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CORRESP
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 SEC Response Letter

 Darin Smith
 Vice President and Associate General
Counsel (319) 573-2676
 darin.smith@equitable.com
 September 15, 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. 2 on Registration Statement on Form N-4
 File No. 333-283589; CIK 0002039145
 Separate Account No. 49 Post Effective Amendment
No. 8 and Amendment No. 530 on Registration Statement on Form N-4 File Nos. 333-254385 and 811-07659; CIK 0001015570 Structured Capital Strategies PLUS ® 21 Dear Mr. Oh:
 The purpose of this letter is to provide a response to oral comments you provided with respect to the above-referenced filings. As discussed, we have made the
revisions as requested. 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 these filings.

 Best Regards,

 /s/ Darin Smith

 Darin Smith

 Equitable Financial Life Insurance Company of America
 Equitable Financial Life Insurance Company
 Supplement dated September 16, 2025 to the Structured Capital Strategies
PLUS ® 21 prospectus dated May 1, 2025

 This Supplement modifies certain information in the above-referenced prospectus (the “Prospectus”). You should read this Supplement in conjunction with your
Prospectus and retain it for future reference. This Supplement incorporates the Prospectus by reference. Unless otherwise indicated, all other information included in your Prospectus remains unchanged. The terms we use in this Supplement have the
same meaning as in your Prospectus. We will send you another copy of any prospectus or supplement without charge upon request. Please contact the customer service
 center at 877-899-3743.
 The following hereby replaces the second paragraph in “Purchasing the contract — Your right to cancel within a certain number of days” :
 Generally, your refund will equal your contributions under the contract. However,
some states require we refund your account value under the contract on the day we receive written notification of your decision to cancel the contract and will reflect any investment gain or loss in the investment options (less the daily charges we
deduct) through the date we receive your contract. This includes the Segment Interim Value for amounts allocated to existing Segments. The Segment Interim Value calculation may reduce the amount of account value paid upon contract cancellation.
For more information, see “Adjustments with respect to early distributions from Segments” in “Charges, Expenses, and Adjustments” in this prospectus. In addition, in some states, the amount of your refund (either the full
amount of your contributions or the account value), and the length of your “free look” period, depend on whether you purchased the contract as a replacement. Please refer to the Appendix “State contract availability and/or
variations of certain features and benefits”, as well as your contract or supplemental materials or contact us for more information. For any IRA contract returned to us within seven days after you receive it, we are required to refund the full
amount of your contribution. When required by applicable law to return the full amount of your contribution and the refunded amount includes account value in the EQ/Money Market variable investment option, we will return the greater of your
contribution or your contract’s cash value. The following hereby replaces the
corresponding section in “Charges, Expenses, and Adjustments — Charges under the contracts — Withdrawal charge (Series B contracts only) — Disability, terminal illness, or confinement to nursing home” :

 (i)
 An owner (or older joint owner, if applicable) has qualified to receive Social Security disability benefits as certified
by the Social Security Administration ( this waiver only applies for contracts issued in New York, Oregon, and South Carolina, as well as all contracts issued using an application signed before September 22, 2025 ); or
 The following hereby supplements the information in the Appendix
“State contract availability and/or variations of certain features and benefits”:
 The state variations listed in the Prospectus dated May 1, 2025 are applicable for all contracts issued using an application signed before September 22, 2025 and for
contracts issued in California and New York.

 State

 Features and benefits

 Availability or variation

 South Carolina

 See “Your right to cancel within a certain number of days” in ”Purchasing the contract”

 If this is a replacement Contract: This Contract may be returned to us for any reason within 30 days after you receive it by mailing or delivering the Contract to either, us at the Processing
Office, or to the agent through whom it was purchased. We will promptly refund any Contribution received on your behalf, plus or minus any investment gain or loss from the date of Contribution to the date of cancellation.

 Catalog No. 800250

 SCS PLUS 21/New Biz

 #56550