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Variable Account AA

 1290 Avenue of the Americas

New York, NY 10104

 Julie Collett

Senior Director and Counsel

Julie.collett@equitable.com

 (303)
902-9135

 November 18, 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:
 Variable Account AA

 Equitable Financial Life Insurance Company of America

 Initial Registration Statement on Form N-4

 File No. 333-266909

Dear Ms. Bentzinger:

 The purpose of this letter is to
provide a response to the supplemental comments you provided with respect to the above-referenced filing for Equitable Financial Life Insurance Company of America (the “Company”).

The Company has made the revisions to the EQUI-VEST® Strategies (Series 902) Prospectus as requested.
Please see the revised Statutory Prospectus and Initial Summary Prospectus filed herewith.

 We would like to have EQUI-VEST® Strategies (Series 902) effective on or before December 19, 2022. We will file a Pre-Effective Amendment that will address any Staff comments to the
prospectus. Also, we will provide any additional exhibits (including contract forms) that might be necessary.

 I trust that the responses provided in this
letter address your comments adequately. If you have any questions regarding these responses, please contact the undersigned at (303) 902-9135. Thank you very much for your assistance with this filing.

Best regards,

 /s/ Julie Collett

Julie Collett

 EQUI-VEST® Strategies
(Series 902)

 A variable and index-linked flexible premium deferred annuity contract

 Prospectus dated December 19, 2022

 Equitable Financial Life Insurance Company of America

Variable Account AA

Please read and keep this prospectus for future reference. It contains important information that you should know before purchasing or taking any other action under
your contract. You should read the prospectuses for each Trust which contain important information about the portfolios.

 What is EQUI-VEST® Strategies?

 EQUI-VEST® Strategies is a variable and index-linked flexible premium deferred annuity contract (“contract”) issued by Equitable Financial Life
Insurance Company of America. Either the plan trustee or the employer will be the EQUI-VEST® Strategies contract holder. Certain rights may be
exercised by employees covered under an employer’s plan (the “participants”). These rights will be summarized in this prospectus and a participation certificate (“certificate”) provided to each participant. EQUI-VEST® Strategies provides for the accumulation of retirement savings and for income. The contract also offers death benefit protection and a number of payout
options.

 This prospectus is a disclosure document and describes all of the
certificate’s material features, benefits, rights and obligations, as well as other information. The description of the certificate’s material provisions in this prospectus is current as of the date of this prospectus. If certain material
provisions under the certificate are changed after the date of this prospectus in accordance with the certificate, those changes will be described in a supplement to this prospectus. You should carefully read this prospectus in conjunction with any
applicable supplements. The certificate should also be read carefully. You have the right to cancel your certificate within a certain number of days after receipt of the certificate.

 Types of
contracts.  We offer the EQUI-VEST® Strategies contract to fund two types of
“plans”: Section 403(b) (also referred to as Tax-sheltered annuity arrangements (“TSA”) plans or contracts) or governmental employer Section 457(b) plans (also referred to as Employee Deferred Compensation
(“EDC”) plans or contracts) (together “plans”). The EQUI-VEST® Strategies contract is available to plans that meet our requirements,
which may include requirements regarding plan vesting provisions. The contract may not be available in all states or for both types of plans.

You invest to accumulate value on a tax-deferred basis in one or more of our variable investment options, our guaranteed interest
option or the Segments of the Structured Investment Option (“SIO”) (collectively, the “investment options”). See Appendix “Portfolio Companies available

under the contract” in the prospectus. The SIO gives you the opportunity to earn interest that we will credit based, in part, on the performance of an external index over a set period of
time, although you could also experience a negative return and a significant loss of principal and previously credited interest. Participants should carefully read the accompanying SIO prospectus.

 Index-linked investment options are complex insurance and investment vehicles and you should
speak with a financial professional about the features, benefits, risks, and fees and whether the SIO is appropriate for you based on your financial situation and objectives.

 We reserve the right to stop accepting any application or contribution from you at any time,
including after you purchase the contract. If we exercise our right to discontinue the acceptance of, and/or place additional limitations on, contributions to the contract, you may no longer be able to fund your guaranteed death benefit(s). This
also means that you may no longer be able to increase your guaranteed death benefits through contributions and transfers.

If you are a new investor in the contract, you may cancel your contract within 10 days of receiving it without paying fees or penalties. In some states, this
cancellation period may be longer. Upon cancellation, you will receive either a full refund of the amount you paid with your application or your account value. You should review this prospectus, or consult with your financial professional, for
additional information about the specific cancellation terms that apply.

 EV Strategies 902 (IF/NB)

#317382

 The Securities and
Exchange Commission (“SEC”) has not approved or disapproved these securities or determined if this prospectus is accurate or complete. Any representation to the contrary is a criminal offense. The contracts are not insured by the FDIC or
any other agency. They are not deposits or other obligations of any bank and are not bank guaranteed. They are subject to investment risks and possible loss of principal. Additional information about certain investment products, including variable
annuities, has been prepared by the SEC’s staff and is available at Investor.gov.

 Contents of this Prospectus

 Definitions of key terms

4

 Important information you should consider about the contract

6

 Overview of the contract

9

 Fee table

10

 The Company

13

 How to reach us

14

1. Purchasing the Contract

17

 How you can contribute to your certificate

17

 How EQUI-VEST® Strategies is available

19

 How contributions can be made

19

 What are your investment options under the contract?

20

 Portfolios of the Trusts

21

 ERISA considerations for employers

23

 Allocating your contributions

23

 Unallocated account

22

 Your right to cancel within a certain number of days

23

2. Benefits available under the contract

24

 Summary of benefits

24

 Death benefits

25

 About Death benefits

25

 Enhanced death benefit

25

 Payment of Death benefit

25

 Your beneficiary and payment of benefit

25

 How death benefit payment is made

26

 Beneficiary continuation option

26

 Other benefits

27

 Automatic transfer options

27

 Rebalancing your account value

27

 Optional Semester Strategies program

28

 When we
address the reader of this prospectus with words such as “you” and “your,” we mean the person who has the right or responsibility that the prospectus is discussing at that point. This is the participant.

When we use the word “contract” we mean the group contract issued to the plan trustee or employer (“contract holder,”). When we use the word
“certificate,” we mean the participation certificate that summarizes the rights of each participant covered under the group contract.

 2

 3. Principal risks
 of investing in the contract

30

 Risks associated with variable investment options

30

 Insurance company risk

30

 Possible fees on access to total account value

30

 Possible adverse tax consequences

30

 Not a short-term investment

30

 Risk of loss

30

 Cybersecurity risks and catastrophic events

30

 COVID-19

31

4. Determining your certificate’s value

32

 Your account value and cash value

32

 Your certificate’s value in the variable investment options

32

 Your certificate’s value in the guaranteed interest option

32

 Insufficient account value

32

 5. Transferring
 your money among investment options

33

 Transferring your account value

33

 Disruptive transfer activity

33

 6. Accessing your
 money

35

 Withdrawing your account value

35

 How withdrawals are taken from your account value

37

 Loans

37

 Termination of participation

38

 When to expect payments

38

 Your annuity payout options

38

 7. Charges and
 expenses

41

 Charges under the contracts

41

 Charges that the Trusts deduct

44

 Variations in charges

44

 8. Tax information

45

 Cares Act

45

 Tax information and ERISA matters

45

 Choosing a contract to fund a retirement arrangement

45

 Special rules for tax-favored retirement plans

45

 Additional “Saver’s Credit” for salary reduction contributions to certain
 plans

46

 Tax-sheltered annuity arrangements
(TSAs)

46

 Distributions from TSAs

48

 Public employee deferred compensation plans (EDC Plans)

52

 ERISA matters

56

 Certain rules applicable to plans designed to comply with Section
404(c) of ERISA

57

 Tax withholding and information reporting

57

 Federal income tax withholding on periodic annuity payments

58

 Federal income tax withholding on non-periodic annuity
 payments (withdrawals) which are not eligible rollover distributions

58

 Mandatory withholding eligible rollover distributions

58

 Impact of taxes to the Company

58

 9. More information

59

 The Separate Account

59

 About the Trusts

59

 About the general account

60

 Dates and prices at which certificate events occur

60

 About your voting rights

60

 Statutory compliance

61

 About legal proceedings

61

 Financial statements

61

 Transfers of ownership, collateral assignments, loans, and borrowing

61

 Funding changes

61

 Distribution of the contracts

61

Appendices

 Portfolio Companies available under the contract

64

 Death benefit example

67

 State contract availability and/or variations of certain features and
benefits

68

 3

 Definitions of key terms

 Account value — Is the total of the values you have allocated to (i) the variable investment options; (ii) the
guaranteed interest option; (iii) the amount of any outstanding loan balances and (iv) Segments in the SIO and Segment Type Holding Accounts in the SIO. For more information about the account value in the SIO, please see the SIO Prospectus. These
amounts are also subject to certain fees and charges discussed in “Charges and expenses” in this prospectus.

Annuitant — Is the person who is the measuring life for determining contract benefits.

 Business day — Our “business day” is generally any day the New York Stock
Exchange (“NYSE”) is open for regular trading and generally ends at 4:00 p.m. Eastern Time (or as of an earlier close of regular trading). If the SEC determines the existence of emergency conditions on any day, and consequently, the NYSE
does not open, then that day is not a business day.

 Cash value — The
contract’s cash value is equal to the account value, less: (i) any applicable withdrawal charges, (ii) the total amount or a pro rata portion of the annual administrative charge and (iii) the amount of any outstanding loan.

 Company — Refers to Equitable Financial Life Insurance Company of America
(“Equitable America”). The terms “we”, “us”, and “our” are also used to identify the issuing Company. Equitable America does not do business or issue contracts in the state of New York.

 Contributions — The employer sponsoring the Plan makes payments to us that we call
“contributions.” We can refuse to accept any application or contribution from you or your employer at any time, including after you purchase the contract.

Guaranteed interest option — The guaranteed interest option is part of our general account and pays interest at guaranteed rates. We assign an interest rate
to each amount allocated to the guaranteed interest option. This rate is guaranteed for a specified period. Therefore, different interest rates may apply to different amounts in the guaranteed interest option.

 Maturity date — The certificate’s “maturity date” is generally the
participation date anniversary that follows the participant’s 95th birthday.

Participation date — The “participation date” is the effective date of the certificate. This usually is the business day we receive the
properly completed and signed application, along with any other required documents, and your initial contribution. Your participation date will be shown in your certificate.

 Participation date anniversary — The end of each 12-month period is your “participation date
anniversary.” For example, if your participation date is May 1st, your participation date anniversary is April 30th.

Participation year — The “participation year” is the 12-month period beginning on your participation date and each 12-month period after that date.

 Separate Account — Variable Account AA is a separate account of Equitable
Financial Life Insurance Company of America under Arizona Insurance Law.

 Structured
Investment Option — The Structured Investment Option or “SIO” permits you to invest in one or more “Segments”, each of which provides performance tied to the performance of an Index, and participate in the performance of
that Index.

 4

 To make this prospectus easier to read, we sometimes use different words than in the contract or supplemental materials.
This is illustrated below. Although we do use different words, they have the same meaning in this prospectus as in the contract or supplemental materials. Your financial professional can provide further explanation about your contract.

Prospectus

Contract or Supplemental Materials

account value

Annuity account value

unit

Accumulation unit

unit value

Accumulation unit value

 5

 Important information you should consider about the contract

FEES AND EXPENSES

Charges for Early Withdrawals

 If you surrender your contract, apply your cash value to a non-life contingent annuity payment
option, or withdraw money from the contract within 10 years following your last contribution, or during the first ten participation years depending on your plan, you will be assessed a withdrawal charge of up to 6% of account value withdrawn or
contributions withdrawn. For example, if you make a withdrawal in the first year, you could pay a withdrawal charge of up to $6,000 on a $100,000 investment.

There is an interim value adjustment for amounts withdrawn from a Segment of the SIO before Segment maturity which could result in up to a 90% loss of the Segment
Investment. See the SIO prospectus for more information.

 For additional information about the
charges for surrenders and early withdrawals see “Withdrawal charge” in “Charges under the contracts” under “Charges and expenses” in the prospectus.

Transaction Charges

 In addition to withdrawal charges, you may also be charged for other transactions (including loans
and for special requests such as wire transfers, express mail, duplicate contracts, preparing checks, or third-party transfers or exchanges).

For additional information about transaction charges see “Charges under the contracts” in “Charges and expenses” later in the prospectus.

Ongoing Fees and Expenses (annual charges)

 The contra