SEC Comment Letter for Equitable Holdings, Inc. (EQH, EQH-PA, EQH-PC) (CIK 0001333986) (EQH) — Feb 26, 2018
Equitable Holdings, Inc. (EQH, EQH-PA, EQH-PC) (CIK 0001333986)
Date: Feb. 26, 2018 · CIK: 0001333986 · Accession: 0000000000-18-006114
AI Filing Summary & Sentiment
File numbers found in text: 333-221521
Letter
February 23, 2018 Mark Pearson President and Chief Executive Officer AXA Equitable Holdings, Inc. 1290 Avenue of the Americas New York, NY 10104 Re:AXA Equitable Holdings, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed February 14, 2018 File No. 333-221521 Dear Mr. Pearson: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 12, 2017 letter. Amendment No. 1 to Registration Statement on Form S-1 filed February 14, 2018 Management’s Discussion and Analysis of Financial Condition and Results of Operations Key Operating Measures, page 104 1.Please refer to your response to our prior comment 10 and your change in the title of your measure from operating earnings to adjusted operating earnings. As you reconcile your non-GAAP measure to net income (loss) attributable to Holdings, as your use of the term adjusted infers that your GAAP financial statements include an after tax line item titled operating earnings, which is not the case, and as operating earnings is the term you use to describe the measure of profit or loss for your segments, please revise the title of this measure accordingly. Also, please disclose in your reconciliation the nature and amount
FirstName LastNameMark Pearson Comapany NameAXA Equitable Holdings, Inc. June 16, 2017 Page 2 FirstName LastName Mark Pearson AXA Equitable Holdings, Inc. February 23, 2018 Page 2 of non-recurring tax items. Finally, revise your reconciliation to start it with the GAAP measure and reconcile to your non-GAAP measure. You may contact Ibolya Ignat at 202-551-3636 or Jim Rosenberg at 202-551-3679 if you have questions regarding comments on the financial statements and related matters. Please contact Irene Paik at 202-551-6553 or Erin Jaskot at 202-551-3442 with any other questions. Division of Corporation Finance Office of Healthcare & Insurance cc: Peter J. Loughran
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February 23, 2018
Mark Pearson
President and Chief Executive Officer
AXA Equitable Holdings, Inc.
1290 Avenue of the Americas
New York, NY 10104
Re:AXA Equitable Holdings, Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed February 14, 2018
File No. 333-221521
Dear Mr. Pearson:
We have reviewed your amended registration statement and have the following
comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our December 12, 2017 letter.
Amendment No. 1 to Registration Statement on Form S-1 filed February 14, 2018
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Key Operating Measures, page 104
1.Please refer to your response to our prior comment 10 and your change in the title of your
measure from operating earnings to adjusted operating earnings. As you reconcile your
non-GAAP measure to net income (loss) attributable to Holdings, as your use of the term
adjusted infers that your GAAP financial statements include an after tax line item titled
operating earnings, which is not the case, and as operating earnings is the term you use to
describe the measure of profit or loss for your segments, please revise the title of this
measure accordingly. Also, please disclose in your reconciliation the nature and amount
FirstName LastNameMark Pearson
Comapany NameAXA Equitable Holdings, Inc.
June 16, 2017 Page 2
FirstName LastName
Mark Pearson
AXA Equitable Holdings, Inc.
February 23, 2018
Page 2
of non-recurring tax items. Finally, revise your reconciliation to start it with the GAAP
measure and reconcile to your non-GAAP measure.
You may contact Ibolya Ignat at 202-551-3636 or Jim Rosenberg at 202-551-3679 if you
have questions regarding comments on the financial statements and related matters. Please
contact Irene Paik at 202-551-6553 or Erin Jaskot at 202-551-3442 with any other questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Peter J. Loughran