Exhibit 16
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April 10, 2015
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-7561
Dear Sirs/Madams:
We have read the following which is from Item 11(i) of Lincoln Benefit Life
Company's Draft of Form S-1 expected to be filed on or about April 13, 2015,
delivered to us from Resolution Life Holdings Inc.:
After conducting a 'request for proposal' process with three major
accounting firms for the annual independent audit of Resolution and its
subsidiaries, and after completing our 2014 filing which included our 2013
financial statements, Lincoln Benefit's Board dismissed Deloitte & Touche
LLP ("Deloitte") as our independent registered public accounting firm. The
decision to change accountants was recommended by the Audit Committee to the
Board, and approved by the Board, on August 13, 2014. On the same day, the
Audit Committee recommended appointment to the Board, and the Board
appointed, PricewaterhouseCoopers LLP ("PwC") as our new independent
registered public accounting firm to audit Lincoln Benefit's financial
statements for the period beginning April 1, 2014. Deloitte was also
reengaged on March 17, 2015 to audit Lincoln Benefit's financial statements
for the three months ended March 31, 2014.
The reports of Deloitte on Lincoln Benefit's financial statements for each
of the two fiscal years ended December 31, 2013 and the three months ended
March 31, 2014 did not contain any adverse opinion or a disclaimer of
opinion and were not qualified or modified as to uncertainty, audit scope or
accounting principles.
During the two years ended December 31, 2013 and through the date of
Deloitte's report on Lincoln Benefit's financial statements for the three
months ended March 31, 2014, there were: (i) no disagreements between
Lincoln Benefit and Deloitte on any matter of accounting principles or
practices, financial statement disclosure, or auditing scope or procedures,
which disagreements, if not resolved to the satisfaction of Deloitte, would
have caused Deloitte to make reference to the subject matter of the
disagreements in connection with its report, and (ii) no reportable events
within the meaning set forth in Item 304(a)(1)(v) of Regulation S-K.
Lincoln Benefit provided Deloitte with a copy of this disclosure before its
filing with the SEC and requested that Deloitte provide us with a letter
addressed to the SEC stating whether or not it agrees with the above
statements. A copy of this letter, dated April 10, 2015, is filed as Exhibit
16 to this registration form on Form S-1.
During the two years ended December 31, 2013 and through the date of PwC's
engagement, we did not consult with PwC regarding (1) the application of
accounting principles to a specified transaction, either completed or
proposed, or the type of audit opinion that might be
Member of
Deloitte Touche Tohmatsu Limited
rendered on Lincoln Benefit's financial statements, and PwC did not provide
either a written report or oral advice to Lincoln Benefit that was an
important factor considered by Lincoln Benefit in reaching a decision as to
any accounting, auditing, or financial reporting issue, or (2) any matter
that was either the subject of a disagreement (as defined in Item
304(a)(1)(iv) of Regulation S-K and the related instructions) or a
reportable event (as defined in Item 304(a)(1)(v) of Regulation S-K).
We have the following comments on the above:
1. We agree with the statements made in the first four indented paragraphs for
which we have a basis on which to comment on, and we agree with, the
disclosures.
2. We have no basis on which to agree or disagree with the statements made in
the fifth indented paragraph which we have no basis on which to comment.
Yours truly,
/s/ Deloitte & Touche LLP