limited to i4LIFE® Advantage

<PAGE>

Lincoln InvestmentSolutionsSM
Lincoln New York Account N for Variable Annuities (Registrant)

Lincoln Life & Annuity Company of New York (Depositor)

Statement of Additional Information (SAI)
This SAI should be read in conjunction with the Lincoln InvestmentSolutionsSM
prospectus of Lincoln New York Account N for Variable Annuities dated _______,
2011. You may obtain a copy of the Lincoln InvestmentSolutionsSM prospectus on
request and without charge. Please write Lincoln Life & Annuity Company of New
York, PO Box 2348, Fort Wayne, IN 46801-2348, or call 1-888-868-2583.

Table of Contents

<TABLE>
<CAPTION>
Item Page
<S> <C>
Special Terms B-2
Services B-2
Principal Underwriter B-2
Purchase of Securities Being Offered B-2
Annuity Payouts B-2
Examples of Regular Income Payment
Calculations B-3
Determination of Accumulation and Annuity Unit
Value B-4

</TABLE>
<TABLE>
<CAPTION>
Item Page
<S> <C>
Capital Markets B-4
Advertising & Ratings B-4
More About the S&P 500 Index B-4
Additional Services B-5
Other Information B-6
Financial Statements B-6
</TABLE>

This SAI is not a prospectus.
The date of this SAI is _______, 2011.
<PAGE>

Special Terms
The special terms used in this SAI are the ones defined in the Prospectus.

Services

Independent Registered Public Accounting Firm
Ernst & Young LLP, independent registered public accounting firm, Two Commerce
Square, 2001 Market Street, Suite 4000, Philadelphia, Pennsylvania, 19103, has
audited a) our financial statements of the VAA as of December 31, 2010; and b)
our financial statements of Lincoln Life & Annuity Company of New York as of
December 31, 2010, which are included in this SAI and Registration Statement.
The aforementioned financial statements are included herein in reliance on
Ernst & Young LLP's reports, given on their authority as experts in accounting
and auditing.

Keeper of Records

All accounts, books, records and other documents which are required to be
maintained for the VAA are maintained by us or by third parties responsible to
Lincoln New York. We have entered into an agreement with The Bank of New York
Mellon, One Mellon Bank Center, 500 Grant Street, Pittsburgh, Pennsylvania,
15258, to provide accounting services to the VAA. No separate charge against
the assets of the VAA is made by us for this service. Administrative services
necessary for the operations of the VAA and the contracts are currently
provided by Lincoln Life. However, neither the assets of Lincoln Life nor the
assets of LNC support the obligation of Lincoln New York under the contracts.

Principal Underwriter
Lincoln Financial Distributors, Inc., ("LFD"), an affiliate of Lincoln New
York, serves as principal underwriter (the "Principal Underwriter") for the
contracts, as described in the prospectus. The Principal Underwriter offers the
contracts to the public on a continuous basis and anticipates continuing to
offer the contracts, but reserves the right to discontinue the offering. The
Principal Underwriter offers the contracts through sales representatives, who
are associated with Lincoln Financial Advisors Corporation and/or Lincoln
Financial Securities Corporation (collectively, "LFN"), our affiliates. The
Principal Underwriter also may enter into selling agreements with other
broker-dealers ("Selling Firms") for the sale of the contracts. Sales
representatives of Selling Firms are appointed as our insurance agents. LFD,
acting as Principal Underwriter, paid $9,599,993, $5,410,039 and $11,044,907 to
LFN and Selling Firms in 2008, 2009 and 2010, respectively, as sales
compensation with respect to the contracts. The Principal Underwriter retained
no underwriting commissions for the sale of the contracts.

Purchase of Securities Being Offered
The variable annuity contracts are offered to the public through licensed
insurance agents who specialize in selling our products; through independent
insurance brokers; and through certain securities brokers/dealers selected by
us whose personnel are legally authorized to sell annuity products. There are
no special purchase plans for any class of prospective buyers. However, under
certain limited circumstances described in the prospectus under the section
Charges and Other Deductions, any applicable account fee and/or surrender
charge may be reduced or waived.

Both before and after the annuity commencement date, there are exchange
privileges between subaccounts, and from the VAA to the general account (if
available) subject to restrictions set out in the prospectus. See The
Contracts, in the prospectus. No exchanges are permitted between the VAA and
other separate accounts.

The offering of the contracts is continuous.

Annuity Payouts

Variable Annuity Payouts
Variable annuity payouts will be determined on the basis of:
o the dollar value of the contract on the Annuity Commencement Date less any
applicable premium tax;
o the annuity tables contained in the contract;
o the type of annuity option selected; and
o the investment results of the fund(s) selected.

B-2
<PAGE>

In order to determine the amount of variable annuity payouts, we make the
following calculation:
o first, we determine the dollar amount of the first payout;
o second, we credit the contract with a fixed number of annuity units based on
the amount of the first payout; and
o third, we calculate the value of the annuity units each period thereafter.

These steps are explained below.

The dollar amount of the first periodic variable annuity payout is determined
by applying the total value of the accumulation units credited under the
contract valued as of the Annuity Commencement Date (less any premium taxes) to
the annuity tables contained in the contract. The first variable annuity payout
will be paid 14 days after the Annuity Commencement Date. This day of the month
will become the day on which all future annuity payouts will be paid. Amounts
shown in the tables are based on the 1983 Table "a" Individual Annuity
Mortality Tables, modified, with an assumed investment return at the rate of
3%, 4%, or 5% per annum, depending on the terms of your contract. The first
annuity payout is determined by multiplying the benefit per $1,000 of value
shown in the contract tables by the number of thousands of dollars of value
accumulated under the contract. These annuity tables vary according to the form
of annuity selected and the age of the annuitant at the Annuity Commencement
Date. The assumed interest rate is the measuring point for subsequent annuity
payouts. If the actual net investment rate (annualized) exceeds the assumed
interest rate, the payout will increase at a rate equal to the amount of such
excess.

Conversely, if the actual rate is less than the assumed interest rate, annuity
payouts will decrease. If the assumed rate of interest were to be increased,
annuity payouts would start at a higher level but would decrease more rapidly
or increase more slowly.

We may use sex-distinct annuity tables in contracts that are not associated
with employer sponsored plans and where not prohibited by law.

At an Annuity Commencement Date, the contract is credited with annuity units
for each subaccount on which variable annuity payouts are based. The number of
annuity units to be credited is determined by dividing the amount of the first
periodic payout by the value of an annuity unit in each subaccount selected.
Although the number of annuity units is fixed by this process, the value of
such units will vary with the value of the underlying fund. The amount of the
second and subsequent periodic payouts is determined by multiplying the
contractowner's fixed number of annuity units in each subaccount by the
appropriate annuity unit value for the valuation date ending 14 days prior to
the date that payout is due.

The value of each subaccount's annuity unit will be set initially at $1.00. The
annuity unit value for each subaccount at the end of any valuation date is
determined by multiplying the subaccount annuity unit value for the immediately
preceding valuation date by the product of:
o The net investment factor of the subaccount for the valuation period for
which the annuity unit value is being determined, and
o A factor to neutralize the assumed investment return in the annuity table.

The value of the annuity units is determined as of a valuation date 14 days
prior to the payment date in order to permit calculation of amounts of annuity
payouts and mailing of checks in advance of their due dates. Such checks will
normally be issued and mailed at least three days before the due date.

Proof of Age, Sex and Survival

We may require proof of age, sex, or survival of any payee upon whose age, sex,
or survival payments depend.

Examples of Regular Income Payment Calculations
These examples will illustrate the impact of the length of the access period
and the impact of a withdrawal on the Regular Income Payments. These examples
assume that the investment return is the same as the assumed investment return
(AIR) to make the Regular Income Payment calculations simpler to understand.
The Regular Income Payments will vary based on the investment performance of
the underlying funds.

<TABLE>
<S> <C> <C>
Annuitant............................ Male, Age 65
Secondary Life....................... Female, Age 63
Purchase Payment..................... $200,000.00
Regular Income Payment Frequency..... Annual
AIR.................................. 4.0%
Hypothetical Investment Return....... 4.0%

20-year Access Period 30-Year Access Period
Regular Income Payment............... $ 10,600.94 $9,974.48
</TABLE>

B-3
<PAGE>

A 10% withdrawal from the Account Value will reduce the Regular Income Payments
by 10% to $9,540.85 with the 20-year access period and $8,977.03 with the
30-year access period.

At the end of the 20-year Access Period, the remaining Account Value of
$109,921.94 (assuming no withdrawals) will be used to continue the $10,600.94
Regular Income Payment during the Lifetime Income Pperiod for the lives of the
annuitant and Secondary Life. At the end of the 30-year Access Period, the
remaining Account Value of $66,884.77 (assuming no withdrawals) will be used to
continue the $9,974.48 Regular Income Payment during the Lifetime Income Period
for the lives of the annuitant and Secondary Life. (Note: the Regular Income
Payments during the Lifetime Income Period will vary with the investment
performance of the underlying funds).

Determination of Accumulation and Annuity Unit Value
A description of the days on which accumulation and annuity units will be
valued is given in the prospectus. The New York Stock Exchange's (NYSE) most
recent announcement (which is subject to change) states that it will be closed
on weekends and on these holidays: New Year's Day, Martin Luther King Day,
President's Day, Good Friday, Memorial Day, Independence Day, Labor Day,
Thanksgiving Day, and Christmas Day. If any of these holidays occurs on a
weekend day, the Exchange may also be closed on the business day occurring just
before or just after the holiday. It may also be closed on other days.

Since the portfolios of some of the fund and series will consist of securities
primarily listed on foreign exchanges or otherwise traded outside the United
States, those securities may be traded (and the net asset value of those fund
and series and of the variable account could therefore be significantly
affected) on days when the investor has no access to those funds and series.

Capital Markets

In any particular year, our capital may increase or decrease depending on a
variety of factors - the amount of our statutory income or losses (which is
sensitive to equity market and credit market conditions), the amount of
additional capital we must hold to support business growth, changes in
reserving requirements, our inability to secure capital market solutions to
provide reserve relief, such as issuing letters of credit to support captive
reinsurance structures, changes in equity market levels, the value of certain
fixed-income and equity securities in our investment portfolio and changes in
interest rates.

Advertising & Ratings

We may include in certain advertisements, endorsements in the form of a list of
organizations, individuals or other parties which recommend Lincoln New York or
the policies. Furthermore, we may occasionally include in advertisements
comparisons of currently taxable and tax deferred investment programs, based on
selected tax brackets, or discussions of alternative investment vehicles and
general economic conditions.

Nationally recognized rating agencies rate the financial strength of our
Company. The ratings do not imply approval of the product and do not refer to
the performance of the product, or to the VAA, including underlying investment
options. Ratings are not recommendations to buy our products. Each of the
rating agencies reviews its ratings periodically. Accordingly, all ratings are
subject to revision or withdrawal at any time by the rating agencies, and
therefore, no assurance can be given that these ratings will be maintained. All
ratings are on outlook stable. Our financial strength ratings, which are
intended to measure our ability to meet contract holder obligations, are an
important factor affecting public confidence in most of our products and, as a
result, our competitiveness. A downgrade of our financial strength rating could
affect our competitive position in the insurance industry by making it more
difficult for us to market our products as potential customers may select
companies with higher financial strength ratings and by leading to increased
withdrawals by current customers seeking companies with higher financial
strength ratings.

More About the S&P 500 Index

Investors look to indexes as a standard of market performance. Indexes are
groups of stocks or bonds selected to represent an entire market. The S&P 500
Index is a widely used measure of large US company stock performance. It
consists of the common stocks of 500 major corporations selected according to
size, frequency and ease by which their stocks trade, and range and diversity
of the American economy.

The LVIP SSgA S&P 500 Index Fund is not sponsored, endorsed, sold or promoted
by Standard & Poor's, a division of The McGraw-Hill Companies, Inc. ("S&P").
S&P makes no representation or warranty, express or implied, to the owners of
the fund or any member of the public regarding the advisability of investing in
securities generally or in the fund particularly or the ability of the S&P 500
Index to track general stock market performance. S&P's only relationship to the
fund is the licensing of certain trademarks and trade names of S&P and of the
S&P 500 Index which is determined, composed and calculated by S&P without
regard to the fund. S&P has no obligation to take the needs of the fund or its
shareholders into consideration in determining, composing or calculating the
S&P 500 Index. S&P is not responsible for and has not participated in the
determination of the prices and amount of the fund or the timing of the
issuance or sale of the fund or in the determination or calculation of the
equation by which the fund is to be converted into cash. S&P has no obligation
or liability in connection with the administration, marketing or trading of the
fund.

B-4
<PAGE>

S&P DOES NOT GUARANTEE THE ACCURACY AND/OR THE COMPLETENESS OF THE S&P 500
INDEX OR ANY DATA INCLUDED THEREIN AND S&P SHALL HAVE NO LIABILITY FOR ANY
ERRORS, OMISSIONS, OR INTERRUPTIONS THEREIN. S&P MAKES NO WARRANTY, EXPRESS OR
IMPLIED, AS TO RESULTS TO BE OBTAINED BY THE FUND OR ITS SHAREHOLDERS, OR ANY
OTHER PERSON OR ENTITY FROM THE USE OF THE S&P 500 INDEX OR ANY DATA INCLUDED
THEREIN. S&P MAKES NO EXPRESS OR IMPLIED WARRANTIES, AND EXPRESSLY DISCLAIMS
ALL WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE
WITH RESPECT TO THE S&P 500 INDEX OR ANY DATA INCLUDED THEREIN. WITHOUT
LIMITING ANY OF THE FOREGOING, IN NO EVENT SHALL S&P HAVE ANY LIABILITY FOR ANY
SPECIAL, PUNITIVE, INDIRECT, OR CONSEQUENTIAL DAMAGES (INCLUDING LOST PROFITS),
EVEN IF NOTIFIED OF THE POSSIBILITY OF SUCH DAMAGES.

Additional Services
Dollar Cost Averaging (DCA) - You may systematically transfer, on a monthly
basis or in accordance with other terms we make available, amounts from certain
subaccounts, or the fixed side (if available) of the contract into the
subaccounts or in accordance with other terms we make available. You may elect
to participate in the DCA program at the time of application or at anytime
before the annuity commencement date by completing an election form available
from us. The minimum amount to be dollar cost averaged is $1,500 over any
period between six and 60 months. Once elected, the program will remain in
effect until the earlier of:
o the Annuity Commencement Date;
o the value of the amount being DCA'd is depleted; or
o you cancel the program by written request or by telephone if we have your
telephone authorization on file.

We reserve the right to restrict access to this program at any time.

A transfer made as part of this program is not considered a transfer for
purposes of limiting the number of transfers that may be made, or assessing any
charges or Interest Adjustment which may apply to transfers. Upon receipt of an
additional purchase payment allocated to the DCA fixed account, the existing
program duration will be extended to reflect the end date of the new DCA
program. However, the existing interest crediting rate will not be extended.
The existing interest crediting rate will expire at its originally scheduled
expiration date and the value remaining in the DCA account from the original
amount as well as any additional purchase payments will be credited with
interest at the standard DCA rate at the time. We reserve the right to
discontinue this program at any time. DCA does not assure a profit or protect
against loss.

Automatic Withdrawal Service (AWS) - AWS provides an automatic, periodic
withdrawal of contract value to you. AWS may take place on either a monthly,
quarterly, semi-annual or annual basis, as selected by the contractowner. You
may elect to participate in AWS at the time of application or at any time
before the annuity commencement date by sending a written request to us. The
minimum contract value required to establish AWS is $10,000. You may cancel or
make changes to your AWS program at any time by sending a written request to
us. If telephone authorization has been elected, certain changes may be made by
telephone. Notwithstanding the requirements of the program, any withdrawal must
be permitted under Section 401(a)(9) of the IRC for qualified plans or
permitted under Section 72 of the IRC for non-qualified contracts. To the
extent that withdrawals under AWS do not qualify for an exemption from the
contingent deferred sales charge, we will assess any applicable surrender
charges on those withdrawals. See Contingent deferred sales charges.

Cross-Reinvestment Program/Earnings Sweep Program - Under this option, Account
Value in a designated variable subaccount of the contract that exceeds a
certain baseline amount is automatically transferred to another specific
variable subaccount(s) of the contract at specific intervals. You may elect to
participate in the cross-reinvestment program at the time of application or at
any time before the Annuity Commencement Date by sending a written request to
us or by telephone if we have your telephone authorization on file. You
designate the holding account, the receiving account(s), and the baseline
amount. Cross-reinvestment will continue until we receive authorization to
terminate the program.

The minimum holding Account Value required to establish cross-reinvestment is
$10,000. A transfer under this program is not considered a transfer for
purposes of limiting the number of transfers that may be made. We reserve the
right to discontinue this service at any time.

B-5
<PAGE>

Portfolio Rebalancing - Portfolio rebalancing is an option, which, if elected
by the contractowner, restores to a pre-determined level the percentage of the
contract value, allocated to each variable subaccount. This pre-determined
level will be the allocation initially selected when the contract was
purchased, unless subsequently changed. The portfolio rebalancing allocation
may be changed at any time by submitting a written request to us. If portfolio
rebalancing is elected, all purchase payments allocated to the variable
subaccounts must be subject to portfolio rebalancing. Portfolio rebalancing may
take place on either a monthly, quarterly, semi-annual or annual basis, as
selected by the contractowner. The contractowner may terminate the portfolio
rebalancing program or re-enroll at any time by sending a written request to
us. If telephone authorization has been elected, the contractowner may make
these elections by phone. The portfolio rebalancing program is not available
following the annuity commencement date.

Other Information
Due to differences in redemption rates, tax treatment or other considerations,
the interests of contractowners under the variable life accounts could conflict
with those of contractowners under the VAA. In those cases, where assets from
variable life and variable annuity separate accounts are invested in the same
fund(s) (i.e., where mixed funding occurs), the Boards of Directors of the fund
involved will monitor for any material conflicts and determine what action, if
any, should be taken. If it becomes necessary for any separate account to
replace shares of any fund with another investment, that fund may have to
liquidate securities on a disadvantageous basis. Refer to the prospectus for
each fund for more information about mixed funding.

Financial Statements

The December 31, 2010 financial statements of the VAA and the December 31, 2010
financial statements of Lincoln New York appear on the following pages.

B-6

Lincoln New York Account N For Variable Annuities CORRESPCorrespondence with SEC