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SEC Company Response from Equitable Financial Life Insurance Co (CIK 0000727920) — May 7, 2020

Equitable Financial Life Insurance Co (CIK 0000727920)
Date: May 7, 2020 · CIK: 0000727920 · Accession: 0001193125-20-135906

AI Filing Summary & Sentiment

File numbers found in text: 333-236443

Date
May 7, 2020
Author
Vice President and
Form
CORRESP
Company
Equitable Financial Life Insurance Co (CIK 0000727920)

Letter

VIA EDGAR AND EMAIL United States Securities and Exchange Commission Office of Capital Markets Trends Division of Corporate Finance Acceleration Request Registration Statement on Form S-3 File No. 333-236443 CIK

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 withdraw the prior acceleration letter request dated April 29, 2020, and 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 5:00 p.m. on May 7, 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

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 SHANE DALY

Vice President and

 Associate General
Counsel

 (212) 314-3912

 Fax: (212)
314-3959

 May 7, 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 withdraw the prior acceleration letter request dated April 29,
2020, and 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 5:00 p.m. on May 7, 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