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Ohio National Financial Services
One Financial Way
Cincinnati, Ohio 45242
VIA EDGAR CORRESPONDENCE
September 11, 2012
Ms. Michelle Roberts
Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
100 F. Street, N.E.
Washington, D.C. 20549-0506
Re: | Ohio National Variable Account A |
ONcore Flex II Individual Variable Annuity |
Post-Effective Amendment No. 10 |
File Nos. 811-09178 & 333-164069 |
Dear Ms. Roberts:
This letter responds to comments of the staff of the Securities and Exchange Commission (“Commission”) on the above-referenced post-effective amendment (the “Post-Effective Amendment”), which you communicated to me by telephone on September 5, 2012. Registrant filed the Post-Effective Amendment with the Commission on July 31, 2012 pursuant to Rule 485(a) under the Securities Act of 1933 (“1933 Act”) contemporaneously with seven other post-effective amendments (collectively, along with the Post-Effective Amendment, the “filings”).
For convenience, each of Registrant’s responses below is preceded by the applicable Staff comment. Capitalized terms used herein have the meanings given to them in the Post-Effective Amendment. Registrant will give effect to disclosure changes made in response to Staff comments by means of post-effective amendments filed pursuant to Rule 485(b) under the 1933 Act.
Comments
• | The comments are given as to ONcore Flex II. To the extent any comments apply to the other filings, please make them in those filings. |
Response:To the extent such comments apply to the following post-effective amendment filings by Registrant, Ohio National Variable Account A, our responses are applicable to each such filing:
Product filing | 40 Act File No. | 33 Act File No. | ||
ONcore Wrap, Post-Effective Amendment No. 22 | 811-01978 | 333-134982 | ||
ONcore Lite II, Post-Effective Amendment No. 17 | 811-01978 | 333-156430 | ||
ONcore Ultra II, Post-Effective Amendment No. 17 | 811-01978 | 333-156432 | ||
ONcore Lite III, Post-Effective Amendment No. 10 | 811-01978 | 333-164075 | ||
ONcore Xtra II, Post-Effective Amendment No. 10 | 811-01978 | 333-164073 | ||
ONcore Premier II, Post-Effective Amendment No. 10 | 811-01978 | 333-164070 | ||
ONcore Premier WF, Post-Effective Amendment No. 7 | 811-01978 | 333-171785 |
Ms. Roberts
September 11, 2012
Page 2 of 5
1. Supplement – Please include a lead-in sentence to indicate the page in the prospectus on which the replaced section starts.
Response: The requested change has been made.
2. Investment Restrictions for Certain Optional Riders, Managed Volatility Model – Please include a page reference to where a customer can find a description of the breakdown of the Managed Volatility Model in the prospectus.
Response: The disclosure regarding the GWLB Plus, Joint GLWB Plus and GPP (2012) (applied for on or after October 1, 2012) investment restrictions has been revised as follows:
If you apply for the GLWB Plus, Joint GLWB Plus or GPP (2012) rider on or after October 1, 2012, your purchase payments and Contract Value must be allocated in accordance with the restrictions specified below. The Fixed Accumulation Account is not an available investment option with the GLWB Plus, Joint GLWB Plus or GPP (2012). Your purchase payments and Contract Value must be allocated in compliance with (a) or (b):
(a) | 100% must be allocated to the Managed Volatility Model. The Managed Volatility Model is one of our Asset Allocation Models. It seeks to provide protection from market downturns and more consistent returns over time. See “Optional Asset Allocation Models.” Please see Appendix D for the investment options included in the Model or contact us at 1-888-925-6446 or your registered representative for more detailed information on the Model… |
Similarly, cross-references to Appendix D have been added in the other portions of the “Investment Restrictions for Certain Optional Riders” that set forth Models in which an owner may allocate payments or Contract Value. Appendix D has been added to the supplement. A copy of Appendix D is attached hereto as Exhibit A.
3. Franklin Templeton Foreign Securities Fund – Please confirm the name of the Franklin Templeton Foreign Securities Fund is shown correctly in the list of investment options.
Response: The Registrant will confirm that the name is shown correctly or correct any typographical errors.
Registrant acknowledges that should the Commission or the Staff, acting pursuant to delegated authority, declare the filings effective or permit them to go effective on their own, the Commission is not foreclosed from taking any action with respect to the filings. Registrant also acknowledges that the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filings effective or allowing them to go effective on their own, does not relieve the registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filings and that the registrant may not assert such action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact me at (513) 794-6278 should you have any questions.
Sincerely,
/s/ Kimberly A. Plante
Kimberly A. Plante
Senior Associate Counsel
Ms. Roberts
September 11, 2012
Page 3 of 5
EXHIBIT A
Appendix D
The following provides a list of the portfolios currently included in the Asset Allocation Models we make available.
Managed Volatility Model
Portfolio | Percentage of Model | |
TOPS™ Protected Moderate Growth ETF Portfolio | 35% | |
Legg Mason Dynamic Multi-Strategy VIT Portfolio | 15% | |
PIMCO Global Diversified Allocation Portfolio | 15% | |
TOPS™ Protected Balanced ETF Portfolio | 15% | |
Invesco V.I. Balanced-Risk Allocation Fund | 10% | |
AllianceBernstein Dynamic Asset Allocation Portfolio | 2.5% | |
Federated Managed Volatility Fund II | 2.5% | |
Goldman Sachs Global Markets Navigator Fund | 2.5% | |
Lazard Retirement Multi-Asset Targeted Volatility Portfolio | 2.5% |
Model 1: Conservative
Portfolio | Percentage of Model | |
PIMCO Total Return Portfolio | 45% | |
PIMCO Real Return Portfolio | 19% | |
High Income Bond Portfolio | 9% | |
Invesco V.I. Balanced-Risk Allocation Portfolio | 5% | |
Goldman Sachs Large Cap Value Fund | 4% | |
PIMCO Global Bond Portfolio (Unhedged) | 4% | |
Bristol Portfolio | 2% | |
Franklin Flex Cap Growth Securities Fund | 2% | |
Lazard Retirement International Equity Portfolio | 2% | |
PIMCO CommodityRealReturn® Strategy Portfolio | 2% | |
Royce Small-Cap Portfolio | 2% | |
Strategic Value Portfolio | 2% | |
Templeton Foreign Securities Fund | 2% |
Model 2: Moderately Conservative
Portfolio | Percentage of Model | |
PIMCO Total Return Portfolio | 36% | |
PIMCO Real Return Portfolio | 13% | |
Invesco V.I. Balanced-Risk Allocation Portfolio | 8% | |
High Income Bond Portfolio | 7% | |
Goldman Sachs Large Cap Value Fund | 6% | |
Lazard Retirement International Equity Portfolio | 6% | |
Templeton Foreign Securities Fund | 4% | |
Royce Small-Cap Portfolio | 3% | |
Bristol Growth Portfolio | 2% | |
Bristol Portfolio | 2% | |
Fidelity® VIP Mid Cap Portfolio | 2% | |
Fidelity® VIP Real Estate Portfolio | 2% | |
Franklin Flex Cap Growth Securities Fund | 2% | |
PIMCO CommodityRealReturn® Strategy Portfolio | 2% | |
PIMCO Global Bond Portfolio (Unhedged) | 2% | |
Strategic Value Portfolio | 2% | |
Bryton Growth Portfolio | 1% |
Ms. Roberts
September 11, 2012
Page 4 of 5
Model 3: Balanced
Portfolio | Percentage of Model | |
PIMCO Total Return Portfolio | 24% | |
Invesco V.I. Balanced-Risk Allocation Portfolio | 12% | |
Lazard Retirement International Equity Portfolio | 9% | |
Goldman Sachs Large Cap Value Fund | 8% | |
PIMCO Real Return Portfolio | 7% | |
Templeton Foreign Securities Fund | 7% | |
Franklin Flex Cap Growth Securities Fund | 4% | |
High Income Bond Portfolio | 4% | |
Strategic Value Portfolio | 4% | |
Bristol Portfolio | 3% | |
Fidelity® VIP Mid Cap Portfolio | 3% | |
Royce Small-Cap Portfolio | 3% | |
Bristol Growth Portfolio | 2% | |
Bryton Growth Portfolio | 2% | |
Fidelity® VIP Real Estate Portfolio | 2% | |
Lazard Retirement Emerging Markets Equity Portfolio | 2% | |
PIMCO CommodityRealReturn® Strategy Portfolio | 2% | |
PIMCO Global Bond Portfolio (Unhedged) | 2% |
Model 4: Moderate Growth
Portfolio | Percentage of Model | |
PIMCO Total Return Portfolio | 12% | |
Goldman Sachs Large Cap Value Fund | 11% | |
Lazard Retirement International Equity Portfolio | 11% | |
Invesco V.I. Balanced-Risk Allocation Portfolio | 10% | |
Templeton Foreign Securities Fund | 10% | |
Royce Small-Cap Portfolio | 7% | |
Franklin Flex Cap Growth Securities Fund | 6% | |
Strategic Value Portfolio | 5% | |
Fidelity® VIP Mid Cap Portfolio | 4% | |
Bristol Portfolio | 3% | |
Bryton Growth Portfolio | 3% | |
Lazard Retirement Emerging Markets Equity Portfolio | 3% | |
PIMCO CommodityRealReturn® Strategy Portfolio | 3% | |
PIMCO Global Bond Portfolio (Unhedged) | 3% | |
PIMCO Real Return Portfolio | 3% | |
Bristol Growth Portfolio | 2% | |
Fidelity® VIP Real Estate Portfolio | 2% | |
High Income Bond Portfolio | 2% |
Model 5: Growth
Portfolio | Percentage of Model | |
Goldman Sachs Large Cap Value Fund | 14% | |
Lazard Retirement International Equity Portfolio | 13% | |
Templeton Foreign Securities Fund | 12% | |
Royce Small-Cap Portfolio | 10% | |
Invesco V.I. Balanced-Risk Allocation Portfolio | 8% | |
Franklin Flex Cap Growth Securities Fund | 7% | |
Strategic Value Portfolio | 6% | |
Lazard Retirement Emerging Markets Equity Portfolio | 5% | |
Bristol Portfolio | 4% | |
Fidelity® VIP Mid Cap Portfolio | 4% | |
PIMCO CommodityRealReturn® Strategy Portfolio | 4% |
Ms. Roberts
September 11, 2012
Page 5 of 5
Bryton Growth Portfolio | 3% | |
Bristol Growth Portfolio | 2% | |
Fidelity® VIP Real Estate Portfolio | 2% | |
High Income Bond Portfolio | 2% | |
PIMCO Real Return Portfolio | 2% | |
PIMCO Total Return Portfolio | 2% |