SEC Company Response from Equitable Financial Life Insurance Co (CIK 0000727920) — Apr 29, 2020
Equitable Financial Life Insurance Co (CIK 0000727920)
Date: April 29, 2020 · CIK: 0000727920 · Accession: 0001193125-20-125922
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File numbers found in text: 333-236443
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CORRESP 1 filename1.htm SEC Correspondence SHANE DALY Vice President and Associate General Counsel (212) 314-3912 Fax: (212) 314-3959 April 29, 2020 VIA EDGAR AND EMAIL Suzanne Hayes United States Securities and Exchange Commission Office of Capital Markets Trends Division of Corporate Finance Washington, DC 20549-8629 Re: AXA Equitable Life Insurance Company (“AXA Equitable”) Acceleration Request Registration Statement on Form S-3 File No. 333-236443 CIK 0000727920 Dear Ms. Hayes: On April 21, 2020, AXA Equitable filed Pre-Effective Amendment No. 1 to the above-captioned registration statement (“Registration Statement”) under the Securities Act of 1933 (“Securities Act”) with respect to the Escrow Shield Plus contract issued by AXA Equitable. Request for Acceleration of the Effectiveness of the Registration Statement On behalf of the Registrant and the principal underwriter, AXA Distributors, LLC, we hereby request acceleration of the effectiveness of the Registration Statement, pursuant to Rule 461 under the Securities Act, so that the Registration Statement will be declared effective at 9:00 a.m. on May 1, 2020, or as soon as practicable thereafter. In this connection, the Registrant and the principal underwriter, AXA Distributors, LLC, have authorized me to represent on their behalf that they are aware of their obligations under the Securities Act. Please contact the undersigned at (212) 314-3912 if you have any questions regarding the Registration Statement or this request. Very truly yours, /s/ Shane Daly Shane Daly AXA Equitable Life Insurance Company