SecProbe.io

April 26, 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. 4 to Registration Statement on Form S-1
Filed April 26, 2018
File No. 333-221521
Dear Mr. Pearson:
            We have reviewed your amended registration statement and have the following
comment.  In some of our comments, we may ask you to provide us with information so we may
better understand your disclosure.
            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 the comment, we may have additional comments.
Form S-1/A Filed April 26, 2018
Notes to Consolidated Financial Statements
6) DAC AND Policyholder Bonus Interest Credits , page F-59
1.Regarding the parenthetical disclosures to certain line items you made to the consolidated
statements of income (loss) on F-4 and elsewhere such as on pages 20, 96, and 113, please
similarly revise, as applicable, the pro forma tables on pages 23 and 100 and the segment
earnings (loss) tables on pages 118, 120 and 126.

 FirstName LastNameMark Pearson
 Comapany NameAXA Equitable Holdings, Inc.
 June 16, 2017 Page 2
 FirstName LastName
Mark Pearson
AXA Equitable Holdings, Inc.
April 26, 2018
Page 2
            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 Dorrie Yale at 202-551-8776 or Erin Jaskot at 202-551-3442 with any other questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Peter J. Loughran