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SEC Response Letter

 [EQUITABLE AMERICA LOGO]

Darin Smith

 Associate General
Counsel

 (319) 573-2676

April 8, 2025

 VIA EDGAR

Securities and Exchange Commission

 100 F Street, NE

Washington, DC 20549-8629

Re:
 Equitable Financial Life Insurance Company

Post-Effective Amendment No. 1 to Form N-4 Registration Statement

Registration Statement No. 333-283623

CIK # 0002039145

 Dear Mr. Oh:

The purpose of this letter is to provide a response to oral comments you provided with respect to the above-referenced filing. We have made all the revisions
as requested. As we discussed, we use the term “variable product business” in our business disruption risk disclosure in our 10-K and, accordingly, would like to continue to use that same term in the “Business disruption,
cybersecurity, and artificial intelligence (“AI”) technologies risks” section of “Principal risks” in the prospectus.

 I trust
that the revisions address your comments adequately. If you have any questions regarding the revisions, 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

 Income Manager®

 Payout annuity contracts

 Prospectus dated May 1, 2025

 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. This Prospectus supersedes all prior Prospectuses and supplements.

 What is Income
Manager®?

Income Manager® contracts are payout annuity contracts issued by
Equitable Financial Life Insurance Company (the “Company”, “we”, “our” and “us”). They are designed to provide retirement income. We offer two versions of the Income
Manager® payout annuity contract from which you may choose to receive your retirement income. You may choose to receive income payable for a specified
period (“period certain”). Or, you may choose to receive lifetime income payable for at least a specified period (“life annuity with a period certain”). Under the life annuity with a period certain contract, you may choose
whether payments are made on a single life or a joint and survivor life basis. In certain circumstances, the forms of annuity available under your Income
Manager® contract may be limited.

This Prospectus is a disclosure document and describes all of the contract’s material features, benefits, rights and obligations, as well as other information. The
description of the contract’s material provisions in this Prospectus is current as of the date of this Prospectus. If certain material provisions under the contract are changed after the date of this Prospectus in accordance with the contract,
those changes will be described in a supplement to this Prospectus. You should carefully read this Prospectus in conjunction with any applicable supplements. All optional features and benefits described in this Prospectus may not be available at the
time you purchase the contract. We have the right to restrict availability of any optional feature or benefit. We can refuse to accept any application or contribution from you at any time, including after you purchase the contract.

 Types of contracts. We offer the contracts for use as:

•

A nonqualified annuity (“NQ”) for after-tax contributions only.

•

A traditional individual retirement annuity (“IRA”).

•

A GMIB Income Manager® payout annuity issued upon exercise of the guaranteed minimum income benefit under an Accumulator® series contract (“GMIB Income Manager®
contract”). A GMIB Income Manager® contract can be used as an NQ and a traditional IRA, as well as a Roth IRA contract (“Roth IRA”).

 Generally, a contribution of at least $10,000 is required to purchase a
contract.

 Fixed maturity
options. We allocate your contributions to a series of fixed maturity options to provide your income payments during the period certain. Amounts allocated to each fixed maturity
option will receive a fixed rate of interest during the period certain. Interest is earned at a guaranteed rate we set (“rate to maturity”). The fixed maturity options are listed in Appendix: “Investment options available under the
contract”.

 The contract is a complex investment and involves risks, including potential loss of principal if you take a withdrawal
prior to the maturity of a fixed maturity option. The contract is not a short-term investment and is not appropriate for an investor who needs ready access to cash. Withdrawals could result in withdrawal charges, negative market value adjustments,
taxes, and tax penalties and cause you to lose money. You may receive less than the amount of the withdrawal and any associated market value adjustment could significantly reduce the annuity payment perhaps by more than the amount of withdrawal, as
well as shorten the length of the period certain. A market value adjustment will apply to withdrawals, transfers, surrender of your contract, when we make deductions for charges, or payment of a death benefit from a fixed maturity option before
the maturity date. The actual amount of the market value adjustment is determined by a formula that depends on, among other things, the difference between the rate to maturity that applies to the amount being withdrawn and the rate to maturity
in effect at that time for new allocations to that same fixed maturity option, and the length of time remaining until the maturity date. It is theoretically possible that you could lose up to 100% of your investment and previously credited
interest in certain extreme scenarios. You should speak with a financial professional about the features, benefits, risks, and fees and whether the contract is appropriate for you based on your financial situation and objectives.

 All obligations and guarantees are subject to the Company’s financial strength and claims
paying ability.

 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, although we will apply the market value adjustment. 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 (less any withdrawals and/or market value adjustment) or the account value under (which reflects any positive or negative market value adjustments) through the date we receive your contract. You should review this
Prospectus, or consult with your investment professional, for additional information about the specific cancellation terms that apply.

 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 fixed annuities with market value adjustments, has been prepared by the SEC’s staff and is
available at Investor.gov.

 #852421

 Contents of this Prospectus

 Definition of key terms

4

 Overview of the contract

5

 Important information you should consider about the contract

7

 Fee table

9

 The Company

10

 How to reach us

11

1. Principal risks of investing in the contract

12

 Risks associated with the fixed maturity options

12

 Risk associated with taking an early withdrawal

12

 Death benefit risk

12

 Insurance company risk

12

 Possible adverse tax consequences

12

 Contract changes risk

12

 Availability by financial intermediary

13

 Business disruption, cybersecurity, and artificial intelligence (“AI”) technologies
 risks

13

2. Purchasing the contract and contract features

14

 How you can purchase and contribute to your contract

14

 Source of contributions (not applicable to GMIB Income Manager® contract)

14

 Owner and annuitant requirements

14

 What are your investments under the contract?

14

 What are your contract choices?

15

 Life annuity with a period certain contract

16

 Period certain contract (not available if you are purchasing a GMIB Income Manager® contract)

20

3. Other features of the contracts

21

 How you can make your contributions

21

 Your right to cancel within a certain number of days

21

 Surrendering your contract to receive its cash value

22

 When to expect payments

22

4. Charges and adjustments

23

 Withdrawal charges

23

 Amounts applied from other contracts issued by the Company

23

 Charges for state premium and other applicable taxes

23

”Financial professional” means the registered representative who is offering you the contract.

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 usually the contract owner.

 When we use the word “contract“ it also includes certificates that are issued under group contracts in some
states.

 2

 Group or sponsored arrangements

24

 Other distribution arrangements

24

 Market value adjustments

24

5. Benefits available under the contract

25

 Death benefit — for all contracts other than GMIB Income Manager® contracts

25

 Death benefit — for all GMIB Income Manager® contracts

26

 Your beneficiary

26

 Your annuity payout options (not including GMIB Income Manager® contracts)

26

6. Tax information

28

 Overview

28

 Taxation of nonqualified annuities

28

 Special rules for NQ contracts issued in Puerto Rico

30

 Individual retirement arrangements (“IRAs”)

30

 Traditional individual retirement annuities (“traditional
IRAs”)

31

 Tax withholding and information reporting

37

7. More information

38

 About the non-unitized separate account for the fixed maturity options

38

 About our general account

38

 Other methods of payment

38

 About payments under period certain contracts

38

 Dates and prices at which contract events occur

39

 Statutory compliance

39

 About legal proceedings

39

 Financial statements

39

 Transfers of ownership, collateral assignments, loans, and borrowing

39

 Distribution of the contracts

39

Appendix

 Investment options available under the contract

42

  

 3

 Definition of key terms

 Account value — is the sum of your market adjusted amounts in each fixed maturity option plus your amounts held in the separate account to provide for payments off maturity dates.

 Annuitant — is the person who is the measuring life for determining contract benefits. The annuitant is not necessarily the contract owner.

 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 — Your cash value is equal to your account value minus any withdrawal charge.

Company — Refers to Equitable Financial Life
Insurance Company (“Equitable Financial”). The terms “we”, “us”, and “our” are also used to identify the Company.

Contract date — The “contract date” is
the effective date of a contract. 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 contract date will be shown in your contract.

 Contract date
anniversary — The end of each 12-month period is your “contract date anniversary”. For example, if

your contract date is May 1st, your contract anniversary date is April 30th.

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

Fixed Maturity Amount — the present value of a
fixed maturity option’s maturity value calculated using the fixed maturity option’s interest rate adjusted for any prior withdrawals and associated market value adjustments.

 Fixed Maturity Options Non-Unitized Separate
Account — Separate Account No. 48 is a non-unitized separate account of Equitable Financial Life Insurance Company established under New York Insurance Law.

 Market Adjusted Amount — the present value of a fixed maturity option’s maturity value calculated using the current interest rate in effect on the date of the calculation adjusted for any prior withdrawals and
associated market value adjustments.

Maturity date — The contact’s
“maturity date” is generally the contract date anniversary that follows the annuitant’s 95th birthday.

Maturity Value — the total amount allocated to a
fixed maturity option accumulated daily at the fixed maturity option’s interest rate adjusted for any prior withdrawals and associated market value adjustments.

SEC — Securities and Exchange Commission.

 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 use different words, they have the same meaning in the Prospectus as in the contract or supplemental materials. Your financial professional can provide further explanation about your contract.

Prospectus

Contract or Supplemental Materials

fixed maturity amount

Guaranteed Period Amount

fixed maturity options

Guarantee Periods
(Guaranteed Interest Rate Options (“GIRO’s”) in supplemental materials)

off maturity date payments

Modal Payment Portion

market adjusted amount

annuity account value

maturity date

Expiration Date

rate to maturity

Guaranteed Rate

 4

 Overview of the contract

 Purpose of the contract

Income Manager® contracts are payout annuity contracts designed to
provide retirement income to investors who want to begin receiving annuity payments immediately but have the option to defer payments in the short run and be able to take withdrawals or surrender their contract even though they are receiving annuity
payments. We offer the contracts for use as a nonqualified annuity (“NQ”) for after-tax contributions only; as a traditional individual retirement annuity (“IRA”); and as a GMIB Income
Manager® payout annuity issued upon exercise of the guaranteed minimum income benefit under an Accumulator® series contract (“GMIB Income Manager® contract”). A GMIB Income Manager® contract can be used as an NQ and a traditional IRA, as well as a Roth IRA contract (“Roth IRA”).

 Income payments under the contract

 We offer two versions of the Income Manager® payout annuity contract from which you may choose to receive your retirement income. You may choose to receive income payable for a specified period (“period certain”). Or, you
may choose to receive lifetime income payable for at least a specified period (“life annuity with a period certain”). Under the life annuity with a period certain contract, you may choose whether payments are made on a single life or a
joint and survivor life basis. For GMIB Income Manager® contracts, a period certain annuity is not available. Please note: the terms “income
payments” and “annuity payments” mean the same thing and we use them in this prospectus interchangeably.

If you purchase a GMIB Income Manager® contract, the period certain is
specified in your Accumulator® contract and cannot be changed. Generally, you will receive at least 10 years of payments. Depending on the
annuitant’s age at GMIB exercise and the issue date and type of your Accumulator® contract, the period may be longer or shorter. For all other
Income Manager® contracts, you will receive payments for periods certain ranging from 7 to 15 years depending on the age of the annuitant. For a life
annuity with period certain, payments will continue while the annuitant or joint annu