SEC Company Response from Equitable Holdings, Inc. (EQH, EQH-PA, EQH-PC) (CIK 0001333986) (EQH) — May 7, 2018
Equitable Holdings, Inc. (EQH, EQH-PA, EQH-PC) (CIK 0001333986)
Date: May 7, 2018 · CIK: 0001333986 · Accession: 0001193125-18-153700
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File numbers found in text: 333-221521
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CORRESP 1 filename1.htm CORRESP Morgan Stanley & Co. LLC 1585 Broadway New York, New York 10036 J.P. Morgan Securities LLC 383 Madison Avenue New York, New York 10179 Barclays Capital Inc. 745 Seventh Avenue New York, New York 10019 Citigroup Global Markets Inc. 388 Greenwich Street New York, New York 10013 May 7, 2018 U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Dorrie Yale Re: AXA Equitable Holdings, Inc. (the “Company”) Registration Statement on Form S-1 (File No. 333-221521) Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness at 3:00 pm New York City time on May 9, 2018, or as soon thereafter as practicable. Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus. The undersigned advise that the underwriters have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. [Signature Pages Follow] Very truly yours, MORGAN STANLEY & CO. LLC By: /s/ Michael Occi Name: Michael Occi Title: Executive Director J.P. MORGAN SECURITIES LLC By: /s/ Alaoui Zenere Name: Alaoui Zenere Title: Vice President BARCLAYS CAPITAL INC. By: /s/ Victoria Hale Name: Victoria Hale Title: Vice President CITIGROUP GLOBAL MARKETS INC. By: /s/ Aaron Lissner Name: Aaron Lissner Title: Director [AEH—Signature Page to Underwriter Acceleration Request]