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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

AI Filing Summary & Sentiment

File numbers found in text: 333-221521

Date
May 7, 2018
Author
Executive Director
Form
CORRESP
Company
Equitable Holdings, Inc. (EQH, EQH-PA, EQH-PC) (CIK 0001333986)

Letter

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

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

Show Raw Text
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]