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Equitable Financial Life Insurance Company SCS PLUS 21

 Darin Smith

Associate General Counsel

 (319) 573-2676

 November 15, 2022

VIA EDGAR

 Elisabeth Bentzinger, Esq.

United States Securities and Exchange Commission

 Office of
Insurance Products

 Division of Investment Management

 Mail
Stop 8629

 Washington, DC 20549-8629

Re:
 Equitable Financial Life Insurance Company

Post-Effective Amendment No. 1 to Form S-3 Registration Statement

Registration Statement No. 333-262807

CIK 0000727920

 Dear Ms. Bentzinger:

The purpose of this letter is to provide a response to the oral comments you provided with respect to the above-referenced filing. We have made the revisions
as requested and discussed. Also as requested, we confirm that the Performance Cap Rates in the supplement are reasonable based on several factors including recent suggested bids analysis and current market conditions.

I trust that the revisions address your comments adequately. If you have any questions regarding the revisions, please contact the undersigned at (319) 573-2676. Thank you very much for your assistance with this filing.

 Best regards,

 /s/ Darin Smith

Darin Smith

 Equitable Financial Life Insurance Company

Equitable Financial Life Insurance Company of America

Supplement dated             , 2022 to the current prospectus for Structured Capital Strategies® PLUS 21

This Supplement modifies certain information in the above-referenced prospectus (the “Prospectus”) offered by Equitable Financial Life Insurance Company (the
“Company”). You should read this Supplement in conjunction with your Prospectus and retain it for future reference. This Supplement incorporates the Prospectus by reference. Unless otherwise indicated, all other information included in
your Prospectus remains unchanged. The terms we use in this Supplement have the same meaning as in your Prospectus. We will send you another copy of any prospectus or supplement without charge upon request. Please contact the customer service center
at 877-899-3743.

We are offering the following new Segment Options and Segment Types: (1) A new Dual Step Up Segment Option (described below); (2) A new Loss Limiter Segment Option
(described below); (3) Additional Standard Segment Types with a -15%, -20% and -40% Segment Buffer; (4) Additional Dual Direction Segment Types with a -10%, -15% and -20% Segment Buffer for 6-year Segment
Durations and a -10% and -15% Segment Buffer for 1-year Segment Durations; (5) Additional Annual Lock Segment Types with a 6-year Segment Duration, -10% Segment Buffer; (6) Additional Step Up Segment Types with a -15% Segment Buffer for 1-year
Segment Durations and –10% for 6-year Segment Durations; and (7) Additional Enhanced Upside Segment Types with a 1-year Segment Duration, -10% Segment Buffer.

The following chart lists the current Segment Types (including any new Segment Types added herein):

  Segment Option

Segment Duration

Segment Buffer

Minimum Performance Cap Rate

Standard1

6 year

-10%; -15%; -20%; -40%

12%

1 year

-10%; -15%; -20%; -40%

2%

 DualDirection2

6 year

-10%; -15%; -20%

12%; 15%; 20%

1 year

-10%; -15%

2%

AnnualLock2

6 year

-10%

2%

StepUp2

6 year

-10%

12%

1 year

-10%; -15%

2%

 EnhancedUpside3,4

6 year

-10%; -15%

12%

1 year

-10%

2%

 DualStep
Up2

1 year

-10%; -15%

2%

LossLimiter3

6 year5

-10%

12%

1 year6

-10%

2%

1
 Indices available: S&P 500 Price Return; Russell 2000® Price Return; MSCI EAFE Price Return; NASDAQ-100 Price Return; MSCI Emerging Markets Price Return (not available with 6-year Standard Segments); EURO STOXX 50® Return (not available with 6-year
Standard Segments)

2
 Indices available: S&P 500 Price Return; Russell 2000® Price Return (not available with 6-year Step Up Segments); MSCI EAFE Price Return (not available with
6-year Step Up Segments); NASDAQ-100 Price Return (not available with 6-year Step Up Segments)

3
 Indices available: S&P 500 Price Return

4
 Enhanced Upside Rates of 110% and 125%.

5
 Segment Investment Protection Level of 95%

6
 Segment Investment Protection Level of 90%

 On a Segment Maturity Date, the highest level of protection is the -40% Segment Buffer and
lowest level of protection is the -10% Segment Buffer.

 Please note: Unless otherwise noted, all discussions about a Segment Option or Segment Type, including discussions and statements about and
examples of the Segment Rates of Return, assume that the Return of Premium Death Benefit is not elected.

(1) Dual Step Up Segment Option.

We are adding a new Segment Option – Dual Step Up. A Dual Step Up Segment is any Segment belonging to a Segment Type whose name includes “Dual Step Up”.
For Dual Step Up Segments the Segment Rate of Return is equal to the Performance Cap Rate if the Index Performance Rate is greater than or equal to the Segment Buffer or the Index Performance Rate if the Index Performance Rate is negative, subject
to the Segment Buffer.

 Dual Step Up Segment example: For the S&P 500 Price Return Index/Dual Step Up/1
year/-10% Segment Type, a Segment could be established as S&P 500 Price Return Index Dual Step Up/1 year/-10% with a 10% Performance Cap Rate. This means that you
will participate in the performance of the S&P 500 Price Return Index for one year starting from the Segment Start Date. If the Index performs equal to or better than the Segment Buffer, your Segment Rate of Return will be 10% for that Segment
Duration. This means if the Index performs negatively down to and including -10%, then your Segment Rate of Return will be 10%. If the Index performs more negatively than the Segment Buffer, your Segment Rate of Return will be negative equal to the
percentage loss in the Index which exceeds the Segment Buffer.

 Dual Step Up Segments will
generally have lower Performance Cap Rates than Standard Segments with the same Index, Segment Duration and Segment Buffer. This is because the Segment Rate of Return for Dual Step Up Segments is equal to the Performance Cap Rate for certain
lower and negative returns. Please note that the Performance Cap Rate and Segment Rate of Return for Dual Step Up Segments are cumulative rates of return from the Segment Start Date to the Segment Maturity Date. They are NOT annual rates.

 The following Dual Step Up Segment Types are being added:

  Index

Segment Duration

Segment Buffer

Minimum Performance Cap Rate

 S&P500 Price Return Index

1 year

-10%; -15%

2%

 Russell2000® Price Return

1 year

-10%; -15%

2%

 MSCIEAFE Price Return

1 year

-10%; -15%

2%

 NASDAQ-100Price
Return

1 year

-10%; -15%

2%

 Dual Step Up
Segments. For Dual Step Up Segments, the Segment Rate of Return is equal to the Performance Cap Rate unless the Index Performance Rate is less than the Segment Buffer in which case it is
equal to the Index Performance Rate subject to the Segment Buffer, minus the Return of Premium Death Benefit charge if the Return of Premium Death Benefit is elected, as follows:

  If the Index Performance Rate:

Your Segment Rate of Return will be:

is greater than or equal to the Segment Buffer

 equal to the Performance Cap Rate

minus the Return of Premium Death Benefit charge if the Return of Premium Death Benefit is elected

is negative by a percentage greater than the Segment Buffer

 negative, equal to the extent of the percentage exceeding the Segment Buffer

minus the Return of Premium Death Benefit charge if the Return of Premium Death Benefit is elected

 These values are based on the value of the relevant Index on the
Segment Start Date and the Segment Maturity Date. Any fluctuations in the value of the Index between those dates is ignored in calculating the Segment Rate of Return.

Please note: Because of the way Segment Rate of Return is calculated for Dual Step Up Segments, when the Index Performance Rate is near the Segment Buffer, a very
small difference in the Index Performance Rate on the Segment Maturity Date can result in a very different Segment Rate of Return. For example, if the Performance Cap Rate is 10.00%, the Segment Buffer is -10%
and the Index Performance Rate is -10.00% on the Segment Maturity Date, the Segment Rate of Return would be 10.00% whereas, if the Index Performance Rate is -10.01% on
the Segment Maturity Date the Segment Rate of Return is -0.01%.

Dual Step Up Segment Examples

Assume that you invest $1,000 in an S&P 500 Price Return Index Dual Step Up, 1-year Segment with a -10% Segment Buffer, we
set the Performance Cap Rate for that Segment at 10%, and you make no withdrawal from the Segment and do not elect the Return of Premium death benefit.

If the S&P 500 Price Return Index is 20% higher on the Segment Maturity Date than on the Segment Start Date, you will receive a 10% Segment Rate of Return, and your
Segment Maturity Value would be $1,100. We reach that amount as follows:

•

The Index Performance Rate (20%) is greater than or equal to the Segment Buffer, so the Segment Rate of Return (10%) is equal to the Performance Cap Rate.

•

The Segment Return Amount ($100) is equal to the Segment Investment ($1,000) multiplied by the Segment Rate of Return (10%).

•

The Segment Maturity Value ($1,100) is equal to the Segment Investment ($1,000) plus the Segment Return Amount ($100).

 If the S&P 500 Price Return Index is 5% higher on the Segment Maturity Date than on the Segment Start Date, you will
receive a 10% Segment Rate of Return, and your Segment Maturity Value would be $1,100. We reach that amount as follows:

•

The Index Performance Rate (5%) is greater than or equal to the Segment Buffer, so the Segment Rate of Return (10%) is equal to the Performance Cap Rate.

•

The Segment Return Amount ($100) is equal to the Segment Investment ($1,000) multiplied by the Segment Rate of Return (10%).

•

The Segment Maturity Value ($1,100) is equal to the Segment Investment ($1,000) plus the Segment Return Amount ($100).

If the S&P 500 Price Return Index is 5% lower on the Segment Maturity Date than on the Segment Start Date, then you will receive a 10% Segment Rate of Return, and
your Segment Maturity Value would be $1,100. We reach that amount as follows:

•

The Index Performance Rate (-5%) is greater than or equal to the Segment Buffer, so the Segment Rate of Return (10%) is equal to the Performance Cap Rate.

•

The Segment Return Amount ($100) is equal to the Segment Investment ($1,000) multiplied by the Segment Rate of Return (10%).

•

The Segment Maturity Value ($1,100) is equal to the Segment Investment ($1,000) plus the Segment Return Amount ($100).

If the S&P 500 Price Return Index is 15% lower on the Segment Maturity Date than on the Segment Start Date, then you will receive a -5% Segment Rate of Return, and
your Segment Maturity Value would be $950. We reach that amount as follows:

•

The Index Performance Rate is -15% and the Segment Buffer absorbs the first 10% of negative performance, so the Segment Rate of Return is -5% which is equal to the percentage exceeding the Segment Buffer (5%).

•

The Segment Return Amount (-$50) is equal to the Segment Investment ($1,000) multiplied by the Segment Rate of Return (-5%).

•

The Segment Maturity Value ($950) is equal to the Segment Investment ($1,000) plus the Segment Return Amount (-$50).

 Assume that you invest $1,000 in an S&P 500 Price Return Index Dual Step Up, 1-year Segment
with a -10% Segment Buffer, we set the Performance Cap Rate for that Segment at 10%, and you make no withdrawal from the Segment and do elect the Return of Premium death benefit.

 If the S&P 500 Price Return Index is 20% higher on the Segment Maturity Date than on the
Segment Start Date, you will receive a 10% Segment Rate of Return, and your Segment Maturity Value would be $1,098. We reach that amount as follows:

•

The Index Performance Rate (20%) is greater than or equal to the Segment Buffer, so the Segment Rate of Return (9.8%) is equal to the Performance Cap Rate (10%) minus the Return of Premium Death Benefit charge (0.20%).

•

The Segment Return Amount ($98) is equal to the Segment Investment ($1,000) multiplied by the Segment Rate of Return (9.8%).

•

The Segment Maturity Value ($1,098) is equal to the Segment Investment ($1,000) plus the Segment Return Amount ($98).

Risk Factors unique to Dual Step Up Segment Types

•

For Dual Step Up Segments, your Segment Rate of Return is limited by its Performance Cap Rate, which could cause your Segment Rate of Return to be lower than it would otherwise be if you invested in a mutual fund or
exchange traded fund designed to track the performance of the applicable Index.

•

Dual Step Up Segments will tend to have a lower Performance Cap Rate than Standard Segments with the same Index, Segment Duration and Segment Buffer.

 (2) Loss Limiter Segment Option.

 We are adding a new Segment Option – Loss Limiter. A Loss Limiter Segment is any Segment
belonging to a Segment Type whose name includes “Loss Limiter”. For Loss Limiter Segments, the Segment Rate of Return is equal to the greater of (a) the Index Performance Rate subject to the Performance Cap Rate and Segment Buffer and
(b) the Segment Investment Protection Level minus 1. We currently offer a Segment Investment Protection Level of 90% (Loss Limiter 90) for 1-year Segments and a Segment Investment Protection Level of 95%
(Loss Limiter 95) for 6-year Segments. The 95% and 90% Segment Investment Protection Levels mean that you will lose no more than 5% or 10%, respectively, of your Segment Investment due to Index performance.

 Loss Limiter Segment example: For the S&P 500 Price Return Index/ Loss Limiter 90 /1 year/-10% Segment Type, a Segment could be established as S&P 500 Price Return Index Loss Limiter 90 /1 year/-10% with a 9% Performance Cap Rate [and 90% Segment
Investment Protection]. This means that you will participate in the performance of the S&P 500 Price Return Index for 1 year starting from the Segment Start Date. If the Index performs equal to or better than the Segment Buffer, your Segment
Rate of Return could be as much as 9% for that Segment Duration. If the Index performs more negatively than the Segment Buffer, your Segment Rate of Return will be negative but no more than the Segment Investment Protection Level minus 1, in this
example, -10%.

 Loss Limiter Segments will
generally have lower Performance Cap Rates than Standard Segments with the same Index, Segment Duration and Segment Buffer. This is because the Segment Rate of Return for Loss Limiter Segments limits the loss for negative returns to the Segment
Investment Protection Level minus 1. Please note that the Performance Cap Rate and Segment Rate of Return for Loss Limiter Segments are cumulative rates of return from the Segment Start Date to the Segment Maturity Date. They are NOT annual rates,
even if the Segment Duration is longer than one year.

 The following Loss Limiter Segment
Types are being added:

  Index

Segment Duration

Segment Buffer

Minimum Performance Cap Rate

 S&P500 Price Return Index

6 year*
 1 year**

-10%
 -10%

12%
 2%

*
 Segment Investment Protection Level of 95%

**
 Segment Investment Protection Level of 90%

 Loss Limiter Segments. For Loss Limiter Segments, the Segment Rate of Return is equal to the greater of (a) Index Performance Rate, subject to the Performance Cap Rate and Segment Buffer and (b) the Segment Investment
Protection Level minus 1; minus the Return of Premium Death Benefit charge if the Return of Premium Death Benefit is elected, as follows:

where (a) is equal to:

  If the Index Performance Rate:

Your Segment Rate of Return will be:

exceeds the Performance Cap Rate

 equal to the Performance Cap Rate

minus the Return of Premium Death Benefit charge if the Return of Premium Death Benefit is elected

is positive but less than or equal to the Performance Cap Rate

 equal to the Index Performance Rate

minus the Return of Premium Death Benefit charge if the Return of