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Correspondence 0001193125-22-289774 from Variable Account AA (CIK 0001932768)

Variable Account AA (CIK 0001932768)
Date: Nov. 21, 2022 · CIK: 0001932768 · Accession: 0001193125-22-289774

AI Filing Summary & Sentiment

File numbers found in text: 333-266576

Date
November 21, 2022
Author
Vice President and
Form
CORRESP
Company
Variable Account AA (CIK 0001932768)

Letter

VIA EDGAR United States Securities and Exchange Division of Investment Management Re: Variable Account AA Equitable Financial Life Insurance Company of America Initial Registration Statement on Form N-4 File No. 333-266576

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 202) Prospectus as requested. Please see the revised Statutory Prospectus filed herewith.

We would like to have EQUI-VEST® Strategies (Series 202) effective on or before December 16, 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 (319) 573-2676. Thank you very much for your assistance with this filing.

Best regards,
/s/ Darin Smith

Show Raw Text
CORRESP
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Equitable Financial Life Insurance Company of America EV-202

 Equitable America

Darin Smith

 Vice President and

Associate General Counsel

 (319) 573-2676

 darin.smith@equitable.com

November 21, 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. 333-266576

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 202) Prospectus as requested.
Please see the revised Statutory Prospectus filed herewith.

 We would like to have EQUI-VEST®
Strategies (Series 202) effective on or before December 16, 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 (319) 573-2676. Thank you very much for your assistance with this filing.

Best regards,

 /s/ Darin Smith

     Darin Smith