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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
———————————————
FORM 10-Q
QUARTERLY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the quarterly period ended September 30, 2020 2021
or
TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the transition period from              to
Commission File No. 000-20501
————————————————
efl-20210930_g1.jpg
Equitable Financial Life Insurance Company
(Exact name of registrant as specified in its charter)
New York13-5570651
(State or other jurisdiction of incorporation or organization)(I.R.S. Employer Identification No.)

1290 Avenue of the Americas, New York, New York                 10104
(Address of principal executive offices) (Zip Code)

(212) 554-1234
(Registrant’s telephone number, including area code)


Securities registered pursuant to Section 12(b) of the Act: None
Securities registered pursuant to Section 12(g) of the Act: None
Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.    Yes      No  
Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).    Yes      No  
Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company or an “emerging growth company”. See definition of “accelerated filer,” “large accelerated filer,” “smaller reporting company” and “emerging growth company” in Rule 12b-2 of the Exchange Act.
Large accelerated filerAccelerated filerNon-accelerated filerSmaller reporting companyEmerging growth company
If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13 (a) of the Exchange Act. ¨
Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes  No
As of November 3, 2020,4, 2021, 2,000,000 shares of the registrant’s Common Stock , $1.25 par value Common Stock were outstanding, all of which were owned indirectly by Equitable Holdings, Inc.
REDUCED DISCLOSURE FORMAT
Equitable Financial Life Insurance Company meets the conditions set forth in General Instruction (H)(1)(a) and (b) of Form 10-Q and is therefore filing this Form with the reduced disclosure format.
See Notes to Consolidated Financial Statements (Unaudited).

Table of Contents

TABLE OF CONTENTS
 Page
PART I - FINANCIAL INFORMATION
Consolidated Financial Statements
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Quantitative and Qualitative Disclosures About Market Risk
Controls and Procedures
PART II - OTHER INFORMATION
Item 1.Legal Proceedings
Item 1A.Risk Factors
Item 2.Unregistered Sales of Equity Securities and Use of Proceeds
Item 3.Defaults Upon Senior Securities
Item 4.Mine Safety Disclosures
Item 5.Other Information
Item 6.Exhibits


Table of Contents

NOTE REGARDING FORWARD-LOOKING STATEMENTS AND INFORMATION
Certain of the statements included or incorporated by reference in this Quarterly Report on Form 10-Q constitute forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Words such as “expects,” “believes,” “anticipates,” “intends,” “seeks,” “aims,” “plans,” “assumes,” “estimates,” “projects,” “should,” “would,” “could,” “may,” “will,” “shall” or variations of such words are generally part of forward-looking statements. Forward-looking statements are made based on management’s current expectations and beliefs concerning future developments and their potential effects upon Equitable Financial Life Insurance Company (“Equitable Financial”) and its consolidated subsidiaries. “We,” “us” and “our” refer to Equitable Financial and its consolidated subsidiaries, unless the context refers only to Equitable Financial as a corporate entity. There can be no assurance that future developments affecting Equitable Financial will be those anticipated by management. Forward-looking statements include, without limitation, all matters that are not historical facts.
These forward-looking statements are not a guarantee of future performance and involve risks and uncertainties, and there are certain important factors that could cause actual results to differ, possibly materially, from expectations or estimates reflected in such forward-looking statements, including, among others: (i) conditions in the financial markets and economy, including the impact of COVID-19 and related economic conditions, equity market declines and volatility, interest rate fluctuations and changes in liquidity and, access to and cost of capital and the impact of COVID-19 and related economic conditions;capital; (ii) operational factors, remediation of our material weakness, indebtedness, protection of confidential customer information or proprietary business information, information systems failing or being compromised,operational failures, our separation and rebranding, strong industry competitionservice providers, and catastrophic events, such as the outbreak of pandemic diseases including COVID-19; (iii) credit, counterparties and investments, including counterparty default on derivative contracts, failure of financial institutions, defaults errors or omissions by third parties and affiliates and gross unrealized losses on fixed maturityeconomic downturns, defaults and equity securities;other events adversely affecting our investments; (iv) our reinsurance and hedging programs; (v) our products, structure and product distribution, including variable annuity guaranteed benefits features within certain of our products, complex regulation and administration of our products, variations in statutory capital requirements, financial strength and claims-paying ratings and key product distribution relationships; (vi) estimates, assumptions and valuations, including risk management policies and procedures, potential inadequacy of reserves actual mortality, longevity, morbidity and lapse experience differing from pricing expectations or reserves, amortization of Deferred Policy Acquisition Costs (“DAC”)deferred acquisition costs and financial models; and (vii) legal and regulatory risks, including federal and state legislation affecting financial institutions, insurance regulation and tax reform.
Forward-looking statements should be read in conjunction with the other cautionary statements, risks, uncertainties and other factors identified in Equitable Financial’s Annual Report on Form 10-K for the year ended December 31, 2019,2020, as amended or supplemented in our subsequently filed Quarterly Reports on Form 10-Q, including in the section entitled “Risk Factors,” and elsewhere in this Quarterly Report on Form 10-Q. You should read this Form 10-Q completely and with the understanding that actual future results may be materially different from expectations. Further, any forward-looking statement speaks only as of the date on which it is made, and we undertake no obligation to update or revise any forward-looking statement to reflect events or circumstances after the date on which the statement is made or to reflect the occurrence of unanticipated events, except as otherwise may be required by law.
Other risks, uncertainties and factors, including those discussed under “Risk Factors”, in our Annual Report on Form 10-K could cause our actual results to differ materially from those projected in any forward-looking statements we make. Readers should read carefully the factors described in “Risk Factors” in our Annual Report on Form 10-K to better understand the risks and uncertainties inherent in our business and underlying any forward-looking statements.
Throughout this Quarterly Report on Form 10-Q we use certain defined terms and abbreviations, which are summarized in the “Glossary” and “Acronyms” sections.
3

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Part I FINANCIAL INFORMATION
Item 1.Consolidated Financial Statements

Table of Contents

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Consolidated Balance Sheets
September 30, 20202021 (Unaudited) and December 31, 20192020
September 30, 2020December 31, 2019
(in millions, except share data)
ASSETS
Investments:
Fixed maturities available-for-sale, at fair value (amortized cost of $66,277 and $59,278) (allowance for credit losses of $13 at September 30, 2020)$74,814 $62,362 
Mortgage loans on real estate (net of allowance for credit losses of $70 at September 30, 2020)12,785 12,090 
Policy loans3,647 3,270 
Other equity investments (1)1,260 1,149 
Trading securities, at fair value5,787 6,598 
Other invested assets1,523 2,156 
Total investments99,816 87,625 
Cash and cash equivalents3,962 1,492 
Deferred policy acquisition costs3,735 4,222 
Amounts due from reinsurers (allowance for credit losses of $0 at September 30, 2020)3,032 3,002 
Loans to affiliates1,200 1,200 
GMIB reinsurance contract asset, at fair value3,247 2,466 
Current and deferred income taxes0 249 
Other assets3,854 3,050 
Separate Accounts assets121,099 124,646 
Total Assets$239,945 $227,952 
LIABILITIES
Policyholders’ account balances$59,099 $55,421 
Future policy benefits and other policyholders' liabilities41,117 33,979 
Broker-dealer related payables432 428 
Amounts due to reinsurers112 105 
Current and deferred income taxes1,130 
Other liabilities2,519 1,769 
Separate Accounts liabilities121,099 124,646 
Total Liabilities$225,508 $216,348 
Redeemable noncontrolling interest (2)$38 $39 
Commitments and contingent liabilities (Note 13)

EQUITY
Equity attributable to Equitable Financial:
Common stock, $1.25 par value; 2,000,000 shares authorized, issued and outstanding$2 $
Additional paid-in capital7,831 7,809 
Retained earnings1,634 2,145 
Accumulated other comprehensive income (loss)4,923 1,596 
Total equity attributable to Equitable Financial14,390 11,552 
Noncontrolling interest9 13 
Total Equity14,399 11,565 
Total Liabilities, Redeemable Noncontrolling Interest and Equity$239,945 $227,952 

September 30, 2021December 31, 2020
(in millions, except share data)
ASSETS
Investments:
Fixed maturities available-for-sale, at fair value (amortized cost of $67,332 and $68,136) (allowance for credit losses of $27 and $13)$71,708 $76,353 
Mortgage loans on real estate (net of allowance for credit losses of $64 and $81)13,431 13,142 
Policy loans3,541 3,635 
Other equity investments (1)2,733 1,342 
Trading securities, at fair value409 5,340 
Other invested assets2,339 2,383 
Total investments94,161 102,195 
Cash and cash equivalents1,307 2,043 
Deferred policy acquisition costs4,099 3,816 
Amounts due from reinsurers (allowance for credit losses of $— and $5 ) (fair value of $5,869 and $—) (3)13,388 3,053 
Loans to affiliates1,900 900 
GMIB reinsurance contract asset, at fair value2,156 2,859 
Current and deferred income taxes886 — 
Other assets3,601 3,078 
Separate Accounts assets138,942 133,350 
Total Assets$260,440 $251,294 
LIABILITIES
Policyholders’ account balances$72,055 $63,109 
Future policy benefits and other policyholders' liabilities37,416 40,151 
Broker-dealer related payables641 1,064 
Amounts due to reinsurers211 122 
Current and deferred income taxes 234 
Other liabilities2,510 1,580 
Separate Accounts liabilities138,942 133,350 
Total Liabilities$251,775 $239,610 
Redeemable noncontrolling interest (2)$25 $41 
Commitments and contingent liabilities (Note 13)00
EQUITY
Equity attributable to Equitable Financial:
Common stock, $1.25 par value; 2,000,000 shares authorized, issued and outstanding$2 $
Additional paid-in capital8,539 7,841 
Retained earnings(2,187)(795)
Accumulated other comprehensive income (loss)2,286 4,595 
Total Equity8,640 11,643 
Total Liabilities, Redeemable Noncontrolling Interest and Equity$260,440 $251,294 
______________
(1)See Note 2 for details of balances with variable interest entities.VIEs.
(2)See Note 12 for details of Redeemableredeemable noncontrolling interest.
(3)Represents the fair value of the ceded reserves to Venerable. See Note 1- Organization for details of the Venerable transaction and Note 8- Fair Value Disclosures.
See Notes to Consolidated Financial Statements (Unaudited).
45

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Consolidated Statements of Income (Loss)
For the Three and Nine Months Ended September 30, 2021 and 2020 and 2019 (Unaudited)

Three Months Ended September 30,Nine Months Ended September 30,Three Months Ended September 30,Nine Months Ended September 30,
20202019202020192021202020212020
(in millions)(in millions)
REVENUESREVENUESREVENUES
Policy charges and fee incomePolicy charges and fee income$853 $899 $2,582 $2,619 Policy charges and fee income$811 $853 $2,581 $2,582 
PremiumsPremiums178 232 613 696 Premiums181 178 574 613 
Net derivative gains (losses)Net derivative gains (losses)(1,527)(343)2,097 (2,080)Net derivative gains (losses)(236)(1,527)(4,152)2,097 
Net investment income (loss)Net investment income (loss)809 744 2,334 2,527 Net investment income (loss)885 809 2,655 2,334 
Investment gains (losses), net:Investment gains (losses), net:Investment gains (losses), net:
Credit losses on AFS debt securities and loans(4)(47)
Credit losses on available-for-sale debt securities and loansCredit losses on available-for-sale debt securities and loans(2)(4)4 (47)
Other investment gains (losses), netOther investment gains (losses), net19 201 262 181 Other investment gains (losses), net166 19 753 262 
Total investment gains (losses), netTotal investment gains (losses), net15 201 215 181 Total investment gains (losses), net164 15 757 215 
Investment management and service feesInvestment management and service fees257 258 744 761 Investment management and service fees228 257 791 744 
Other incomeOther income18 (1)43 39 Other income24 18 65 43 
Total revenuesTotal revenues603 1,990 8,628 4,743 Total revenues2,057 603 3,271 8,628 
BENEFITS AND OTHER DEDUCTIONSBENEFITS AND OTHER DEDUCTIONSBENEFITS AND OTHER DEDUCTIONS
Policyholders’ benefitsPolicyholders’ benefits950 1,642 4,267 3,356 Policyholders’ benefits708 950 2,383 4,267 
Interest credited to policyholders’ account balancesInterest credited to policyholders’ account balances277 296 845 859 Interest credited to policyholders’ account balances285 277 841 845 
Compensation and benefitsCompensation and benefits76 70 210 237 Compensation and benefits111 76 246 210 
CommissionsCommissions153 153 462 462 Commissions140 153 494 462 
Interest expenseInterest expense0 0 Interest expense — 1 — 
Amortization of deferred policy acquisition costsAmortization of deferred policy acquisition costs119 54 1,290 345 Amortization of deferred policy acquisition costs93 119 342 1,290 
Other operating costs and expensesOther operating costs and expenses221 214 653 614 Other operating costs and expenses223 221 847 653 
Total benefits and other deductionsTotal benefits and other deductions1,796 2,429 7,727 5,877 Total benefits and other deductions1,560 1,796 5,154 7,727 
Income (loss) from continuing operations, before income taxesIncome (loss) from continuing operations, before income taxes(1,193)(439)901 (1,134)Income (loss) from continuing operations, before income taxes497 (1,193)(1,883)901 
Income tax (expense) benefitIncome tax (expense) benefit249 175 (181)289 Income tax (expense) benefit(99)249 500 (181)
Net income (loss)Net income (loss)(944)(264)720 (845)Net income (loss)398 (944)(1,383)720 
Less: Net income (loss) attributable to the noncontrolling interestLess: Net income (loss) attributable to the noncontrolling interest2 (1)Less: Net income (loss) attributable to the noncontrolling interest 1 (1)
Net income (loss) attributable to Equitable FinancialNet income (loss) attributable to Equitable Financial$(946)$(264)$721 $(848)Net income (loss) attributable to Equitable Financial$398 $(946)$(1,384)$721 

See Notes to Consolidated Financial Statements (Unaudited).
56


EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Consolidated Statements of Comprehensive Income (Loss)
For the Three and Nine Months Ended September 30, 20202021 and 20192020 (Unaudited)

Three Months Ended September 30,Nine Months Ended September 30,Three Months Ended September 30,Nine Months Ended September 30,
20202019202020192021202020212020
(in millions)(in millions)
COMPREHENSIVE INCOME (LOSS)COMPREHENSIVE INCOME (LOSS)COMPREHENSIVE INCOME (LOSS)
Net income (loss)Net income (loss)$(944)$(264)$720 $(845)Net income (loss)$398 $(944)$(1,383)$720 
Other comprehensive income (loss), net of income taxes:Other comprehensive income (loss), net of income taxes:Other comprehensive income (loss), net of income taxes:
Change in unrealized gains (losses), net of adjustments (1)Change in unrealized gains (losses), net of adjustments (1)247 730 3,327 2,721 Change in unrealized gains (losses), net of adjustments (1)(354)247 (2,309)3,327 
Other comprehensive income (loss), net of income taxesOther comprehensive income (loss), net of income taxes247 730 3,327 2,721 Other comprehensive income (loss), net of income taxes(354)247 (2,309)3,327 
Comprehensive income (loss)Comprehensive income (loss)(697)466 4,047 1,876 Comprehensive income (loss)44 (697)(3,692)4,047 
Less: Comprehensive income (loss) attributable to the noncontrolling interest (2)Less: Comprehensive income (loss) attributable to the noncontrolling interest (2)2 (1)Less: Comprehensive income (loss) attributable to the noncontrolling interest (2) 1 (1)
Comprehensive income (loss) attributable to Equitable FinancialComprehensive income (loss) attributable to Equitable Financial$(699)$466 $4,048 $1,873 Comprehensive income (loss) attributable to Equitable Financial$44 $(699)$(3,693)$4,048 
_____________
(1)See Note 11 for details of Changechange in unrealized gains (losses), net of adjustments.
(2)Amounts for the three and nine months ended September 30, 2019 were reclassified to conform to the current year’s presentation.


See Notes to Consolidated Financial Statements (Unaudited).
67


EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Consolidated Statements of Comprehensive Income (Loss)
For the Three and Nine Months Ended September 30, 2021 and 2020 (Unaudited)




Three Months Ended September 30,
Equitable Financial Equity
Common StockAdditional Paid-in CapitalRetained EarningsAccumulated Other Comprehensive Income (Loss)TotalNon-controlling InterestTotal Equity
(in millions)
July 1, 2021$2 $8,531 $(2,584)$2,640 $8,589 $ $8,589 
Dividend to parent company       
Capital contribution from parent company       
Net income (loss)  398  398  398 
Other comprehensive income (loss)   (354)(354) (354)
Other 8 (1) 7  7 
September 30, 2021$2 $8,539 $(2,187)$2,286 $8,640 $ $8,640 


July 1, 2020$$7,821 $2,580 $4,676 $15,079 $$15,088 
Dividend to parent company— — — — — — — 
Net income (loss)— — (946)— (946)— (946)
Other comprehensive income (loss)— — — 247 247 — 247 
Other— 10 — — 10 — 10 
September 30, 2020$$7,831 $1,634 $4,923 $14,390 $$14,399 
8


EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Consolidated Statements of Equity
For the Three and Nine Months Ended September 30, 20202021 and 20192020 (Unaudited)

Three Months Ended September 30,
Equitable Financial Equity
Common StockAdditional Paid-in CapitalRetained EarningsAccumulated Other Comprehensive Income (Loss)TotalNon-controlling InterestTotal Equity
(in millions)
July 1, 2020$2 $7,821 $2,580 $4,676 $15,079 $9 $15,088 
Dividend to parent company  0  0  0 
Net income (loss)  (946) (946) (946)
Other comprehensive income (loss)   247 247  247 
Other 10   10  10 
September 30, 2020$2 $7,831 $1,634 $4,923 $14,390 $9 $14,399 
July 1, 2019$$7,822 $4,455 $1,490 $13,769 $12 $13,781 
Dividend to parent company— — (1,000)— — — (1,000)
Net income (loss)— — (264)— (264)— (264)
Other comprehensive income (loss)— — — 730 730 — 730 
Other— — — — 
September 30, 2019$$7,829 $3,191 $2,220 $13,242 $12 $13,254 

Nine Months Ended September 30,
Equitable Financial Equity
Common StockAdditional Paid-in CapitalRetained EarningsAccumulated Other Comprehensive Income (Loss)TotalNon-controlling InterestTotal Equity
(in millions)
January 1, 2020$2 $7,809 $2,145 $1,596 $11,552 $13 $11,565 
Dividend to parent company  (1,200) (1,200)0 (1,200)
Cumulative effect of adoption of ASU 2016-13, CECL  (32) (32) (32)
Net income (loss)  721  721 (2)719 
Other comprehensive income (loss)   3,327 3,327  3,327 
Other 22   22 (2)20 
September 30, 2020$2 $7,831 $1,634 $4,923 $14,390 $9 $14,399 
January 1, 2019$$7,807 $5,039 $(501)$12,347 $12 $12,359 
Dividend to parent company— — (1,000)— — — (1,000)
Net income (loss)— — (848)— (848)— (848)
Other comprehensive income (loss)— — — 2,721 2,721 — 2,721 
Other— 22 — — 22 — 22 
September 30, 2019$$7,829 $3,191 $2,220 $13,242 $12 $13,254 
Nine Months Ended September 30,
Equitable Financial Equity
Common StockAdditional Paid-in CapitalRetained EarningsAccumulated Other Comprehensive Income (Loss)TotalNon-controlling InterestTotal Equity
(in millions)
January 1, 2021$2 $7,841 $(795)$4,595 $11,643 $ $11,643 
Dividend to parent company  (7) (7) (7)
Capital contribution from parent company 750   750  750 
Net income (loss)  (1,384) (1,384) (1,384)
Other comprehensive income (loss)   (2,309)(2,309) (2,309)
Other (52)(1) (53) (53)
September 30, 2021$2 $8,539 $(2,187)$2,286 $8,640 $ $8,640 
January 1, 2020$$7,809 $2,145 $1,596 $11,552 $13 $11,565 
Dividend to parent company— — (1,200)— (1,200)— (1,200)
Cumulative effect of adoption of ASU 2016-13, CECL— — (32)— (32)— (32)
Net income (loss)— — 721 — 721 (2)719 
Other comprehensive income (loss)— — — 3,327 3,327 — 3,327 
Other— 22 — — 22 (2)20 
September 30, 2020$$7,831 $1,634 $4,923 $14,390 $$14,399 


See Notes to Consolidated Financial Statements (Unaudited).
79


EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Consolidated Statements of Cash Flows
For the Nine Months Ended September 30, 20202021 and 20192020 (Unaudited)
Nine Months Ended September 30,Nine Months Ended September 30,
2020201920212020
(in millions)(in millions)
Cash flows from operating activities:Cash flows from operating activities:Cash flows from operating activities:
Net income (loss)Net income (loss)$720 $(845)Net income (loss)$(1,383)$720 
Adjustments to reconcile net income (loss) to net cash provided by (used in) operating activities:Adjustments to reconcile net income (loss) to net cash provided by (used in) operating activities:Adjustments to reconcile net income (loss) to net cash provided by (used in) operating activities:
Interest credited to policyholders’ account balancesInterest credited to policyholders’ account balances845 859 Interest credited to policyholders’ account balances841 845 
Policy charges and fee incomePolicy charges and fee income(2,582)(2,619)Policy charges and fee income(2,581)(2,582)
Net derivative (gains) lossesNet derivative (gains) losses(2,097)2,080 Net derivative (gains) losses4,152 (2,097)
Credit losses on AFS debt securities and loansCredit losses on AFS debt securities and loans47 Credit losses on AFS debt securities and loans(4)47 
Investment (gains) losses, netInvestment (gains) losses, net(262)(181)Investment (gains) losses, net(753)(262)
Realized and unrealized (gains) losses on trading securitiesRealized and unrealized (gains) losses on trading securities(98)(421)Realized and unrealized (gains) losses on trading securities49 (98)
Non-cash long-term incentive compensation expenseNon-cash long-term incentive compensation expense21 23 Non-cash long-term incentive compensation expense(23)21 
Amortization and depreciationAmortization and depreciation1,230 271 Amortization and depreciation242 1,230 
Equity (income) loss from limited partnershipsEquity (income) loss from limited partnerships13 (63)Equity (income) loss from limited partnerships(371)13 
Changes in:Changes in:Changes in:
Reinsurance recoverable(202)(127)
Reinsurance recoverable (1)Reinsurance recoverable (1)(824)(202)
Capitalization of deferred policy acquisition costsCapitalization of deferred policy acquisition costs(414)(466)Capitalization of deferred policy acquisition costs(519)(414)
Future policy benefitsFuture policy benefits1,811 1,075 Future policy benefits33 1,811 
Current and deferred income taxesCurrent and deferred income taxes502 (86)Current and deferred income taxes(507)502 
Other, netOther, net(171)(212)Other, net229 (171)
Net cash provided by (used in) operating activitiesNet cash provided by (used in) operating activities$(637)$(712)Net cash provided by (used in) operating activities$(1,419)$(637)
Cash flows from investing activities:Cash flows from investing activities:Cash flows from investing activities:
Proceeds from the sale/maturity/prepayment of:Proceeds from the sale/maturity/prepayment of:Proceeds from the sale/maturity/prepayment of:
Fixed maturities, available-for-saleFixed maturities, available-for-sale$10,002 $9,394 Fixed maturities, available-for-sale$25,629 $10,002 
Mortgage loans on real estateMortgage loans on real estate454 708 Mortgage loans on real estate1,417 454 
Trading account securitiesTrading account securities1,320 8,216 Trading account securities5,010 1,320 
Real estate joint ventures0 
Short-term investmentsShort-term investments1,431 1,916 Short-term investments84 1,431 
OtherOther519 145 Other1,509 519 
Payment for the purchase/origination of:Payment for the purchase/origination of:Payment for the purchase/origination of:
Fixed maturities, available-for-saleFixed maturities, available-for-sale(16,620)(23,834)Fixed maturities, available-for-sale(32,790)(16,620)
Mortgage loans on real estateMortgage loans on real estate(1,208)(913)Mortgage loans on real estate(1,680)(1,208)
Trading account securitiesTrading account securities(403)(923)Trading account securities(142)(403)
Short-term investmentsShort-term investments(1,098)(2,134)Short-term investments(5)(1,098)
OtherOther(678)(305)Other(2,377)(678)
Cash settlements related to derivative instruments, netCash settlements related to derivative instruments, net2,560 191 Cash settlements related to derivative instruments, net(6,522)2,560 
Issuance of loans to affiliatesIssuance of loans to affiliates(1,000)— 
Investment in capitalized software, leasehold improvements and EDP equipmentInvestment in capitalized software, leasehold improvements and EDP equipment(31)(49)Investment in capitalized software, leasehold improvements and EDP equipment(41)(31)
Other, netOther, net(397)Other, net(15)(397)
Net cash provided by (used in) investing activitiesNet cash provided by (used in) investing activities$(4,149)$(7,585)Net cash provided by (used in) investing activities$(10,923)$(4,149)
Cash flows from financing activities:Cash flows from financing activities:
See Notes to Consolidated Financial Statements (Unaudited).




8


See Notes to Consolidated Financial Statements (Unaudited).
10


EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Consolidated Statements of Cash Flows
For the Nine Months Ended September 30, 20202021 and 20192020 (Unaudited)
Nine Months Ended September 30,Nine Months Ended September 30,
2020201920212020
(in millions)(in millions)
Cash flows from financing activities:
Policyholders’ account balances:Policyholders’ account balances:Policyholders’ account balances:
DepositsDeposits$7,542 $9,464 Deposits$12,336 $7,542 
WithdrawalsWithdrawals(3,144)(3,433)Withdrawals(4,647)(3,144)
Transfer (to) from Separate AccountsTransfer (to) from Separate Accounts1,966 1,427 Transfer (to) from Separate Accounts1,569 1,966 
Change in collateralized pledged assetsChange in collateralized pledged assets58 Change in collateralized pledged assets55 58 
Change in collateralized pledged liabilitiesChange in collateralized pledged liabilities1,981 1,898 Change in collateralized pledged liabilities1,492 1,981 
Capital contribution from parent companyCapital contribution from parent company750 — 
Shareholder dividend paidShareholder dividend paid(1,200)(1,000)Shareholder dividend paid(7)(1,200)
Purchase (redemption) of noncontrolling interests of consolidated company-sponsored
investment funds
Purchase (redemption) of noncontrolling interests of consolidated company-sponsored
investment funds
4 14 Purchase (redemption) of noncontrolling interests of consolidated company-sponsored investment funds10 
Repayment of loans from affiliates0 (572)
Increase (decrease) in securities sold under agreement to repurchase0 (573)
Other, netOther, net49 Other, net48 49 
Net cash provided by (used in) financing activitiesNet cash provided by (used in) financing activities$7,256 $7,228 Net cash provided by (used in) financing activities$11,606 $7,256 
Change in cash and cash equivalentsChange in cash and cash equivalents2,470 (1,069)Change in cash and cash equivalents(736)2,470 
Cash and cash equivalents, beginning of yearCash and cash equivalents, beginning of year1,492 2,622 Cash and cash equivalents, beginning of year2,043 1,492 
Cash and cash equivalents, end of yearCash and cash equivalents, end of year$3,962 $1,553 Cash and cash equivalents, end of year$1,307 $3,962 
Non-cash transactions:
Non-cash transactions from investing and financing activities:Non-cash transactions from investing and financing activities:
Right-of-use assets obtained in exchange for lease obligationsRight-of-use assets obtained in exchange for lease obligations$20 $42 Right-of-use assets obtained in exchange for lease obligations$3 $20 
Transfer of assets to reinsurerTransfer of assets to reinsurer$(9,023)$— 
_____________
(1) Amount includes cash paid for Venerable transaction of $494 million (see Note 1 Organization).











See Notes to Consolidated Financial Statements (Unaudited).




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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited)

1)    ORGANIZATION
Equitable Financial Life Insurance Company’s (“Equitable Financial” and, collectivelyFinancial’s (collectively with its consolidated subsidiaries, the “Company”) primary business is providing variable annuity, life insurance and employee benefit products to both individuals and businesses. The Company is an indirect, wholly-owned subsidiary of Equitable Holdings, Inc. (“Holdings”).Holdings. Equitable Financial is a stock life insurance company organized in 1859 under the laws of the State of New York.
The Company’s 2 principal subsidiaries include Equitable Distributors, LLC (“Equitable Distributors”) and Equitable Investment Management Group, LLC (“EIMG”), which both are wholly-owned indirect subsidiaries of Holdings.
On June 1, 2021, Holdings completed its previously announced sale (the “Transaction”) of Corporate Solutions Life Reinsurance Company, an insurance company domiciled in Delaware and wholly owned subsidiary of Holdings (“CSLRC”), to Venerable Insurance and Annuity Company, an insurance company domiciled in Iowa (“VIAC”), pursuant to the Master Transaction Agreement, dated October 27, 2020 (the “Master Transaction Agreement”), among the Company, VIAC and, solely with respect to Article XIV thereof, Venerable Holdings, Inc., a Delaware corporation (“Venerable”). VIAC issued a surplus note in aggregate principal amount of $50 million to Equitable Financial for cash consideration.
Immediately following the closing of the Transaction, CSLRC and Equitable Financial entered into a coinsurance and modified coinsurance agreement (the “Reinsurance Agreement”), pursuant to which Equitable Financial ceded to CSLRC, on a combined coinsurance and modified coinsurance basis, legacy variable annuity policies sold by Equitable Financial between 2006-2008 (the “Block”), comprised of non-New York “Accumulator” policies containing fixed rate Guaranteed Minimum Income Benefit and/or Guaranteed Minimum Death Benefit guarantees. At the closing of the Transaction, CSLRC deposited assets supporting the general account liabilities relating to the Block into a trust account for the benefit of Equitable Financial, which assets will secure its obligations to Equitable Financial under the Reinsurance Agreement. The Company transferred assets of $9.5 billion, including primarily available for sale securities and cash, to a collateral trust account as the consideration for the reinsurance transaction. In addition, the Company recorded $9.6 billion of direct insurance liabilities ceded under the reinsurance contract, of which $5.3 billion is accounted at fair value, as the reinsurance of GMxB with no lapse guarantee riders are embedded derivatives. Additionally, $16.9 billion of Separate Account liabilities were ceded under a modified coinsurance portion of the agreement.
In addition, upon the completion of the Transaction, EIMG, a wholly owned subsidiary of the Company, acquired an approximate 9.09% equity interest in Venerable’s parent holding company, VA Capital Company LLC. In connection with such investment, EIMG designated a member to the Board of Managers of VA Capital Company LLC.

On June 22, 2021, Holdings completed the formation of Equitable Investment Management, LLC, (“EIM”). Both Equitable Distributors, a wholly owned indirect subsidiary of Holdings. Effective August 1, 2021, following the formation of EIM, EIMG terminated, and EIM, are wholly-owned Delaware limited liability companies.entered into certain administrative agreements with separate accounts held by the Company. In addition, on October 1, 2021, the Company entered into an investment advisory and management agreement in which EIM will become the investment manager for the Company’s general account portfolio.

2)    SIGNIFICANT ACCOUNTING POLICIES
Basis of Presentation and Principles of Consolidation
The unaudited interim consolidated financial statements (the “consolidated financial statements”) have been prepared in conformity with accounting principles generally accepted in the United States of America (“U.S. GAAP” or “GAAP”) on a basis consistent with reporting interim financial information in accordance with instructions to the Form 10-Q and Article 10 of Regulation S-X of the Securities and Exchange Commission (“SEC”).
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In the opinion of management, all adjustments necessary for a fair statement of the financial position and results of operations have been made. All such adjustments are of a normal, recurring nature, with the exception of the Company’s update of its interest rate assumption and adoption of new economic scenario generator as further described below in Assumption Updates and Model Changes. Interim results are not necessarily indicative of the results that may be expected for the full year. These financial statements should be read in conjunction with the Company’s consolidated financial statements included in the Company’s Annual Report on Form 10-K for the year ended December 31, 2019.2020.
The accompanying unaudited consolidated financial statements present the consolidated results of operations, financial condition and cash flows of the Company and its subsidiaries and those investment companies, partnerships and joint ventures in which the Company has control and a majority economic interest as well as those variable interest entities (“VIEs”) that meet the requirements for consolidation.
All significant intercompany transactions and balances have been eliminated in consolidation. The terms “third quarter 2020”2021” and “third quarter 2019”2020” refer to the three months ended September 30, 20202021 and 2019,2020, respectively. The terms “first nine months of 2020”2021” and “first nine months of 2019”2020” refer to the nine months ended September 30, 20202021 and 2019,2020, respectively.
Certain prior year amounts have been reclassified to conform to the current year’s presentation.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Adoption of New Accounting Pronouncements
DescriptionEffect on the Financial Statement or Other Significant Matters
ASU 2016-13: Financial Instruments—Credit Losses2019-12: Income Taxes (Topic 326), as clarified and amended by ASU 2018-19: Codification Improvements to Topic 326, Financial Instruments—Credit Losses, ASU 2019-04: Codification Improvements to Topic 326, Financial Instruments—Credit Losses, Topic 815, Derivatives and Hedging, and Topic 825, Financial Instruments and ASU 2019-05: Financial Instruments—Credit Losses (Topic 326) Targeted Transition Relief, ASU 2019-11: Codification Improvements to Topic 326, Financial Instruments-Credit Losses740): Simplifying the Accounting for Income Taxes
This ASU 2016-13 contains new guidance which introduces an approach based on expected lossessimplifies the accounting for income taxes by removing certain exceptions to estimate credit losses on certain types of financial instruments. It also modifies the impairment model for available-for-sale debt securitiesgeneral principles in Topic 740, as well as clarifying and provides for a simplified accounting model for purchased financial assets with credit deterioration since their origination.

ASU 2019-05 provides entities that have instruments within the scope of Subtopic 326-20 an option to irrevocably elect the fair value option on an instrument-by-instrument basis upon adoption of Topic 326.

ASU 2018-19, ASU 2019-04 and ASU 2019-11 clarified the codification guidance and did not materially change the standard.
amending existing guidance.
On January 1, 2020,2021, the Company adopted the new standardaccounting standards update. The new guidance is applied either on a retrospective, modified retrospective or prospective basis based on the items to which the amendments relate. The adoption did not have a material impact on the Company’s consolidated financial position, results of operations and completed implementation of its updated current expected credit losses (“CECL”) models, processes and controls related to the identified financial assets that fall within the scopecash flows as of the new standard. Upon adoption the Company recorded a cumulative effect adjustment to reduce the opening retained earnings balance by approximately $40 million, on a pre-tax and pre-DAC basis. The adjustment is primarily attributable to an increase in the allowance for credit losses associated with the Company’s commercial and agricultural mortgage loan portfolios and reinsurance.

Results for reporting periods beginning after January 1, 2020 are presented under ASU 2016-13 while prior period amounts continue to be reported in accordance with previously applicable GAAP.
date.
ASU 2018-13: Fair Value Measurement (Topic 820)
This ASU improves the effectiveness of fair value disclosures in the notes to financial statements. Amendments in this ASU impact the disclosure requirements in Topic 820, including the removal, modification and addition to existing disclosure requirements.The Company elected to early adopt during 2019 the removal of disclosures relating to transfers between Level 1 and Level 2 of the fair value hierarchy, the policy for timing of transfers between levels and valuation processes for Level 3 fair value measurements. The Company adopted the additional disclosures related to Level 3 fair value information on January 1, 2020.
ASU 2018-17: Consolidation (Topic 810): Targeted Improvements to Related Party Guidance for Variable Interest Entities
This ASU provides guidance requiring that indirect interests held through related parties in common control arrangements be considered on a proportional basis for determining whether fees paid to decision makers and service providers are variable interests.The Company adopted this new standard effective for January 1, 2020. Adoption of this standard did not materially impact the Company’s financial position or results of operations.

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Future Adoption of New Accounting Pronouncements
DescriptionEffective Date and Method of AdoptionEffect on the Financial Statement or Other Significant Matters
ASU 2018-12:2018-12: Financial Services - Insurance (Topic 944); ASU 2019-09:2020-11: Financial Services - Insurance (Topic 944): Effective Date
and Early Application
This ASU provides targeted improvements to existing recognition, measurement, presentation, and disclosure requirements for long-duration contracts issued by an insurance entity. The ASU primarily impacts four key areas, including:

1. Measurement of the liability for future policy benefits for traditional and limited payment contracts. The ASU requires companies to review, and if necessary, update, cash flow assumptions at least annually for non-participating traditional and limited-payment insurance contracts. Interest rates used to discount the liability will need to be updated quarterly using an upper medium grade (low credit risk) fixed-income instrument yield.
In November 2019,2020, the FASB issued ASU 2019-09 was issued2020-11 which modifieddeferred the effective date of the amendments in ASU 2018-12 to befor all insurance entities. ASU 2018-12 is effective for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2021.2022. Early adoption is permitted. On September 30, 2020, the FASB tentatively affirmed its decision to defer the effective date of the amendments in ASU 2018-12, for all insurance entities by one year. Early adoption would still be allowed.

For the liability for future policyholder benefits for traditional and limited payment contracts, companies can elect one of two adoption methods. Companies can either elect a modified retrospective transition method applied to contracts in force as of the beginning of the earliest period presented on the basis of their existing carrying amounts, adjusted for the removal of any related amounts in Accumulated other comprehensive income (“AOCI”) or a full retrospective transition method using actual historical experience information as of contract inception. The same adoption method must be used for deferred policy acquisition costs.
The Company is currently evaluating the impact that adoption of this guidance will have on the Company’s consolidated financial statements, however the adoption of the ASU is expected to have a significant impact on the Company’s consolidated financial condition, results of operations, cash flows and required disclosures, as well as processes and controls.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
DescriptionEffective Date and Method of AdoptionEffect on the Financial Statement or Other Significant Matters
2. Measurement of market risk benefits (“MRBs”). MRBs, as defined under the ASU, will encompass certain variable annuity guaranteed benefit (“GMxB”) features associated with variable annuity products and other general account annuities with other than nominal market risk. The ASU requires MRBs to be measured at fair value with changes in value attributable to changes in instrument-specific credit risk recognized in Other comprehensive income (“OCI”).

3. Amortization of deferred acquisition costs. The ASU simplifies the amortization of deferred acquisition costs and other balances amortized in proportion to premiums, gross profits, or gross margins, requiring such balances to be amortized on a constant level basis over the expected term of the contracts. Deferred costs will be required to be written off for unexpected contract terminations but will not be subject to impairment testing.

4. Expanded footnote disclosures. The ASU requires additional disclosures including disaggregated roll-forwards of beginning to ending balances of the liability for future policy benefits, policyholder account balances, MRBs, separate account liabilities and deferred acquisition costs. Companies will also be required to disclose information about significant inputs, judgements, assumptions and methods used in measurement.
For MRBs, the ASU should be applied retrospectively as of the beginning of the earliest period presented.


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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
ASU 2019-12: Income Taxes (Topic 740): SimplifyingDescription
Effective Date and Method of AdoptionEffect on the Accounting for Income TaxesFinancial Statement or Other Significant Matters
This ASU simplifies the accounting for income taxes by removing certain exceptions to the general principles in Topic 740, as well as clarifying and amending existing guidance.Effective for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2020. Early adoption is permitted.The Company is currently evaluating the impact adopting the guidance will have on the Company’s consolidated financial statements, however the adoption is not expected to materially impact the Company’s financial position, results of operation, or cash flows.
ASU2020-04: Reference Rate Reform (Topic 848): Facilitation of the Effects of Reference Rate Reform on Financial Reporting
The amendments in this ASU provide optional expedients and exceptions to contracts, hedging relationships, and other transactions affected by reference rate reform if certain criteria are met.  The amendments in this ASU apply only to contracts, hedging relationships, and other transactions that reference LIBOR or another reference rate expected to be discontinued because of reference rate reform.This ASU is effective as of March 12, 2020 through December 31, 2022.The Company will determineis currently assessing the applicability of the optional expedients and exceptions provided under the ASU as reference rate reform continues to develop.ASU. Management is evaluating the impact that the adoption of this guidance will have on the Company’s consolidated financial statements.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Investments
The carrying values of fixed maturities classified as available-for-sale (“AFS”)AFS are reported at fair value. Changes in fair value are reported in OCI, net of allowance for credit losses, policy related amounts and deferred income taxes. With the adoption of the new Financial Instruments-Credit Losses standard, changesChanges in credit losses are recognized in Investment gains (losses), net. The redeemable preferred stock investments that are reported in fixed maturities include real estate investment trusts (“REIT”),REIT, perpetual preferred stock and redeemable preferred stock. These securities may not have a stated maturity, may not be cumulative and do not provide for mandatory redemption by the issuer. Effective January 1, 2021, the Company began classifying certain preferred stock as equity securities to better reflect the economics and nature of these securities. These preferred stock securities are reported in other equity investments.
The Company determines the fair values of fixed maturities and equity securities based upon quoted prices in active markets, when available, or through the use of alternative approaches when market quotes are not readily accessible or available. These alternative approaches include matrix or model pricing and use of independent pricing services, each supported by reference to principal market trades or other observable market assumptions for similar securities. More specifically, the matrix pricing approach to fair value is a discounted cash flow methodology that incorporates market interest rates commensurate with the credit quality and duration of the investment. The Company’s management, with the assistance of its investment advisors, evaluates AFS debt securities that experienced a decline in fair value below amortized cost for credit losses which are evaluated in accordance with the new financial instruments credit losses guidance effective January 1, 2020.guidance. Integral to this review is an assessment made each quarter, on a security-by-security basis, by the Company’s Investments Under Surveillance (“IUS”)IUS Committee, of various indicators of credit deterioration to determine whether the investment security has experienced a credit loss. This assessment includes, but is not limited to, consideration of the severity of the unrealized loss, failure, if any, of the issuer of the security to make scheduled payments, actions taken by rating agencies, adverse conditions specifically related to the security or sector, and the financial strength, liquidity and continued viability of the issuer.
The Company recognizes an allowance for credit losses on AFS debt securities with a corresponding adjustment to earnings rather than a direct write down that reduces the cost basis of the investment, and credit losses are limited to the amount by which the security’s amortized cost basis exceeds its fair value. Any improvements in estimated credit losses on AFS debt securities are recognized immediately in earnings. Management does not use the length of time a security has been in an unrealized loss position as a factor, either by itself or in combination with other factors, to conclude that a credit loss does not exist, as they were permitted to do prior to January 1, 2020.exist.
When the Company determines that there is more than 50% likelihood that it is not going to recover the principal and interest cash flows related to an AFS debt security, the security is placed on nonaccrual status and the Company reverses accrued interest receivable against interest income. Since the nonaccrual policy results in a timely reversal of accrued interest receivable, the Company does not record an allowance for credit losses on accrued interest receivable.
If there is no intent to sell or likely requirement to dispose of the fixed maturity security before its recovery, only the credit loss component of any resulting allowance is recognized in income (loss) and the remainder of the fair value loss is recognized in OCI. The amount of credit loss is the shortfall of the present value of the cash flows expected to be collected as compared to the amortized cost basis of the security. The present value is calculated by discounting management’s best estimate of projected future cash flows at the effective interest rate implicit in the debt security at the date of acquisition. Projections of future cash flows are based on assumptions regarding probability of default and estimates regarding the amount and timing of recoveries. These assumptions and estimates require use of management judgment and consider internal credit analyses as well as market observable data relevant to the collectability of the
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
security. For mortgage and asset-backed securities, projected future cash flows also include assumptions regarding prepayments and underlying collateral value.
Write-offs of AFS debt securities are recorded when all or a portion of a financial asset is deemed uncollectible. Full or partial write-offs are recorded as reductions to the amortized cost basis of the AFS debt security and deducted from the allowance in the period in which the financial assets are deemed uncollectible. The Company elected to reverse accrued interest deemed uncollectible as a reversal of interest income. In instances where the Company collects cash that it has previously written off, the recovery will be recognized through earnings or as a reduction of the amortized cost basis for interest and principal, respectively.
Real estate held for the production of income is stated at depreciated cost less allowance for credit losses. Depreciation of real estate held for production of income is computed using the straight-line method over the estimated useful lives of the properties, which generally range from 40 to 50 years.
Policy loans represent funds loaned to policyholders up to the cash surrender value of the associated insurance policies and are carried at the unpaid principal balances due to the Company from the policyholders. Interest income on policy loans is recognized in net investment income at the contract interest rate when earned. Policy loans are fully collateralized by the cash surrender value of the associated insurance policies.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Partnerships, investment companies and joint venture interests that the Company has control of and has an economic interest in or those that meet the requirements for consolidation under accounting guidance for consolidation of VIEs are consolidated. Those that the Company does not have control of and does not have a majority economic interest in and those that do not meet the VIE requirements for consolidation are reported on the equity method of accounting and are reported in other equity investments. The Company records its interests in certain of these partnerships on a month or one quarter lag.
Trading securities, which include equity securities and fixed maturities, are carried at fair value based on quoted market prices, with realized and unrealized gains (losses) reported in net investment income (loss) in the consolidated statements of income (loss).
Corporate owned life insurance (“COLI”)COLI has been purchased by the Company and certain subsidiaries on the lives of certain key employees and the Company and these subsidiaries are named as beneficiaries under these policies. COLI is carried at the cash surrender value of the policies. AtAs of September 30, 20202021 and December 31, 2019,2020, the carrying value of COLI was $962 million$1.0 billion and $942$989 million, respectively, and is reported in Otherother invested assets in the consolidated balance sheets.
Cash
Derivatives
Derivatives are financial instruments whose values are derived from interest rates, foreign exchange rates, financial indices, values of securities or commodities, credit spreads, market volatility, expected returns and cash equivalents includes cash on hand, demand deposits, moneyliquidity. Values can also be affected by changes in estimates and assumptions, including those related to counterparty behavior and non-performance risk used in valuation models. Derivative financial instruments generally used by the Company include equity, currency, and interest rate futures, total return and/or other equity swaps, interest rate swaps and floors, swaptions, variance swaps and equity options, all of which may be exchange-traded or contracted in the OTC market. All derivative positions are carried in the consolidated balance sheets at fair value, generally by obtaining quoted market accounts, overnight commercial paper and highly liquid debt instruments purchased with an original maturityprices or through the use of three months or less. Due to the short-term nature of these investments, the recorded value is deemed to approximate fair value.valuation models.
All securities owned, including U.S. government and agency securities, mortgage-backed securities, futures and forwards transactions,Freestanding derivative contracts are reported in the consolidated financial statements on a trade-date basis.
Mortgage Loans on Real Estate
Mortgage loans are stated at unpaid principal balances, net of unamortized discounts and the allowance for credit losses.balance sheets either as assets within “other invested assets” or as liabilities within “other liabilities”. The Company calculatesnets the allowancefair value of all derivative financial instruments with counterparties for credit losses in accordance with the CECL model in order to provide for the risk of credit losseswhich an ISDA Master Agreement and related CSA have been executed. All changes in the lending process.
Expected credit losses for loans with similar risk characteristics are estimated on a collective (i.e., pool) basis in order to meet CECL’s risk of loss concept which requires the Company to consider possibilities of loss, even if remote.
For collectively evaluated mortgages, the Company estimates the allowance for credit losses based on the amortized cost basis of its mortgages over their expected life using a probability of default (“PD”) / loss given default (“LGD”) model. The PD/LGD model incorporates the Company’s reasonable and supportable forecast of macroeconomic information over a specified period. The length of the reasonable and supportable forecast period is reassessed on a quarterly basis and may be adjusted as appropriate over time to be consistent with macroeconomic conditions and the environment as of the reporting date. For periods beyond the reasonable and supportable forecast period, the model reverts to historical loss information. The PD and LGD are estimated at the loan-level based on loans’ current and forecasted risk characteristics as well as macroeconomic forecasts. The PD is estimated using both macroeconomic conditions as well as individual loan risk characteristics including LTV ratios, DSC ratios, seasoning, collateral type, geography, and underlying credit. The LGD is driven primarily by the type and value of collateral, and secondarily by expected liquidation costs and time to recovery.
The CECL model is configured to the Company’s specifications and takes into consideration the detailed risk attributes of each discrete loan in the mortgage portfolio which include, but are not limited to the following:
Loan-to-value (“LTV”) ratio - Derived from current loan balance divided by the fair market value of the property. An LTV ratioCompany’s freestanding derivative positions not designated to hedge accounting relationships, including net receipts and payments, are included in excess“net derivative gains (losses)” without considering changes in the fair value of 100% indicates an underwater mortgage. the economically associated assets or liabilities.
Debt service coverage (“DSC”) ratio - DerivedThe Company has designated certain derivatives it uses to economically manage asset/liability risk in relationships which qualify for hedge accounting. To qualify for hedge accounting, we formally document our designation at inception of the hedge relationship as a cash flow, fair value or net investment hedge. This documentation includes our risk management objective and strategy for undertaking the hedging transaction. The Company identifies how the hedging instrument is expected to offset the designated risks related to the hedged item and the method that will be used to retrospectively and prospectively assess the hedge effectiveness. To qualify for hedge accounting, a hedging instrument must be assessed as being highly effective in offsetting the designated risk of the hedged item. Hedge effectiveness is formally assessed and documented at inception and periodically throughout the life of the hedge accounting relationship.
The Company does not exclude any components of the hedging instrument from actual operating earnings divided by annual debt service. If the ratio is below 1.0x, theneffectiveness assessments and therefor does not separately measure or account for any excluded components of the hedging instrument.
While in cash flow hedge relationships, any periodic net receipts and payments from the hedging instrument are included in the income or expense line that the hedged item’s periodic income or expense is recognized. Other changes in the fair value of the hedging instrument while in a cash flow hedging relationship are reported within OCI. These amounts are deferred in AOCI until they are reclassified to Net income (loss). The reclassified amount offsets the effect of the cash flows on Net income (loss) in the same period when the hedged item affects earnings and on the same line as the hedged item.
We discontinue cash flow hedge accounting prospectively when the Company determines: (1) the hedging instrument is no longer highly effective in offsetting changes in the cash flow from the property does not supporthedged risk, (2) the debt.
Occupancy - Criteria varies by property type but lowhedged item is no longer probable of occurring within two months of their forecast, or below market occupancy(3) the hedging instrument is an indicator of sub-par property performance.
Lease expirations - The percentage of leases expiringotherwise redesignated from the hedging relationship. Changes in the upcoming 12 to 36 months are monitored as a decline in rent and/or occupancy may negatively impact the debt service coverage ratio. In the case of single-tenant properties or properties with large tenant exposure, the lease expiration is a material risk factor.
Other - Any other factors such as maturity, borrower/tenant related issues, payment status, property condition, or current economic conditions may call into question the performancefair value of the loan.derivative after discontinuation of cash flow hedge accounting are accounted for as freestanding derivative positions not designated to hedge accounting relationships unless and until the derivative is redesignated to a hedge accounting relationship. When cash flow hedge accounting is discontinued the amounts deferred in AOCI during the hedge relationship continue to be deferred in
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Mortgage loansAOCI, as long as the hedged items continue to be probable of occurring within two months of their forecast, until the hedged item affects Net income (loss). Any amount deferred in AOCI for hedged items which are no longer probable of occurring within two months of their forecast will be reclassified to “net derivative gains (losses)” at that do not share similar risk characteristics with other loans in the portfolio are individually evaluated quarterly by the Company’s IUS Committee. time.
The allowance for credit losses on these individually evaluated mortgagesCompany is a loan-specific reserve as a resultparty to financial instruments and other contracts that contain “embedded” derivative instruments. At inception, the Company assesses whether the economic characteristics of the loan review process that is recorded based onembedded instrument are “clearly and closely related” to the present value of expected future cash flows discounted at the loan’s effective interest rate or based on the fair valueeconomic characteristics of the collateral. The individually assessed allowance for mortgage loans can increase or decrease from period to period based on such factors.
Individually assessed loans may include, but are not limited to, mortgages that have deteriorated in credit quality such as troubled debt restructurings (“TDR”) and reasonably expected TDRs, mortgages for which foreclosure is probable, and mortgages which have been classified as “potential problem” or “problem” loans within the Company’s IUS Committee processes as described below.
Within the IUS process, Commercial mortgages 60 days or more past due and agricultural mortgages 90 days or more past due, as well as all mortgages in the process of foreclosure, are identified as problem loans. Based on its monthly monitoring of mortgages, a class of potential problem loans are also identified, consisting of mortgage loans not currently classified as problem loans but for which management has doubts as to the abilityremaining component of the borrower to comply“host contract” and whether a separate instrument with the present loan paymentsame terms and which may resultas the embedded instrument would meet the definition of a derivative instrument. Once those criteria are met, the resulting embedded derivative is bifurcated from the host contract, carried in the loan becoming a problem or being modified. The decision whether to classify a performing mortgage loan as a potential problem involves judgments by management as to likely future industry conditions and developments with respect to the borrower or the individual mortgaged property.
Individually assessed mortgage loans without provision for losses are mortgage loans where the fair value of the collateral or the net present value of the expected future cash flows related to the loan equals or exceeds the recorded investment. Interest income earned on mortgage loans where the collateral value is used to measure impairment is recorded on a cash basis. Interest income on mortgage loans where the present value method is used to measure impairment is accrued on the net carrying value amount of the loan at the interest rate used to discount the cash flows.
Mortgage loans are placed on nonaccrual status once management believes the collection of accrued interest is not probable. Once mortgage loans are classified as nonaccrual mortgage loans, interest income is recognized under the cash basis of accounting and the resumption of the interest accrual would commence only after all past due interest has been collected or the mortgage loan has been restructured to where the collection of interest is considered likely. The Company charges off loan balances and accrued interest that are deemed uncollectible.
The components of amortized cost for mortgage loans on the consolidated balance sheets excludes accrued interest amounts becauseat fair value, and changes in its fair value are recognized immediately and captioned in the consolidated statements of income (loss) according to the nature of the related host contract. For certain financial instruments that contain an embedded derivative that otherwise would need to be bifurcated and reported at fair value, the Company presents accrued interest receivables within Other assets. Once mortgage loans are placed on nonaccrual status,instead may elect to carry the entire instrument at fair value.
Reinsurance
For each of its reinsurance agreements, the Company reverses accrued interest receivabledetermines whether the agreement provides indemnification against interest income. Sinceloss or liability relating to insurance risk in accordance with applicable accounting standards. Cessions under reinsurance agreements do not discharge the nonaccrual policy results inCompany’s obligations as the primary insurer. The Company reviews all contractual features, including those that may limit the amount of insurance risk to which the reinsurer is subject or features that delay the timely reversalreimbursement of accrued interest receivable,claims.
For reinsurance of existing in-force blocks of long-duration contracts that transfer significant insurance risk, the Company does not record an allowance for credit losses on accrued interest receivable.
Troubled Debt Restructuring
The Company invests in commercial and agricultural mortgage loans included indifference, if any, between the balance sheet as Mortgage loans on real estate and privately negotiated fixed maturities included in the balance sheet as Fixed maturities AFS. Under certain circumstances, modifications are granted to these contracts. Each modification is evaluated as to whether a troubled debt restructuring has occurred. A modification is a troubled debt restructuring when the borrower is in financial difficultyamounts paid (received), and the creditor makes concessions. Generally,liabilities ceded (assumed) related to the typesunderlying contracts is considered the net cost of concessions may include reducingreinsurance at the face amount or maturity amountinception of the debtreinsurance agreement. The net cost of reinsurance is recorded as originally stated, reducing the contractual interest rate, extending the maturity date at an interest rate lower than current market interest rates and/or reducing accrued interest. The Company considers the amount, timingadjustment and extent of the concession granted in determining any impairment or changes in the specific credit allowance recorded in connection with the troubled debt restructuring. A credit allowance may have been recorded prior to the quarter when the loan is modified in a troubled debt restructuring. Accordingly, the carrying value (net of the allowance) before and after modification through a troubled debt restructuring may not change significantly, or may increase if the expected recovery is higher than the pre-modification recovery assessment.
Net Investment Income (Loss), Investment Gains (Losses), Net, and Unrealized Investment Gains (Losses)
Realized investment gains (losses) are determined by identification with the specific asset and are presentedrecognized as a component of revenue. Changesother expenses on a basis consistent with the expected life of the underlying reinsured contracts. Subsequent amounts paid (received) on the reinsurance of in-force blocks, as well as amounts paid (received) related to new business, are recorded as premiums ceded (assumed); and amounts due from reinsurers (amounts due to reinsurers) are established.
Assets and liabilities relating to reinsurance agreements with the same reinsurer may be recorded net on the balance sheet, if a right of offset exists within the reinsurance agreement. In the event that reinsurers do not meet their obligations to the Company under the terms of the reinsurance agreements, reinsurance recoverable balances could become uncollectible. Reinsurance recoverable balances are stated net of allowances for uncollectible reinsurance.
Premiums, policy charges and fee income, and policyholders’ benefits include amounts assumed under reinsurance agreements and are net of reinsurance ceded. Amounts received from reinsurers for policy administration are reported in other revenues. With respect to GMIBs, a portion of the allowance for credit losses are included in Investment gains (losses), net.
Realized and unrealized holding gains (losses) on trading and equity securities are reflected in Net investment income (loss).
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Unrealized investment gains (losses) on fixed maturities designated as AFS held by the Companydirectly written GMIBs are accounted for as a separate component of AOCI,insurance liabilities, but the associated reinsurance agreements contain embedded derivatives as they are net of related deferred income taxes, assettled. These embedded derivatives are amounts attributable to certain pension operations, Closed Block’s policyholders’ dividend obligation, insurance liability loss recognition, DAC related to UL policies, investment-type products and participating traditional life policies.
Changesincluded in unrealizedGMIB reinsurance contract asset, at fair value with changes in estimated fair value reported in net derivative gains (losses) reflect changes. Separate Account liabilities that have been ceded on a Modified coinsurance (Modco) basis, receivable and payable have been recognized on a net basis as right of setoff exists.
If the Company determines that a reinsurance agreement does not expose the reinsurer to a reasonable possibility of a significant loss from insurance risk, the Company records the agreement using the deposit method of accounting. Deposits received are included in fair valueother liabilities and deposits made are included within other assets. As amounts are paid or received, consistent with the underlying contracts, the deposit assets or liabilities are adjusted. Interest on such deposits is recorded as other income or other operating costs and expenses, as appropriate. Periodically, the Company evaluates the adequacy of onlythe expected payments or recoveries and adjusts the deposit asset or liability through other revenues or other expenses, as appropriate.
For reinsurance contracts other than those fixed maturities classifiedaccounted for as AFSderivatives, reinsurance recoverable balances are calculated using methodologies and do not reflect any change in fair value of policyholders’ account balances and future policy benefits.assumptions that are consistent with those used to calculate the direct liabilities.
Accounting and Consolidation of VIEs
For all new investment products and entities developed by the Company, (other than Collateralized Debt Obligations (“CDOs”)), the Company first determines whether the entity is a VIE, which involves determining an entity’s variability and variable interests, identifying the holders of the equity investment at risk and assessing the five characteristics of a VIE. Once an entity has been determined to be a VIE, the Company then identifiesdetermines whether it is the primary beneficiary of the VIE.VIE based on its beneficial interests. If the Company is deemed to be the primary beneficiary of the VIE, then the Company consolidates the entity.
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Notes to Consolidated Financial Statements (Unaudited), Continued
Management of the Company reviews quarterly its investment management agreements and its investments in, and other financial arrangements with, certain entities that hold client assets under management (“AUM”)AUM to determine the entities that the Company is required to consolidate under this guidance. These entities include certain mutual fund products, hedge funds, structured products, group trusts, collective investment trusts and limited partnerships.
The analysis performed to identify variable interests held, determine whether entities are VIEs or voting interest entities (“VOEs”),VOEs, and evaluate whether the Company has a controlling financial interest in such entities requires the exercise of judgment and is updated on a continuous basis as circumstances change or new entities are developed. The primary beneficiary evaluation generally is performed qualitatively based on all facts and circumstances, including consideration of economic interests in the VIE held directly and indirectly through related parties and entities under common control, as well as quantitatively, as appropriate.
Consolidated VIEs
AtAs of September 30, 20202021 and December 31, 2019,2020, the Company consolidated 1 real estate joint venturelimited partnerships and LLCs for which it was identified as the primary beneficiary under the VIE model. The consolidated entity is jointly owned by Equitable Financial and AXA France and holds an investment in a real estate venture. Included in Other invested assets and Mortgage loans on real estate in the Company’s consolidated balance sheets at September 30, 20202021 and December 31, 20192020 are total assets of $31$133 million and $32and $12 million, respectively related to this VIE, primarily resulting from the consolidated presentation of this real estate joint venture as real estate held for sale. Redeemable noncontrolling interests are presented in mezzanine equity and non-redeemable noncontrolling interests are presented within permanent equity.these VIE.
Non-Consolidated VIEs
AtAs of September 30, 20202021 and December 31, 2019,2020, respectively, the Company held approximately $1.2$2.0 billion and $1.1$1.3 billion of investment assets in the form of equity interests issued by non-corporate legal entities determined under the guidance to be VIEs, such as limited partnerships and limited liability companies, including CLOs, hedge funds, private equity funds and real estate-related funds. Additionally, as of September 30, 2020, Equitable Financial holds $18 million of equity interests in a newly formed Special Purpose Entity (“SPE”) established to purchase loans from the market in anticipation of a Collateralized Loan Obligation (“CLO”) transaction. As an equity investor, the Company is considered to have a variable interest in each of these VIEs as a result of its participation in the risks and/or rewards these funds were designed to create by their defined portfolio objectives and strategies. Primarily through qualitative assessment, including consideration of related party interests or other financial arrangements, if any, the Company was not identified as primary beneficiary of any of these VIEs, largely due to its inability to direct the activities that most significantly impact their economic performance. Consequently, the Company continues to reflect these equity interests in the consolidated balance sheets as Otherother equity investments and applies the equity method of accounting for these positions. The net assets of these non-consolidated VIEs are approximately $156.6$240.7 billion and $160.2$165.8 billion atas of September 30, 20202021 and December 31, 2019,2020, respectively. The Company’s maximum exposure to loss from its direct involvement with these VIEs is the carrying value of its investment of $1.2$2.0 billion and $1.1$1.3 billion and approximately $1.2$1.3 billion and $1.1$1.2 billion of unfunded commitments atas of September 30, 20202021 and December 31, 2019,2020, respectively. The Company has no further economic interest in these VIEs in the form of guarantees, derivatives, credit enhancements or similar instruments and obligations.
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Notes to Consolidated Financial Statements(Unaudited), Continued
In addition, at September 30, 2020 and December 31, 2019, Other invested assets includes real estate held for production of income of $(4) million and $(5) million, respectively, as related to 1 non-consolidated real estate joint venture.
Assumption Updates and Model Changes
The Company conducts its annual review of its assumptions and models during the third quarter of each year. The annual review encompasses assumptions underlying the valuation of unearned revenue liabilities, embedded derivatives for our insurance business, liabilities for future policyholder benefits, DAC and deferred sales inducement (“DSI”)DSI assets.
However, the Company updates its assumptions as needed in the event it becomes aware of economic conditions or events that could require a change in assumptions that it believes may have a significant impact to the carrying value of product liabilities and assets and consequently materially impact its earnings in the period of the change.
Annual Update
The net impact of assumption changes in the third quarter of 2020 decreased Policy charges and fee income by $21 million, increased Policyholders’ benefits by $175 million, increased Interest credited to policyholders’ account balances by $8 million, increased Net derivative gains by $106 million, and increased Amortization of DAC by $26 million. This resulted in a decrease in Income (loss) from operations, before income taxes of $124 million and decreased Net income (loss) by $98 million. Third quarter 2020 assumption updates include a pre-tax gain of $421 million attributable to the removal of the credit risk adjustment from our fair value scenario calibration to better align with U.S. valuation practices, offset by updates to our mortality and policyholder behavior assumptions to reflect emerging experience.
The net impact of assumption changes in the third quarter of 2019 decreased Policy charges and fee income by $11 million, increased Policyholders’ benefits by $886 million, decreased Interest credited to policyholders’ account balances by $14 million, increased Net derivative losses by $548 million and decreased Amortization of DAC by $77 million. This resulted in a decrease in Income (loss) from operations, before income taxes of $1.4 billion and decreased Net income (loss) by $1.1 billion.
First Quarter Update
In the first quarter of 2020, dueDue to the extraordinary economic conditions driven by the COVID-19 pandemic in the first quarter of 2020, the Company updated its interest rate assumption to grade from the current interest rate environment to an ultimate five-year historical average over a 10-year period. As such, the 10-year U.S. Treasury yield grades from the current level to an ultimate 5-year average of 2.25%. The Company determined that no assumption updates were necessary in the second quarter of 2020.
The low interest rate environment and update to the interest rate assumption caused a loss recognition event for the Company’s life interest-sensitive products, as well as to certain run-off business. This loss recognition event caused an acceleration of DAC amortization on the life interest-sensitive products and an increase in the premium deficiency reserve on the run-off business in the first quarter of 2020.
Annual Update
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Notes to Consolidated Financial Statements (Unaudited), Continued
The net impact of assumption changes in the third quarter of 2021 decreased policy charges and fee income by $32 million, decreased policyholders’ benefits by $100 million, decreased net derivative gains by $249 million, and decreased amortization of DAC by $19 million. This resulted in a decrease in income (loss) from operations, before income taxes of $162 million and decreased net income (loss) by $128 million. As part of this annual update, the reference interest rate utilized in our GAAP fair value calculations was updated from the LIBOR swap curve to the US Treasury curve due to the impending cessation of LIBOR and our GAAP fair value liability risk margins were increased, resulting in little impact to overall valuation as our view regarding market participant pricing of our guarantees has not changed at this time.
The net impact of assumption changes in the third quarter of 2020 decreased policy charges and fee income by $21 million, increased policyholders’ benefits by $175 million, increased interest credited to policyholders’ account balances by $8 million, increased net derivative gains by $106 million, and increased amortization of DAC by $26 million. This resulted in a decrease in income (loss) from operations, before income taxes of $124 million and decreased net income (loss) by $98 million.
First Quarter of 2020 Update
The net impact of the economic assumption update in the first quarter of 2020 increased Policypolicy charges and fee income by $54 million, increased Policyholders’policyholders’ benefits by $1.3 billion, decreased Interestinterest credited to policyholders’ account balances by $6 million, and increased Amortizationamortization of DAC by $840 million. This resulted in a decrease in Incomeincome (loss) from continuing operations, before income taxes of $2.1 billion and decreased Netnet income (loss) of $1.7 billion.billion
Model Changes
There were no material model changes in the first nine months of 2021.
In the first quarter of 2020, the Company adopted a new economic scenario generator to calculate the fair value of the GMIB reinsurance contract asset and GMxB derivative features liability, eliminating reliance on AXA Group for scenario production. The new economic scenario generator allows for a tighter calibration of U.S. indices, better reflecting the Company’s actual portfolio. The net impact of the new economic scenario generator resulted in an increase in Incomeincome (loss) from continuing operations, before income taxes of $165 million, and an increase to Net Incomenet income (loss) of $130 million during the first nine months of 2020.

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Revision of Prior Period Financial Statements
The Company identified certain errors in its previously issued financial statements primarily related to the calculation of actuarially determined insurance contract assets and liabilities. The impact of these errors to the current and the prior periods consolidated financial statements were not considered to be material. In order to improve the consistency and comparability of the financial statements, management revised the consolidated financial statements to include the revisions discussed herein. See Note 14 to the Notes to Consolidated Financial Statements for details of the revisions.
3)    INVESTMENTS
Fixed Maturities Available-for-Sale
Accounting for credit impairments of fixed maturities classified as AFS has changed from a direct write-down, or other-than-temporary impairment (“OTTI”) approach to an allowance for credit loss model starting in 2020 upon adoption of CECL (see Note 2, Significant Accounting Policies – Investments).
The components of fair value and amortized cost for fixed maturities classified as AFS on the consolidated balance sheets excludes accrued interest receivable because the Company elected to present accrued interest receivable within Otherother assets. Accrued interest receivable on AFS fixed maturities atas of September 30, 20202021 was $510 $473 million.
There was 0 noaccrued interest written off for AFS fixed maturities for the three and nine months ended September 30, 2020.
Comparative tables as of December 31, 2019 include OTTI, reported net of tax in OCI and in AOCI until realized.2021.
The following tables provide information relating to the Company’s fixed maturities classified as AFS.

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Notes to Consolidated Financial Statements (Unaudited), Continued
AFS Fixed Maturities by Classification
Amortized
Cost
Allowance for Credit Losses (4)Gross
Unrealized
Gains
Gross
Unrealized
Losses
Fair ValueAmortized
Cost
Allowance for Credit LossesGross
Unrealized
Gains
Gross
Unrealized
Losses
Fair Value
(in millions)(in millions)
September 30, 2020:
September 30, 2021September 30, 2021
Fixed Maturities:Fixed Maturities:Fixed Maturities:
Corporate (1)Corporate (1)$47,421 $13 $4,281 $170 $51,519 Corporate (1)$44,856 $27 $2,787 $164 $47,452 
U.S. Treasury, government and agencyU.S. Treasury, government and agency13,126 0 4,158 0 17,284 U.S. Treasury, government and agency13,464  1,642 23 15,083 
States and political subdivisionsStates and political subdivisions706 0 109 0 815 States and political subdivisions504  77 3 578 
Foreign governmentsForeign governments828 0 80 6 902 Foreign governments977  43 17 1,003 
Residential mortgage-backed (2)Residential mortgage-backed (2)132 0 13 0 145 Residential mortgage-backed (2)90  8  98 
Asset-backed (3)Asset-backed (3)2,584 0 25 18 2,591 Asset-backed (3)5,542  28 4 5,566 
Commercial mortgage-backedCommercial mortgage-backed1,067 0 50 0 1,117 Commercial mortgage-backed1,858  28 12 1,874 
Redeemable preferred stock(4)Redeemable preferred stock(4)413 0 31 3 441 Redeemable preferred stock(4)41  13  54 
Total at September 30, 2020$66,277 $13 $8,747 $197 $74,814 
Total at September 30, 2021Total at September 30, 2021$67,332 $27 $4,626 $223 $71,708 
December 31, 2019:
December 31, 2020:December 31, 2020:
Fixed Maturities:Fixed Maturities:Fixed Maturities:
Corporate (1)Corporate (1)$42,347 $$2,178 $61 $44,464 Corporate (1)$48,501 $13 $4,703 $89 $53,102 
U.S. Treasury, government and agencyU.S. Treasury, government and agency14,385 1,151 305 15,231 U.S. Treasury, government and agency12,644 — 3,304 15,943 
States and political subdivisionsStates and political subdivisions584 68 649 States and political subdivisions482 — 92 — 574 
Foreign governmentsForeign governments460 35 490 Foreign governments1,011 — 98 1,103 
Residential mortgage-backed (2)Residential mortgage-backed (2)161 12 173 Residential mortgage-backed (2)119 — 12 — 131 
Asset-backed (3)Asset-backed (3)843 844 Asset-backed (3)3,633 — 28 3,656 
Commercial mortgage-backedCommercial mortgage-backed1,148 — 55 — 1,203 
Redeemable preferred stockRedeemable preferred stock498 18 511 Redeemable preferred stock598 — 46 641 
Total at December 31, 2019$59,278 $$3,465 $381 $62,362 
Total at December 31, 2020Total at December 31, 2020$68,136 $13 $8,338 $108 $76,353 
______________
(1)Corporate fixed maturities include both public and private issues.
(2)Includes publicly traded agency pass-through securities and collateralized obligations.
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Notes to Consolidated Financial Statements(Unaudited), Continued
(3)Includes credit-tranched securities collateralized by sub-prime mortgages, credit risk transfer securities. and other asset types and credit tenant loans.types.
(4)Amounts represent the allowance for credit losses for 2020 - Effective January 1, 2021, certain preferred stock have been reclassified to other equity investments (see Note 2 Significant2-Significant Accounting Policies - Investments).

The contractual maturities of AFS fixed maturities atas of September 30, 20202021 are shown in the table below. Bonds not due at a single maturity date have been included in the table in the final year of maturity. Actual maturities may differ from contractual maturities because borrowers may have the right to call or prepay obligations with or without call or prepayment penalties.
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Notes to Consolidated Financial Statements (Unaudited), Continued
Contractual Maturities of AFS Fixed Maturities
Amortized Cost (Less Allowance for Credit Losses)Fair ValueAmortized Cost (Less Allowance for Credit Losses)Fair Value
(in millions) (in millions)
September 30, 2020:
September 30, 2021:September 30, 2021:
Contractual maturities:Contractual maturities:Contractual maturities:
Due in one year or lessDue in one year or less$4,094 $4,126 Due in one year or less$1,649 $1,660 
Due in years two through fiveDue in years two through five14,862 15,722 Due in years two through five15,999 16,774 
Due in years six through tenDue in years six through ten16,872 18,691 Due in years six through ten15,819 16,848 
Due after ten yearsDue after ten years26,240 31,981 Due after ten years26,307 28,834 
SubtotalSubtotal62,068 70,520 Subtotal59,774 64,116 
Residential mortgage-backedResidential mortgage-backed132 145 Residential mortgage-backed90 98 
Asset-backedAsset-backed2,584 2,591 Asset-backed5,542 5,566 
Commercial mortgage-backedCommercial mortgage-backed1,067 1,117 Commercial mortgage-backed1,858 1,874 
Redeemable preferred stockRedeemable preferred stock413 441 Redeemable preferred stock41 54 
Total at September 30, 2020$66,264 $74,814 
Total at September 30, 2021Total at September 30, 2021$67,305 $71,708 

The following table shows proceeds from sales, gross gains (losses) from sales and credit losses for AFS fixed maturities for the three and nine months ended September 30, 20202021 and 2019:2020:
Proceeds from Sales, Gross Gains (Losses) from Sales and Credit Losses for AFS Fixed Maturities
 Three Months Ended September 30,Nine Months Ended September 30,
 2020201920202019
 (in millions)
Proceeds from sales$1,399 $3,839 $5,985 $6,756 
Gross gains on sales$23 $207 $297 $224 
Gross losses on sales$(5)$(4)$(32)$(25)
Credit losses (1)$0 $$(13)$
______________
 Three Months Ended September 30,Nine Months Ended September 30,
 2021202020212020
 (in millions)
Proceeds from sales$3,575 $1,399 $20,294 $5,985 
Gross gains on sales$172 $23 $1,017 $297 
Gross losses on sales$(6)$(5)$(160)$(32)
Credit losses$(2)$— $(14)$(13)
(1)Commencing with the Company’s adoption of ASU 2016-13 on January 1, 2020, credit losses on AFS debt securities were recognized as an allowance for credit losses. Prior to this, credit losses on AFS fixed maturities were recognized as OTTI.
The following table sets forth the amount of credit loss impairments on AFS fixed maturities held by the Company at the dates indicated and the corresponding changes in such amounts.
AFS Fixed Maturities - Credit Loss Impairments
Three Months Ended September 30,Nine Months Ended September 30,Three Months Ended September 30,Nine Months Ended September 30,
20202019202020192021202020212020
(in millions)(in millions)
Balance, beginning of periodBalance, beginning of period$28 $18 $15 $46 Balance, beginning of period$40 $28 $28 $15 
Previously recognized impairments on securities that matured, paid, prepaid or soldPreviously recognized impairments on securities that matured, paid, prepaid or sold0 (3)0 (31)Previously recognized impairments on securities that matured, paid, prepaid or sold(2)— (3)— 
Recognized impairments on securities impaired to fair value this period (1)Recognized impairments on securities impaired to fair value this period (1)0 0 Recognized impairments on securities impaired to fair value this period (1) —  — 
Credit losses recognized this period on securities for which credit losses were not previously recognizedCredit losses recognized this period on securities for which credit losses were not previously recognized1 (2)9 
Additional credit losses this period on securities previously impairedAdditional credit losses this period on securities previously impaired1 6 
Increases due to passage of time on previously recorded credit lossesIncreases due to passage of time on previously recorded credit losses —  — 
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Notes to Consolidated Financial Statements(Unaudited), Continued
Credit losses recognized this period on securities for which credit losses were not previously recognized(2)7 
Additional credit losses this period on securities previously impaired2 6 
Increases due to passage of time on previously recorded credit losses0 0 
Accretion of previously recognized impairments due to increases in expected cash flows (for OTTI securities 2019 and prior)0 0 
Balance at September 30,$28 $15 $28 $15 
Accretion of previously recognized impairments due to increases in expected cash flows (for OTTI securities 2019 and prior) —  — 
Balance at September 30,$40 $28 $40 $28 
______________
(1)Represents circumstances where the Company determined in the current period that it intends to sell the security, or it is more likely than not that it will be required to sell the security before recovery of the security’s amortized cost.
The tables that follow below present a roll-forward of net unrealized investment gains (losses) recognized in AOCI, split between amounts related to fixed maturities on which a credit loss has been recognized, and all other.AOCI.
Net Unrealized Gains (Losses) on AFS Fixed Maturities
Net Unrealized Gains (Losses) on InvestmentsDAC  Policyholders’ LiabilitiesDeferred Income Tax Asset (Liability)AOCI Gain (Loss) Related to Net Unrealized Investment Gains (Losses) Net Unrealized Gains (Losses) on InvestmentsDAC  Policyholders’ LiabilitiesDeferred Income Tax Asset (Liability)AOCI Gain (Loss) Related to Net Unrealized Investment Gains (Losses) 
(in millions)
Balance, July 1, 2021Balance, July 1, 2021$4,931 $(389)$(1,037)$(736)$2,769 
Net investment gains (losses) arising during the periodNet investment gains (losses) arising during the period(362)   (362)
Reclassification adjustment:Reclassification adjustment: 
Included in Net income (loss)Included in Net income (loss)(165)   (165)
Excluded from Net income (loss)Excluded from Net income (loss)     
OtherOther     
Impact of net unrealized investment gains (losses)Impact of net unrealized investment gains (losses) 28 55 93 176 
Net unrealized investment gains (losses) excluding credit lossesNet unrealized investment gains (losses) excluding credit losses4,404 (361)(982)(643)2,418 
Net unrealized investment gains (losses) with credit lossesNet unrealized investment gains (losses) with credit losses(1)   (1)
Balance, September 30, 2021Balance, September 30, 2021$4,403 $(361)$(982)$(643)$2,417 
(in millions)
Balance, July 1, 2020Balance, July 1, 2020$8,207 $(494)$(1,801)$(1,242)$4,670 Balance, July 1, 2020$8,207 $(494)$(1,801)$(1,242)$4,670 
Net investment gains (losses) arising during the periodNet investment gains (losses) arising during the period345    345 Net investment gains (losses) arising during the period345 — — — 345 
Reclassification adjustment:Reclassification adjustment: Reclassification adjustment:— 
Included in Net income (loss)Included in Net income (loss)(18)   (18)Included in Net income (loss)(18)— — — (18)
Excluded from Net income (loss)Excluded from Net income (loss)0    0 Excluded from Net income (loss)— — — — — 
Impact of net unrealized investment gains (losses)Impact of net unrealized investment gains (losses)0 54 (6)(79)(31)Impact of net unrealized investment gains (losses)— 54 (6)(79)(31)
Net unrealized investment gains (losses) excluding credit lossesNet unrealized investment gains (losses) excluding credit losses8,534 (440)(1,807)(1,321)4,966 Net unrealized investment gains (losses) excluding credit losses8,534 (440)(1,807)(1,321)4,966 
Net unrealized investment gains (losses) with credit lossesNet unrealized investment gains (losses) with credit losses3 0 (1)0 2 Net unrealized investment gains (losses) with credit losses— (1)— 
Balance, September 30, 2020Balance, September 30, 2020$8,537 $(440)$(1,808)$(1,321)$4,968 Balance, September 30, 2020$8,537 $(440)$(1,808)$(1,321)$4,968 
Balance, July 1, 2019$2,622 $(616)$(98)$(420)$1,488 
Net investment gains (losses) arising during the period1,548��— — — 1,548 
Reclassification adjustment:— 
Included in Net income (loss)(201)— — — (201)
Excluded from Net income (loss)— — — 
Impact of net unrealized investment gains (losses)(324)(122)(156)(602)
Net unrealized investment gains (losses) excluding credit losses3,969 (940)(220)(576)2,233 
Net unrealized investment gains (losses) with credit losses (1)
Balance, September 30, 2019$3,970 $(940)$(220)$(576)$2,234 





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Notes to Consolidated Financial Statements(Unaudited), Continued
Net Unrealized Gains (Losses) on InvestmentsDAC  Policyholders’ LiabilitiesDeferred Income Tax Asset (Liability)AOCI Gain (Loss) Related to Net Unrealized Investment Gains (Losses) Net Unrealized Gains (Losses) on InvestmentsDAC  Policyholders’ LiabilitiesDeferred Income Tax Asset (Liability)AOCI Gain (Loss) Related to Net Unrealized Investment Gains (Losses) 
(in millions)
Balance, January 1, 2021Balance, January 1, 2021$8,230 $(466)$(1,814)$(1,250)$4,700 
Net investment gains (losses) arising during the periodNet investment gains (losses) arising during the period(3,057)   (3,057)
Reclassification adjustment:Reclassification adjustment: 
Included in net income (loss)Included in net income (loss)(739)   (739)
Excluded from net income (loss)Excluded from net income (loss)     
Other (1)Other (1)(31)   (31)
Impact of net unrealized investment gains (losses)Impact of net unrealized investment gains (losses) 105 832 607 1,544 
Net unrealized investment gains (losses) excluding credit lossesNet unrealized investment gains (losses) excluding credit losses4,403 (361)(982)(643)2,417 
Net unrealized investment gains (losses) with credit lossesNet unrealized investment gains (losses) with credit losses     
Balance, September 30, 2021Balance, September 30, 2021$4,403 $(361)$(982)$(643)$2,417 
(in millions)
Balance, January 1, 2020Balance, January 1, 2020$3,084 $(826)$(192)$(433)$1,633 Balance, January 1, 2020$3,084 $(826)$(192)$(433)$1,633 
Net investment gains (losses) arising during the periodNet investment gains (losses) arising during the period5,707    5,707 Net investment gains (losses) arising during the period5,707 — — — 5,707 
Reclassification adjustment:Reclassification adjustment: Reclassification adjustment:
Included in Net income (loss)(248)   (248)
Excluded from Net income (loss)0    0 
Included in net income (loss)Included in net income (loss)(248)— — — (248)
Excluded from net income (loss)Excluded from net income (loss)— — — — — 
Impact of net unrealized investment gains (losses)Impact of net unrealized investment gains (losses)0 386 (1,617)(889)(2,120)Impact of net unrealized investment gains (losses)— 386 (1,617)(889)(2,120)
Net unrealized investment gains (losses) excluding credit lossesNet unrealized investment gains (losses) excluding credit losses8,543 (440)(1,809)(1,322)4,972 Net unrealized investment gains (losses) excluding credit losses8,543 (440)(1,809)(1,322)4,972 
Net unrealized investment gains (losses) with credit lossesNet unrealized investment gains (losses) with credit losses(6)0 1 1 (4)Net unrealized investment gains (losses) with credit losses(6)— (4)
Balance, September 30, 2020Balance, September 30, 2020$8,537 $(440)$(1,808)$(1,321)$4,968 Balance, September 30, 2020$8,537 $(440)$(1,808)$(1,321)$4,968 
Balance, January 1, 2019$(577)$37 $(69)$125 $(484)
Net investment gains (losses) arising during the period4,754 — — — 4,754 
Reclassification adjustment:
Included in Net income (loss)(208)— — — (208)
Excluded from Net income (loss)— — — 
Impact of net unrealized investment gains (losses)(977)(151)(701)(1,829)
Net unrealized investment gains (losses) excluding credit losses3,969 (940)(220)(576)2,233 
Net unrealized investment gains (losses) with credit losses (1)
Balance, September 30, 2019$3,970 $(940)$(220)$(576)$2,234 
___________________________
(1)Credit losses for 2019 were OTTI losses. Effective January 1, 2021, certain preferred stock have been reclassified to other equity investments (see Note 2 - Significant Accounting Policies – Investments).
The following tables disclose the fair values and gross unrealized losses of the 7091,299 issues atas of September 30, 20202021 and the 390537 issues atas of December 31, 20192020 that are not deemed to have credit losses, aggregated by investment category and length of time that individual securities have been in a continuous unrealized loss position for the specified periods at the dates indicated:
AFS Fixed Maturities in an Unrealized Loss Position for Which No Allowance Is Recorded
Less Than 12 Months12 Months or LongerTotal Less Than 12 Months12 Months or LongerTotal
Fair ValueGross Unrealized LossesFair ValueGross Unrealized LossesFair ValueGross Unrealized Losses Fair ValueGross Unrealized LossesFair ValueGross Unrealized LossesFair ValueGross Unrealized Losses
(in millions)(in millions)
September 30, 2020:
September 30, 2021September 30, 2021
Fixed Maturities:Fixed Maturities:Fixed Maturities:
CorporateCorporate$4,063 $116 $365 $49 $4,428 $165 Corporate$7,308 $139 $479 $23 $7,787 $162 
U.S. Treasury, government and agencyU.S. Treasury, government and agency1,417 23   1,417 23 
States and political subdivisionsStates and political subdivisions102 2 7 1 109 3 
Foreign governmentsForeign governments88 1 31 5 119 6 Foreign governments380 11 42 6 422 17 
Asset-backedAsset-backed1,324 16 74 2 1,398 18 Asset-backed817 4 20  837 4 
Redeemable preferred stock59 1 11 2 70 3 
Total at September 30, 2020$5,534 $134 $481 $58 $6,015 $192 
December 31, 2019: (1)
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
 Less Than 12 Months12 Months or LongerTotal
 Fair ValueGross Unrealized LossesFair ValueGross Unrealized LossesFair ValueGross Unrealized Losses
(in millions)
Fixed Maturities:
Corporate$2,669 $41 $366 $20 $3,035 $61 
U.S. Treasury, government and agency4,245 305 4,247 305 
States and political subdivisions123 123 
Foreign governments11 47 58 
Asset-backed319 201 520 
Redeemable preferred stock29 49 78 
Total at December 31, 2019$7,396 $349 $665 $32 $8,061 $381 
______________
(1)Amounts represents fixed maturities in an unrealized loss position that are not deemed to be OTTI for 2019.
 Less Than 12 Months12 Months or LongerTotal
 Fair ValueGross Unrealized LossesFair ValueGross Unrealized LossesFair ValueGross Unrealized Losses
(in millions)
Commercial mortgage-backed887 12 2  889 12 
Total at September 30, 2021$10,911 $191 $550 $30 $11,461 $221 
December 31, 2020:
Fixed Maturities:
Corporate$2,773 $52 $332 $32 $3,105 $84 
U.S. Treasury, government and agency881 — — 881 
Foreign governments153 20 173 
Asset-backed809 76 885 
Redeemable preferred stock53 11 64 
Total at December 31, 2020$4,669 $64 $439 $39 $5,108 $103 
The Company’s investments in fixed maturities do not include concentrations of credit risk of any single issuer greater than 10% of the consolidated equity of the Company, other than securities of the U.S. government, U.S. government agencies, and certain securities guaranteed by the U.S. government. The Company maintains a diversified portfolio of corporate securities across industries and issuers and does not have exposure to any single issuer in excess of 0.6% of total corporate securities. The largest exposures to a single issuer of corporate securities held atas of September 30, 20202021 and December 31, 20192020 were $321$292 million and $279$338 million, respectively, representing 2.2%3.4% and 2.4%2.9% of the consolidated equity of the Company.
Corporate high yield securities, consisting primarily of public high yield bonds, are classified as other than investment grade by the various rating agencies, i.e., a rating below Baa3/BBB- or the National Association of Insurance Commissioners (“NAIC”)NAIC designation of 3 (medium investment grade), 4 or 5 (below investment grade) or 6 (in or near default). AtAs of September 30, 20202021 and December 31, 2019,2020, respectively, approximately $2.0$3.0 billion and $1.4$2.4 billion, or 3.0%4.4% and 2.3%3.6%, of the $66.3$67.3 billion and $59.3$68.1 billion aggregate amortized cost of fixed maturities held by the Company were considered to be other than investment grade. These securities had gross unrealized losses of $81$20 million and $21$48 million atas of September 30, 20202021 and December 31, 2019,2020, respectively.
AtAs of September 30, 20202021 and December 31, 2019,2020, respectively, the $58$30 million and $32$39 million of gross unrealized losses of twelve months or more were primarily concentrated in corporate securities, as applicable.securities. In accordance with the policy described in Note 2, the Company concluded that an adjustment to income for OTTI (prior to January 1, 2020) nor an allowance for credit losses (after January 1, 2020) for these securities was not warranted at either September 30, 20202021 or December 31, 2019. At2020. As of September 30, 20202021 and December 31, 2019,2020, the Company did not intend to sell the securities nor will it likely be required to dispose of the securities before the anticipated recovery of their remaining amortized cost basis.
Based on the Company’s evaluation both qualitatively and quantitatively of the drivers of the decline in fair value of fixed maturity securities as of September 30, 2020,2021, the Company determined that the unrealized loss was primarily due to increases in credit spreads and changes in credit ratings due to the impact of the COVID-19 pandemic on financial markets and assessments of fundamental risks.ratings.
Mortgage Loans on Real Estate
Accrued interest receivable on commercial and agricultural mortgage loans atas of September 30, 20202021 was $29$30 million and $32$29 million, respectively. There was 0no accrued interest written off for commercial and agricultural mortgage loans for the three and nine months ended September 30, 2020.2021.
AtAs of September 30, 2020,2021, the Company had 0no loans for which foreclosure was probable included within the individually assessed mortgage loans, and accordingly had 0no associated allowance for credit losses.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Allowance for Credit Losses on Mortgage Loans
The change in the allowance for credit losses for commercial mortgage loans and agricultural mortgage loans during the three and nine months ended September 30, 2021 and 2020 waswere as follows:
Three Months Ended September 30, 2020Nine Months Ended September 30, 2020Three Months Ended September 30,Nine Months Ended September 30,
2021202020212020
(in millions)(in millions)
Allowance for credit losses on mortgage loans (1):
Allowance for credit losses on mortgage loans:Allowance for credit losses on mortgage loans:
Commercial mortgages:Commercial mortgages:Commercial mortgages:
Balance, beginning of periodBalance, beginning of period$62 $33 Balance, beginning of period$59 $62 $77 $33 
Current-period provision for expected credit lossesCurrent-period provision for expected credit losses4 33 Current-period provision for expected credit losses1 (17)33 
Write-offs charged against the allowanceWrite-offs charged against the allowance0 0 Write-offs charged against the allowance —  0
Recoveries of amounts previously written offRecoveries of amounts previously written off0 0 Recoveries of amounts previously written off —  0
Net change in allowanceNet change in allowance4 33 Net change in allowance1 (17)33 
Ending Balance, September 30,$66 $66 
Balance, end of periodBalance, end of period$60 $66 $60 $66 
Agricultural mortgages:Agricultural mortgages:Agricultural mortgages:
Balance, beginning of periodBalance, beginning of period$4 $3 Balance, beginning of period$4 $$4 $
Current-period provision for expected credit lossesCurrent-period provision for expected credit losses0 1 Current-period provision for expected credit losses —  
Write-offs charged against the allowanceWrite-offs charged against the allowance0 0 Write-offs charged against the allowance ���  — 
Recoveries of amounts previously written offRecoveries of amounts previously written off0 0 Recoveries of amounts previously written off —  — 
Net change in allowanceNet change in allowance0 1 Net change in allowance —  
Ending Balance, September 30,$4 $4 
Balance, end of periodBalance, end of period$4 $$4 $
Total allowance for credit lossesTotal allowance for credit losses$70 $70 Total allowance for credit losses$64 $70 $64 $70 
____________
(1)    See Note 2 for discussion of the allowance of credit losses transition balance, which is included in the Balance, beginning of period.
The change in the allowance for credit losses is attributable to:
increases/decreases in the loan balance due to new originations, maturing mortgages, and loan amortization;
changes in credit quality; and
changes in market assumptions primarily related to COVID-19 driven economic changes.
Credit Quality Information
The following tables summarize the Company’s mortgage loans segregated by risk rating exposure atas of September 30, 2021 and December 31, 2020.
LTV Ratios (1)
At September 30, 2020
Amortized Cost Basis by Origination Year
20202019201820172016PriorTotal
(in millions)
Mortgage loans:
Commercial:
0% - 50%$0 $0 $0 $324 $170 $650 $1,144 
50% - 70%935 411 885 760 2,432 1,608 7,031 
70% - 90%90 394 368 115 153 574 1,694 
90% plus0 0 12 5 0 216 233 
Total commercial$1,025 $805 $1,265 $1,204 $2,755 $3,048 $10,102 






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Notes to Consolidated Financial Statements(Unaudited), Continued
At September 30, 2020
Amortized Cost Basis by Origination Year
20202019201820172016PriorTotal
(in millions)
Agricultural:
0% - 50%$181 $137 $168 $161 $232 $679 $1,558 
50% - 70%253 131 172 110 136 372 1,174 
70% - 90%0 0 3 0 0 18 21 
90% plus0 0 0 0 0 0 0 
Total agricultural$434 $268 $343 $271 $368 $1,069 $2,753 
Total mortgage loans:
0% - 50%$181 $137 $168 $485 $402 $1,329 $2,702 
50% - 70%1,188 542 1,057 870 2,568 1,980 8,205 
70% - 90%90 394 371 115 153 592 1,715 
90% plus0 0 12 5 0 216 233 
Total mortgage loans$1,459 $1,073 $1,608 $1,475 $3,123 $4,117 $12,855 
LTV Ratios (1)
September 30, 2021
Amortized Cost Basis by Origination Year
20212020201920182017PriorTotal
(in millions)
Mortgage loans:
Commercial:
0% - 50%$ $1 $ $184 $324 $910 $1,419 
50% - 70%1,286 1,265 390 619 492 2,853 6,905 
70% - 90%97 320 413 451 275 748 2,304 
90% plus   12 5 207 224 
Total commercial$1,383 $1,586 $803 $1,266 $1,096 $4,718 $10,852 
Agricultural:
0% - 50%$113 $215 $130 $131 $133 $774 $1,496 
50% - 70%174 270 105 134 88 359 1,130 
70% - 90%     17 17 
90% plus       
Total agricultural$287 $485 $235 $265 $221 $1,150 $2,643 
Total mortgage loans:
0% - 50%$113 $216 $130 $315 $457 $1,684 $2,915 
50% - 70%1,460 1,535 495 753 580 3,212 8,035 
70% - 90%97 320 413 451 275 765 2,321 
90% plus   12 5 207 224 
Total mortgage loans$1,670 $2,071 $1,038 $1,531 $1,317 $5,868 $13,495 

Debt Service Coverage Ratios (2)
At September 30, 2020
Amortized Cost Basis by Origination Year
20202019201820172016PriorTotal
(in millions)
Mortgage loans:
Commercial:
Greater than 2.0x$749 $492 $772 $268 $2,036 $1,268 $5,585 
1.8x to 2.0x227 77 118 378 184 524 1,508 
1.5x to 1.8x49 138 186 480 437 569 1,859 
1.2x to 1.5x0 56 154 78 97 533 918 
1.0x to 1.2x0 42 35 0 1 82 160 
Less than 1.0x0 0 0 0 0 72 72 
Total commercial$1,025 $805 $1,265 $1,204 $2,755 $3,048 $10,102 
Agricultural
Greater than 2.0x$52 $27 $39 $38 $73 $158 $387 
1.8x to 2.0x33 36 14 15 21 90 209 
1.5x to 1.8x103 38 45 41 52 212 491 
1.2x to 1.5x165 118 146 105 147 327 1,008 
1.0x to 1.2x77 39 91 71 57 265 600 
Less than 1.0x4 10 8 1 18 17 58 
Total agricultural$434 $268 $343 $271 $368 $1,069 $2,753 
Total mortgage loans
Greater than 2.0x$801 $519 $811 $306 $2,109 $1,426 $5,972 
1.8x to 2.0x260 113 132 393 205 614 1,717 
1.5x to 1.8x152 176 231 521 489 781 2,350 
1.2x to 1.5x165 174 300 183 244 860 1,926 
1.0x to 1.2x77 81 126 71 58 347 760 
Less than 1.0x4 10 8 1 18 89 130 
Total mortgage loans$1,459 $1,073 $1,608 $1,475 $3,123 $4,117 $12,855 
_____________
September 30, 2021
Amortized Cost Basis by Origination Year
20212020201920182017PriorTotal
(in millions)
Mortgage loans:
Commercial:
Greater than 2.0x$705 $1,276 $328 $772 $408 $2,194 $5,683 
1.8x to 2.0x132 136 233 93 269 385 1,248 
1.5x to 1.8x183 115 167 223 166 825 1,679 
1.2x to 1.5x64 59 75 54 253 838 1,343 
1.0x to 1.2x299   88  255 642 
Less than 1.0x   36  221 257 
Total commercial$1,383 $1,586 $803 $1,266 $1,096 $4,718 $10,852 
Agricultural:
Greater than 2.0x$37 $66 $25 $16 $33 $217 $394 
1.8x to 2.0x38 37 26 21 14 74 210 
1.5x to 1.8x50 114 29 28 44 198 463 
1.2x to 1.5x122 180 114 117 73 375 981 
1.0x to 1.2x40 84 32 78 56 247 537 
Less than 1.0x 4 9 5 1 39 58 
Total agricultural$287 $485 $235 $265 $221 $1,150 $2,643 
Total mortgage loans:
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
September 30, 2021
Amortized Cost Basis by Origination Year
20212020201920182017PriorTotal
(in millions)
Greater than 2.0x$742 $1,342 $353 $788 $441 $2,411 $6,077 
1.8x to 2.0x170 173 259 114 283 459 1,458 
1.5x to 1.8x233 229 196 251 210 1,023 2,142 
1.2x to 1.5x186 239 189 171 326 1,213 2,324 
1.0x to 1.2x339 84 32 166 56 502 1,179 
Less than 1.0x 4 9 41 1 260 315 
Total mortgage loans$1,670 $2,071 $1,038 $1,531 $1,317 $5,868 $13,495 
_____________
(1)The LTV ratio is derived from current loan balance divided by the fair value of the property. The fair value of the underlying commercial properties is updated annually for each mortgage loan.
(2)The DSC ratio is calculated using the most recently reported operating income results from property operations divided by annual debt service.
LTV Ratios (1)
December 31, 2020
Amortized Cost Basis by Origination Year
20202019201820172016PriorTotal
(in millions)
Mortgage loans:
Commercial:
0% - 50%$— $— $— $324 $170 $505 $999 
50% - 70%1,294 357 803 656 2,190 1,697 6,997 
70% - 90%321 457 452 219 203 538 2,190 
90% plus— — 12 — 288 305 
Total commercial$1,615 $814 $1,267 $1,204 $2,563 $3,028 $10,491 
Agricultural:
0% - 50%$218 $135 $169 $157 $236 $652 $1,567 
50% - 70%277 129 161 102 124 351 1,144 
70% - 90%— — — — 18 21 
90% plus— — — — — — — 
Total agricultural$495 $264 $333 $259 $360 $1,021 $2,732 
Total mortgage loans:
0% - 50%$218 $135 $169 $481 $406 $1,157 $2,566 
50% - 70%1,571 486 964 758 2,314 2,048 8,141 
70% - 90%321 457 455 219 203 556 2,211 
90% plus— — 12 — 288 305 
Total mortgage loans$2,110 $1,078 $1,600 $1,463 $2,923 $4,049 $13,223 











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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Debt Service Coverage Ratios (2)
December 31, 2020
Amortized Cost Basis by Origination Year
20202019201820172016PriorTotal
(in millions)
Mortgage loans:
Commercial:
Greater than 2.0x$1,230 $492 $772 $268 $1,942 $1,230 $5,934 
1.8x to 2.0x227 83 118 378 184 329 1,319 
1.5x to 1.8x98 138 187 479 437 616 1,955 
1.2x to 1.5x60 57 154 79 — 658 1,008 
1.0x to 1.2x— 44 — — — 123 167 
Less than 1.0x— — 36 — — 72 108 
Total commercial$1,615 $814 $1,267 $1,204 $2,563 $3,028 $10,491 
Agricultural:
Greater than 2.0x$67 $26 $36 $38 $71 $167 $405 
1.8x to 2.0x38 35 14 15 20 82 204 
1.5x to 1.8x117 38 41 45 52 209 502 
1.2x to 1.5x183 120 141 90 142 313 989 
1.0x to 1.2x86 35 93 70 57 233 574 
Less than 1.0x10 18 17 58 
Total agricultural$495 $264 $333 $259 $360 $1,021 $2,732 
Total mortgage loans:
Greater than 2.0x$1,297 $518 $808 $306 $2,013 $1,397 $6,339 
1.8x to 2.0x265 118 132 393 204 411 1,523 
1.5x to 1.8x215 176 228 524 489 825 2,457 
1.2x to 1.5x243 177 295 169 142 971 1,997 
1.0x to 1.2x86 79 93 70 57 356 741 
Less than 1.0x10 44 18 89 166 
Total mortgage loans$2,110 $1,078 $1,600 $1,463 $2,923 $4,049 $13,223 
_____________
(1)The LTV ratio is derived from current loan balance divided by the fair value of the property. The fair value of the underlying commercial properties is updated annually for each mortgage loan.
(2)The DSC ratio is calculated using the most recently reported operating income results from property operations divided by annual debt service.
The following tables provide information relating to the LTV and DSC ratios for commercial and agricultural mortgage loans atas of September 30, 20202021 and December 31, 2019.2020. The values used in these ratio calculations were developed as part of the periodic review of the commercial and agricultural mortgage loan portfolio, which includes an evaluation of the underlying collateral value.










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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued

Mortgage Loans by LTV and DSC Ratios
DSC Ratio (2) (3) DSC Ratio (2) (3)
LTV Ratio (1) (3):LTV Ratio (1) (3):Greater than 2.0x1.8x to 2.0x1.5x to 1.8x1.2x to 1.5x1.0x to 1.2xLess than 1.0xTotalLTV Ratio (1) (3):Greater than 2.0x1.8x to 2.0x1.5x to 1.8x1.2x to 1.5x1.0x to 1.2xLess than 1.0xTotal
(in millions) (in millions)
September 30, 2020:
September 30, 2021:September 30, 2021:
Mortgage loans:Mortgage loans:Mortgage loans:
Commercial:Commercial:Commercial:
0% - 50%0% - 50%$935 $0 $185 $24 $0 $0 $1,144 0% - 50%$860 $ $390 $31 $40 $98 $1,419 
50% - 70%50% - 70%3,992 1,160 1,342 511 26 0 7,031 50% - 70%4,026 680 993 755 421 30 6,905 
70% - 90%70% - 90%574 348 332 306 134 0 1,694 70% - 90%797 568 210 492 181 56 2,304 
90% plus90% plus84 0 0 77 0 72 233 90% plus  86 65  73 224 
Total commercialTotal commercial$5,585 $1,508 $1,859 $918 $160 $72 $10,102 Total commercial$5,683 $1,248 $1,679 $1,343 $642 $257 $10,852 
Agricultural:Agricultural:Agricultural:
0% - 50%0% - 50%$283 $107 $271 $529 $335 $33 $1,558 0% - 50%$289 $98 $283 $501 $296 $29 $1,496 
50% - 70%50% - 70%104 100 220 460 265 25 1,174 50% - 70%105 110 180 480 241 14 1,130 
70% - 90%70% - 90%0 2 0 19 0 0 21 70% - 90% 2    15 17 
90% plus90% plus0 0 0 0 0 0 0 90% plus       
Total agriculturalTotal agricultural$387 $209 $491 $1,008 $600 $58 $2,753 Total agricultural$394 $210 $463 $981 $537 $58 $2,643 
Total mortgage loans:Total mortgage loans:Total mortgage loans:
0% - 50%0% - 50%$1,218 $107 $456 $553 $335 $33 $2,702 0% - 50%$1,149 $98 $673 $532 $336 $127 $2,915 
50% - 70%50% - 70%4,096 1,260 1,562 971 291 25 8,205 50% - 70%4,131 790 1,173 1,235 662 44 8,035 
70% - 90%70% - 90%574 350 332 325 134 0 1,715 70% - 90%797 570 210 492 181 71 2,321 
90% plus90% plus84 0 0 77 0 72 233 90% plus  86 65  73 224 
Total mortgage loansTotal mortgage loans$5,972 $1,717 $2,350 $1,926 $760 $130 $12,855 Total mortgage loans$6,077 $1,458 $2,142 $2,324 $1,179 $315 $13,495 
December 31, 2019:
December 31, 2020:December 31, 2020:
Mortgage loans:Mortgage loans:Mortgage loans:
Commercial:Commercial:Commercial:
0% - 50%0% - 50%$887 $38 $214 $24 $$$1,163 0% - 50%$839 $— $160 $— $— $— $999 
50% - 70%50% - 70%4,097 1,195 1,118 795 242 7,447 50% - 70%4,095 870 1,452 555 25 — 6,997 
70% - 90%70% - 90%251 98 214 154 46 763 70% - 90%844 449 343 376 142 36 2,190 
90% plus90% plus90% plus156 — — 77 — 72 305 
Total commercialTotal commercial$5,235 $1,331 $1,546 $973 $288 $$9,373 Total commercial$5,934 $1,319 $1,955 $1,008 $167 $108 $10,491 
Agricultural:Agricultural:
0% - 50%0% - 50%$297 $108 $291 $520 $317 $34 $1,567 
50% - 70%50% - 70%108 94 211 450 257 24 1,144 
70% - 90%70% - 90%— — 19 — — 21 
90% plus90% plus— — — — — — — 
Total agriculturalTotal agricultural$405 $204 $502 $989 $574 $58 $2,732 
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
DSC Ratio (2) (3) DSC Ratio (2) (3)
LTV Ratio (1) (3):LTV Ratio (1) (3):Greater than 2.0x1.8x to 2.0x1.5x to 1.8x1.2x to 1.5x1.0x to 1.2xLess than 1.0xTotalLTV Ratio (1) (3):Greater than 2.0x1.8x to 2.0x1.5x to 1.8x1.2x to 1.5x1.0x to 1.2xLess than 1.0xTotal
(in millions)
Agricultural:
0% - 50%$322 $104 $241 $545 $321 $50 $1,583 
50% - 70%82 87 236 426 251 33 1,115 
70% - 90%19 19 
90% plus
Total agricultural$404 $191 $477 $990 $572 $83 $2,717 
(in millions)
Total mortgage loans:Total mortgage loans:Total mortgage loans:
0% - 50%0% - 50%$1,209 $142 $455 $569 $321 $50 $2,746 0% - 50%$1,136 $108 $451 $520 $317 $34 $2,566 
50% - 70%50% - 70%4,179 1,282 1,354 1,221 493 33 8,562 50% - 70%4,203 964 1,663 1,005 282 24 8,141 
70% - 90%70% - 90%251 98 214 173 46 782 70% - 90%844 451 343 395 142 36 2,211 
90% plus90% plus90% plus156 — — 77 — 72 305 
Total mortgage loansTotal mortgage loans$5,639 $1,522 $2,023 $1,963 $860 $83 $12,090 Total mortgage loans$6,339 $1,523 $2,457 $1,997 $741 $166 $13,223 
______________
(1)The LTV ratio is derived from current loan balance divided by the fair value of the property. The fair value of the underlying commercial properties is updated annually for each mortgage loan.
(2)The DSC ratio is calculated using the most recently reported operating income results from property operations divided by annual debt service.
(3)Amounts presented at amortized cost basis.
Past-Due and Nonaccrual Mortgage Loan Status
The following table provides information relating to the aging analysis of past-due mortgage loans atas of September 30, 20202021 and December 31, 2019,2020, respectively:
Age Analysis of Past Due Mortgage Loans (1)
Accruing LoansNon-accruing LoansTotal LoansNon-accruing Loans with No AllowanceInterest Income on Non-accruing Loans(2)Accruing LoansNon-accruing LoansTotal LoansNon-accruing Loans with No AllowanceInterest Income on Non-accruing Loans
Past DueCurrentTotalPast DueCurrentTotal
30-59 Days
60-89
Days
90
Days
or  More
Total30-59 Days
60-89
Days
90
Days
or  More
Total
(in millions)(in millions)
September 30, 2020:
September 30, 2021:September 30, 2021:
Mortgage loans:Mortgage loans:Mortgage loans:
CommercialCommercial$0 $0 $0 $0 $10,102 $10,102 $0 $10,102 $0 $0 Commercial$ $ $ $ $10,852 $10,852 $ $10,852 $ $ 
AgriculturalAgricultural24 6 135 165 2,588 2,753 0 2,753 0 0 Agricultural8 3 66 77 2,566 2,643  2,643   
TotalTotal$24 $6 $135 $165 $12,690 $12,855 $0 $12,855 $0 $0 Total$8 $3 $66 $77 $13,418 $13,495 $ $13,495 $ $ 
December 31, 2019:
December 31, 2020:December 31, 2020:
Mortgage loans:Mortgage loans:Mortgage loans:
CommercialCommercial$$$$$9,373 $9,373 $$9,373 $$Commercial$162 $— $— $162 $10,329 $10,491 $— $10,491 $— $— 
AgriculturalAgricultural57 66 124 2,593 2,717 2,717 Agricultural76 29 112 2,620 2,732 — 2,732 — — 
TotalTotal$57 $$66 $124 $11,966 $12,090 $$12,090 $$Total$238 $$29 $274 $12,949 $13,223 $— $13,223 $— $— 
_______________
(1)Amounts presented at amortized cost basis.
(2) Amounts for 2020 represent results for both the three and nine months ended
As of September 30, 2020.
At September 30, 20202021 and December 31, 2019,2020, the carrying values of problem mortgage loans that had been classified as non-accrual loans were $0 million and $0 million, respectively.
Troubled Debt Restructuring
There were no privately negotiated fixed maturity modifications accounted for as a TDR during the three months ended September 30, 2021. During the nine months ended September 30, 2021, the Company had 1 new privately negotiated fixed maturity TDR with a pre-modification cost basis of $9 million and post-modification carrying value of $4 million. This TDR did not have subsequent payment defaults nor additional commitments to lend. The 1 privately negotiated fixed maturity TDR is 0.004% of the Company’s total invested assets. There were no mortgage loan on real estate modifications accounted for as a TDR during three and nine months ended September 30, 2021.

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Troubled Debt Restructuring
ForDuring the three and nine months ended September 30, 2020, the Company had 1 commercial mortgage loan on real estate accounted for as a TDR with a pre-modification cost basis of $75 million2 and post-modification carrying value of $75 million. The 1 commercial mortgage loan TDR is 0.07% of the Company’s total invested assets. For the nine months ended September 30, 2020, the Company had 6 new privately negotiated fixed maturity TDRs with a pre-modification cost basis of $8 million and $50 million and post-modification carrying value of $7 million and $44 million.million, respectively. These TDRs did not have subsequent payment defaults nor additional commitments to lend. The 6 privately negotiated fixed maturity TDRs arewere 0.04% of the Company’s total invested assets. There were no During the three and nine months ended September 30, 2020, there was 1 commercial mortgage loan on real estate or fixed maturities accounted for as a TDR with pre-modification cost basis of $75 million and post-modification carrying value of $75 million. The 1 commercial mortgage loan TDR was 0.07% of the Company’s total invested assets.
Equity Securities
The table below presents a breakdown of unrealized and realized gains and (losses) on equity securities during 2019.the three and nine months ended September 30, 2021.
Unrealized and Realized Gains (Losses) from Equity Securities (1)
Three Months Ended September 30,Nine Months Ended September 30,
20212021
(in millions)
Net investment gains (losses) recognized during the period on securities held at the end of the period$(1)$19 
Net investment gains (losses) recognized on securities sold during the period(3)1 
Unrealized and realized gains (losses) on equity securities$(4)$20 
______________     
(1) Effective January 1, 2021, certain preferred stock have been reclassified to other equity investments (see Note 2 Significant Accounting Policies – Investments).
Trading SecuritiesMortgage Loans on Real Estate
AtAccrued interest receivable on commercial and agricultural mortgage loans as of September 30, 2021 was $30 million and $29 million, respectively. There was no accrued interest written off for commercial and agricultural mortgage loans for the three and nine months ended September 30, 2021.
As of September 30, 2021, the Company had no loans for which foreclosure was probable included within the individually assessed mortgage loans, and accordingly had no associated allowance for credit losses.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Allowance for Credit Losses on Mortgage Loans
The change in the allowance for credit losses for commercial mortgage loans and agricultural mortgage loans during the three and nine months ended September 30, 2021 and 2020 were as follows:
Three Months Ended September 30,Nine Months Ended September 30,
2021202020212020
(in millions)
Allowance for credit losses on mortgage loans:
Commercial mortgages:
Balance, beginning of period$59 $62 $77 $33 
Current-period provision for expected credit losses1 (17)33 
Write-offs charged against the allowance —  0
Recoveries of amounts previously written off —  0
Net change in allowance1 (17)33 
Balance, end of period$60 $66 $60 $66 
Agricultural mortgages:
Balance, beginning of period$4 $$4 $
Current-period provision for expected credit losses —  
Write-offs charged against the allowance ���  — 
Recoveries of amounts previously written off —  — 
Net change in allowance —  
Balance, end of period$4 $$4 $
Total allowance for credit losses$64 $70 $64 $70 

The change in the allowance for credit losses is attributable to:
increases/decreases in the loan balance due to new originations, maturing mortgages, and loan amortization;
changes in credit quality; and
changes in market assumptions primarily related to COVID-19 driven economic changes.
Credit Quality Information
The following tables summarize the Company’s mortgage loans segregated by risk rating exposure as of September 30, 2021 and December 31, 2019, respectively,2020.







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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
LTV Ratios (1)
September 30, 2021
Amortized Cost Basis by Origination Year
20212020201920182017PriorTotal
(in millions)
Mortgage loans:
Commercial:
0% - 50%$ $1 $ $184 $324 $910 $1,419 
50% - 70%1,286 1,265 390 619 492 2,853 6,905 
70% - 90%97 320 413 451 275 748 2,304 
90% plus   12 5 207 224 
Total commercial$1,383 $1,586 $803 $1,266 $1,096 $4,718 $10,852 
Agricultural:
0% - 50%$113 $215 $130 $131 $133 $774 $1,496 
50% - 70%174 270 105 134 88 359 1,130 
70% - 90%     17 17 
90% plus       
Total agricultural$287 $485 $235 $265 $221 $1,150 $2,643 
Total mortgage loans:
0% - 50%$113 $216 $130 $315 $457 $1,684 $2,915 
50% - 70%1,460 1,535 495 753 580 3,212 8,035 
70% - 90%97 320 413 451 275 765 2,321 
90% plus   12 5 207 224 
Total mortgage loans$1,670 $2,071 $1,038 $1,531 $1,317 $5,868 $13,495 

Debt Service Coverage Ratios (2)
September 30, 2021
Amortized Cost Basis by Origination Year
20212020201920182017PriorTotal
(in millions)
Mortgage loans:
Commercial:
Greater than 2.0x$705 $1,276 $328 $772 $408 $2,194 $5,683 
1.8x to 2.0x132 136 233 93 269 385 1,248 
1.5x to 1.8x183 115 167 223 166 825 1,679 
1.2x to 1.5x64 59 75 54 253 838 1,343 
1.0x to 1.2x299   88  255 642 
Less than 1.0x   36  221 257 
Total commercial$1,383 $1,586 $803 $1,266 $1,096 $4,718 $10,852 
Agricultural:
Greater than 2.0x$37 $66 $25 $16 $33 $217 $394 
1.8x to 2.0x38 37 26 21 14 74 210 
1.5x to 1.8x50 114 29 28 44 198 463 
1.2x to 1.5x122 180 114 117 73 375 981 
1.0x to 1.2x40 84 32 78 56 247 537 
Less than 1.0x 4 9 5 1 39 58 
Total agricultural$287 $485 $235 $265 $221 $1,150 $2,643 
Total mortgage loans:
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
September 30, 2021
Amortized Cost Basis by Origination Year
20212020201920182017PriorTotal
(in millions)
Greater than 2.0x$742 $1,342 $353 $788 $441 $2,411 $6,077 
1.8x to 2.0x170 173 259 114 283 459 1,458 
1.5x to 1.8x233 229 196 251 210 1,023 2,142 
1.2x to 1.5x186 239 189 171 326 1,213 2,324 
1.0x to 1.2x339 84 32 166 56 502 1,179 
Less than 1.0x 4 9 41 1 260 315 
Total mortgage loans$1,670 $2,071 $1,038 $1,531 $1,317 $5,868 $13,495 
_____________
(1)The LTV ratio is derived from current loan balance divided by the fair value of the property. The fair value of the underlying commercial properties is updated annually for each mortgage loan.
(2)The DSC ratio is calculated using the most recently reported operating income results from property operations divided by annual debt service.
LTV Ratios (1)
December 31, 2020
Amortized Cost Basis by Origination Year
20202019201820172016PriorTotal
(in millions)
Mortgage loans:
Commercial:
0% - 50%$— $— $— $324 $170 $505 $999 
50% - 70%1,294 357 803 656 2,190 1,697 6,997 
70% - 90%321 457 452 219 203 538 2,190 
90% plus— — 12 — 288 305 
Total commercial$1,615 $814 $1,267 $1,204 $2,563 $3,028 $10,491 
Agricultural:
0% - 50%$218 $135 $169 $157 $236 $652 $1,567 
50% - 70%277 129 161 102 124 351 1,144 
70% - 90%— — — — 18 21 
90% plus— — — — — — — 
Total agricultural$495 $264 $333 $259 $360 $1,021 $2,732 
Total mortgage loans:
0% - 50%$218 $135 $169 $481 $406 $1,157 $2,566 
50% - 70%1,571 486 964 758 2,314 2,048 8,141 
70% - 90%321 457 455 219 203 556 2,211 
90% plus— — 12 — 288 305 
Total mortgage loans$2,110 $1,078 $1,600 $1,463 $2,923 $4,049 $13,223 











27

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Debt Service Coverage Ratios (2)
December 31, 2020
Amortized Cost Basis by Origination Year
20202019201820172016PriorTotal
(in millions)
Mortgage loans:
Commercial:
Greater than 2.0x$1,230 $492 $772 $268 $1,942 $1,230 $5,934 
1.8x to 2.0x227 83 118 378 184 329 1,319 
1.5x to 1.8x98 138 187 479 437 616 1,955 
1.2x to 1.5x60 57 154 79 — 658 1,008 
1.0x to 1.2x— 44 — — — 123 167 
Less than 1.0x— — 36 — — 72 108 
Total commercial$1,615 $814 $1,267 $1,204 $2,563 $3,028 $10,491 
Agricultural:
Greater than 2.0x$67 $26 $36 $38 $71 $167 $405 
1.8x to 2.0x38 35 14 15 20 82 204 
1.5x to 1.8x117 38 41 45 52 209 502 
1.2x to 1.5x183 120 141 90 142 313 989 
1.0x to 1.2x86 35 93 70 57 233 574 
Less than 1.0x10 18 17 58 
Total agricultural$495 $264 $333 $259 $360 $1,021 $2,732 
Total mortgage loans:
Greater than 2.0x$1,297 $518 $808 $306 $2,013 $1,397 $6,339 
1.8x to 2.0x265 118 132 393 204 411 1,523 
1.5x to 1.8x215 176 228 524 489 825 2,457 
1.2x to 1.5x243 177 295 169 142 971 1,997 
1.0x to 1.2x86 79 93 70 57 356 741 
Less than 1.0x10 44 18 89 166 
Total mortgage loans$2,110 $1,078 $1,600 $1,463 $2,923 $4,049 $13,223 
_____________
(1)The LTV ratio is derived from current loan balance divided by the fair value of the property. The fair value of the underlying commercial properties is updated annually for each mortgage loan.
(2)The DSC ratio is calculated using the most recently reported operating income results from property operations divided by annual debt service.
The following tables provide information relating to the LTV and DSC ratios for commercial and agricultural mortgage loans as of September 30, 2021 and December 31, 2020. The values used in these ratio calculations were developed as part of the periodic review of the commercial and agricultural mortgage loan portfolio, which includes an evaluation of the underlying collateral value.










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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued

Mortgage Loans by LTV and DSC Ratios
 DSC Ratio (2) (3)
LTV Ratio (1) (3):Greater than 2.0x1.8x to 2.0x1.5x to 1.8x1.2x to 1.5x1.0x to 1.2xLess than 1.0xTotal
 (in millions)
September 30, 2021:
Mortgage loans:
Commercial:
0% - 50%$860 $ $390 $31 $40 $98 $1,419 
50% - 70%4,026 680 993 755 421 30 6,905 
70% - 90%797 568 210 492 181 56 2,304 
90% plus  86 65  73 224 
Total commercial$5,683 $1,248 $1,679 $1,343 $642 $257 $10,852 
Agricultural:
0% - 50%$289 $98 $283 $501 $296 $29 $1,496 
50% - 70%105 110 180 480 241 14 1,130 
70% - 90% 2    15 17 
90% plus       
Total agricultural$394 $210 $463 $981 $537 $58 $2,643 
Total mortgage loans:
0% - 50%$1,149 $98 $673 $532 $336 $127 $2,915 
50% - 70%4,131 790 1,173 1,235 662 44 8,035 
70% - 90%797 570 210 492 181 71 2,321 
90% plus  86 65  73 224 
Total mortgage loans$6,077 $1,458 $2,142 $2,324 $1,179 $315 $13,495 
December 31, 2020:
Mortgage loans:
Commercial:
0% - 50%$839 $— $160 $— $— $— $999 
50% - 70%4,095 870 1,452 555 25 — 6,997 
70% - 90%844 449 343 376 142 36 2,190 
90% plus156 — — 77 — 72 305 
Total commercial$5,934 $1,319 $1,955 $1,008 $167 $108 $10,491 
Agricultural:
0% - 50%$297 $108 $291 $520 $317 $34 $1,567 
50% - 70%108 94 211 450 257 24 1,144 
70% - 90%— — 19 — — 21 
90% plus— — — — — — — 
Total agricultural$405 $204 $502 $989 $574 $58 $2,732 
29

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
 DSC Ratio (2) (3)
LTV Ratio (1) (3):Greater than 2.0x1.8x to 2.0x1.5x to 1.8x1.2x to 1.5x1.0x to 1.2xLess than 1.0xTotal
 (in millions)
Total mortgage loans:
0% - 50%$1,136 $108 $451 $520 $317 $34 $2,566 
50% - 70%4,203 964 1,663 1,005 282 24 8,141 
70% - 90%844 451 343 395 142 36 2,211 
90% plus156 — — 77 — 72 305 
Total mortgage loans$6,339 $1,523 $2,457 $1,997 $741 $166 $13,223 
______________
(1)The LTV ratio is derived from current loan balance divided by the fair value of the property. The fair value of the underlying commercial properties is updated annually for each mortgage loan.
(2)The DSC ratio is calculated using the most recently reported operating income results from property operations divided by annual debt service.
(3)Amounts presented at amortized cost basis.
Past-Due and Nonaccrual Mortgage Loan Status
The following table provides information relating to the aging analysis of past-due mortgage loans as of September 30, 2021 and December 31, 2020, respectively:
Age Analysis of Past Due Mortgage Loans (1)
Accruing LoansNon-accruing LoansTotal LoansNon-accruing Loans with No AllowanceInterest Income on Non-accruing Loans
Past DueCurrentTotal
30-59 Days
60-89
Days
90
Days
or  More
Total
(in millions)
September 30, 2021:
Mortgage loans:
Commercial$ $ $ $ $10,852 $10,852 $ $10,852 $ $ 
Agricultural8 3 66 77 2,566 2,643  2,643   
Total$8 $3 $66 $77 $13,418 $13,495 $ $13,495 $ $ 
December 31, 2020:
Mortgage loans:
Commercial$162 $— $— $162 $10,329 $10,491 $— $10,491 $— $— 
Agricultural76 29 112 2,620 2,732 — 2,732 — — 
Total$238 $$29 $274 $12,949 $13,223 $— $13,223 $— $— 
_______________
(1)Amounts presented at amortized cost basis.

As of September 30, 2021 and December 31, 2020, the carrying values of problem mortgage loans that had been classified as non-accrual loans were $0 million and $0 million, respectively.
Troubled Debt Restructuring
There were no privately negotiated fixed maturity modifications accounted for as a TDR during the three months ended September 30, 2021. During the nine months ended September 30, 2021, the Company had 1 new privately negotiated fixed maturity TDR with a pre-modification cost basis of $9 million and post-modification carrying value of $4 million. This TDR did not have subsequent payment defaults nor additional commitments to lend. The 1 privately negotiated fixed maturity TDR is 0.004% of the Company’s trading securities was $5.8 billiontotal invested assets. There were no mortgage loan on real estate modifications accounted for as a TDR during three and $6.6 billion. Atnine months ended September 30, 2021.

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued

During the three and nine months ended September 30, 2020, the Company had 2 and December 31, 2019, respectively, trading securities included the General Account’s investment in Separate Accounts, which had carrying values6 new privately negotiated fixed maturity TDRs with a pre-modification cost basis of $37$8 million and $58 million.$50 million and post-modification carrying value of $7 million and $44 million, respectively. These TDRs did not have subsequent payment defaults nor additional commitments to lend. The 6 privately negotiated fixed maturity TDRs were 0.04% of the Company’s total invested assets. During the three and nine months ended September 30, 2020, there was 1 commercial mortgage loan on real estate accounted for as a TDR with pre-modification cost basis of $75 million and post-modification carrying value of $75 million. The 1 commercial mortgage loan TDR was 0.07% of the Company’s total invested assets.
Equity Securities
The table below showspresents a breakdown of Net investment income (loss) from tradingunrealized and realized gains and (losses) on equity securities during the three and nine months ended September 30, 20202021.
Unrealized and 2019:Realized Gains (Losses) from Equity Securities (1)
Net Investment Income (Loss) from Trading Securities
Three Months Ended September 30,Nine Months Ended September 30,
20212021
(in millions)
Net investment gains (losses) recognized during the period on securities held at the end of the period$(1)$19 
Net investment gains (losses) recognized on securities sold during the period(3)1 
Unrealized and realized gains (losses) on equity securities$(4)$20 
Three Months Ended September 30,Nine Months Ended September 30,
2020201920202019
(in millions)
Net investment gains (losses) recognized during the period on securities held at the end of the period$(1)$$86 $431 
Net investment gains (losses) recognized on securities sold during the period(5)13 12 (10)
Unrealized and realized gains (losses) on trading securities(6)20 98 421 
Interest and dividend income from trading securities58 59 152 220 
Net investment income (loss) from trading securities$52 $79 $250 $641 
______________     

4)    DERIVATIVES
The Company uses derivatives as part of its overall asset/liability risk management primarily(1) Effective January 1, 2021, certain preferred stock have been reclassified to reduce exposures to equity market and interest rate risks. Derivative hedging strategies are designed to reduce these risks from an economic perspective and are all executed within the framework of a “Derivative Use Plan” approved by applicable states’ insurance law. Derivatives are generally not accounted for using hedge accounting, with the exception of Treasury Inflation-Protected Securities (“TIPS”), which is discussed further below. Operation of these hedging programs is based on models involving numerous estimates and assumptions, including, among others, mortality, lapse, surrender and withdrawal rates, election rates, fund performance, market volatility and interest rates. A wide range of derivative contracts are used in these hedging programs, including exchange traded equity, currency and interest rate futures contracts, total return and/or other equity swaps, interest rate swap and floor contracts, bond and bond-index total return swaps, swaptions, variance swaps and equity options, credit and foreign exchange derivatives, as well as bond and repo transactions to support the hedging. The derivative contracts are collectively managed in an effort to reduce the economic impact of unfavorable changes in guaranteed benefits’ exposures attributable to movements in capital markets. In addition, as part of its hedging strategy, the Company targets an asset level for all variable annuity products at or above a CTE98 level under most economic scenarios (Conditional Tail Expectation, or “CTE”, is a statistical measure of tail risk which quantifies the total asset requirement to sustain a loss if an event outside a given probability level has occurred. CTE98 denotes the financial resources a company would need to cover the average of the worst 2% of scenarios.)
28

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Derivatives Utilized to Hedge Exposure to Variable Annuities with Guarantee Features
The Company has issued and continues to offer variable annuity products with GMxB features. The risk associated with the GMDB feature is that under-performance of the financial markets could result in GMDB benefits, in the event of death, being higher than what accumulated policyholders’ account balances would support. The risk associated with the GMIB feature is that under-performance of the financial markets could result in the present value of GMIB, in the event of annuitization, being higher than what accumulated policyholders’ account balances would support, taking into account the relationship between current annuity purchase rates and the GMIB guaranteed annuity purchase rates. The risk associated with products that have a GMxB derivative features liability is that under-performance of the financial markets could result in the GMxB derivative features’ benefits being higher than what accumulated policyholders’ account balances would support.
For GMxB features, the Company retains certain risks including basis, credit spread and some volatility risk and risk associated with actual versus expected actuarial assumptions for mortality, lapse and surrender, withdrawal and policyholder election rates, among other things. The derivative contracts are managed to correlate with changes in the value of the GMxB features that result from financial markets movements. A portion of exposure to realized equity volatility is hedged using equity options and variance swaps and a portion of exposure to credit risk is hedged using total return swaps on fixed income indices. Additionally, the Company is party to total return swaps for which the reference U.S. Treasury securities are contemporaneously purchased from the market and sold to the swap counterparty. As these transactions result in a transfer of control of the U.S. Treasury securities to the swap counterparty, the Company derecognizes these securities with consequent gain or loss from the sale. The Company has also purchased reinsurance contracts to mitigate the risks associated with GMDB features and the impact of potential market fluctuations on future policyholder elections of GMIB features contained in certain annuity contracts issued by the Company. The reinsurance of the GMIB features is accounted for as a derivative.
The Company has in place an economic hedge program using interest rate swaps and U.S. Treasury futures to partially protect the overall profitability of future variable annuity sales against declining interest rates.
Derivatives Utilized to Hedge Crediting Rate Exposure on SCS, SIO, MSO and IUL Products/Investment Options
The Company hedges crediting rates in the Structured Capital Strategies (“SCS”) variable annuity, Structured Investment Option in the EQUI-VEST variable annuity series (“SIO”), Market Stabilizer Option (“MSO”) in the variable life insurance products and Indexed Universal Life (“IUL”) insurance products. These products permit the contract owner to participate in the performance of an index, Exchange Traded Funds (“ETF”) or commodity price movement up to a cap for a set period of time. They also contain a protection feature, in which the Company will absorb, up to a certain percentage, the loss of value in an index, ETF or commodity price, which varies by product segment.
In order to support the returns associated with these features, the Company enters into derivative contracts whose payouts, in combination with fixed income investments emulate those of the index, ETF or commodity price, subject to caps and buffers, thereby substantially reducing any exposure to market-related earnings volatility.
Derivatives Used to Hedge Equity Market Risks Associated with the General Account’s Seed Money Investments in Retail Mutual Funds
The Company’s General Account seed money investments in retail mutual funds expose us to market risk, including equity market risk which is partially hedged through equity-index futures contracts to minimize such risk.
Derivatives Used to Hedge Universal Life Products with Secondary Guarantee (“ULSG”) Policy
The Company implemented a hedge program using fixed income total return swaps to mitigate the interest rate exposure in the ULSG policy statutory liability.
Derivatives Used for General Account Investment Portfolio
The Company maintains a strategy in its General Account investment portfolio to replicate the credit exposure of fixed maturity securities otherwise permissible for investment under its investment guidelines through the sale of credit default swaps (“CDS”). Under the terms of these swaps, the Company receives quarterly fixed premiums that, together with any initial amount paid or received at trade inception, replicate the credit spread otherwise currently obtainable by purchasing the referenced entity’s bonds of similar maturity. These credit derivatives generally have remaining terms
29

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
of five years or less and are recorded at fair value with changes in fair value, including the yield component that emerges from initial amounts paid or received, reported in Net derivative gains (losses)(see Note 2 Significant Accounting Policies – Investments).
The Company manages its credit exposure taking into consideration both cash and derivatives based positions and selects the reference entities in its replicated credit exposures in a manner consistent with its selection of fixed maturities. In addition, the Company generally transacts the sale of CDS in single name reference entities of investment grade credit quality and with counterparties subject to collateral posting requirements. If there is an event of default by the reference entity or other such credit event as defined under the terms of the swap contract, the Company is obligated to perform under the credit derivative and, at the counterparty’s option, either pay the referenced amount of the contract less an auction-determined recovery amount or pay the referenced amount of the contract and receive in return the defaulted or similar security of the reference entity for recovery by sale at the contract settlement auction. The Company purchased CDS to mitigate its exposure to a reference entity through cash positions. These positions do not replicate credit spreads.
To date, there have been no events of default or circumstances indicative of a deterioration in the credit quality of the named referenced entities to require or suggest that the Company will have to perform under these CDS. The maximum potential amount of future payments the Company could be required to make under these credit derivatives is limited to the par value of the referenced securities which is the dollar or euro-equivalent of the derivative’s notional amount. The Standard North American CDS Contract (“SNAC”) or Standard European Corporate Contract (“STEC”) under which the Company executes these CDS sales transactions does not contain recourse provisions for recovery of amounts paid under the credit derivative.
The Company purchased 30-year TIPS and other sovereign bonds, both inflation-linked and non-inflation linked, as General Account investments and enters into asset or cross-currency basis swaps, to result in payment of the given bond’s coupons and principal at maturity in the bond’s specified currency to the swap counterparty in return for fixed dollar amounts. These swaps, when considered in combination with the bonds, together result in a net position that is intended to replicate a dollar-denominated fixed-coupon cash bond with a yield higher than a term-equivalent U.S. Treasury bond.
The tables below present quantitative disclosures about the Company’s derivative instruments, including those embedded in other contracts required to be accounted for as derivative instruments:
30

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Derivative Instruments by Category
At September 30, 2020Nine Months Ended September 30, 2020
 Fair Value
 Notional
Amount
Derivative Assets
Derivative
Liabilities
Net Derivative
Gains (Losses) (2)
(in millions)
Derivative instruments:
Freestanding derivatives (1):
Equity contracts:
Futures$3,739 $0 $0 $(347)
Swaps20,667 27 18 (594)
Options31,679 5,543 2,791 (480)
Interest rate contracts:
Swaps23,952 1,696 338 3,588 
Futures19,484 0 0 2,058 
Swaptions0 0 0 9 
Credit contracts:
Credit default swaps1,252 9 4 (4)
Other freestanding contracts:
Foreign currency contracts347 0 0 (3)
Margin0 40 125 0 
Collateral0 14 4,959 0 
Embedded derivatives:
GMIB reinsurance contracts (3)0 3,247 0 849 
GMxB derivative features liability (4)0 0 11,985 (3,382)
SCS, SIO, MSO and IUL indexed features (5)0 0 2,502 410 
Total derivative instruments$101,120 $10,576 $22,722 
Net derivative gains (losses) (6)



$2,104 
______________
(1)Reported in Other invested assets in the consolidated balance sheets.
(2)Reported in Net derivative gains (losses) in the consolidated statements of income (loss).
(3)Reported in GMIB reinsurance contract asset in the consolidated balance sheets.
(4)Reported in Future policy benefits and other policyholders’ liabilities in the consolidated balance sheets.
(5)Reported in Policyholders’ account balances in the consolidated balance sheets.
(6)Investment fees of $9 million are reported in Net derivative gains (losses) in the consolidated statements of income (loss).

31

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Derivative Instruments by Category
At December 31, 2019Nine Months Ended September 30, 2019
 Fair Value
 Notional
Amount
Derivative Assets
Derivative
Liabilities
Net Derivative
Gains (Losses) (2)
(in millions)
Derivative instruments:
Freestanding derivatives (1):
Equity contracts:
Futures$3,510 $$$(967)
Swaps17,064 279 (1,263)
Options47,766 5,080 1,749 1,241 
Interest rate contracts:
Swaps23,700 467 523 2,844 
Futures20,424 183 
Swaptions3,201 16 146 
Credit contracts:
Credit default swaps1,232 18 13 
Other freestanding contracts:
Foreign currency contracts501 (13)
Margin140 
Collateral72 3,001 
Embedded derivatives:
GMIB reinsurance contracts (3)2,466 881 
GMxB derivative features liability (4)8,316 (3,656)
SCS, SIO, MSO and IUL indexed features (5)3,150 (1,489)
Total derivative instruments$117,398 $8,271 $17,018 
Net derivative gains (losses)



$(2,080)
______________
(1)Reported in Other invested assets in the consolidated balance sheets.
(2)Reported in Net derivative gains (losses) in the consolidated statements of income (loss).
(3)Reported in GMIB reinsurance contract asset in the consolidated balance sheets.
(4)Reported in Future policy benefits and other policyholders’ liabilities in the consolidated balance sheets.
(5)Reported in Policyholders’ account balances in the consolidated balance sheets.
Equity-Based and Treasury Futures Contracts Margin
All outstanding equity-based and treasury futures contracts at September 30, 2020 and December 31, 2019 are exchange-traded and net settled daily in cash. At September 30, 2020 and December 31, 2019, respectively, the Company had open exchange-traded futures positions on: (i) the S&P 500, Russell 2000 and Emerging Market indices, having initial margin requirements of $205 million and $58 million, (ii) the 2-year, 5-year and 10-year U.S. Treasury Notes on U.S. Treasury bonds and ultra-long bonds, having initial margin requirements of $314 million and $165 million, and (iii) the Euro Stoxx, FTSE 100, Topix, ASX 200 and European, Australasia, and Far East (“EAFE”) indices as well as corresponding currency futures on the Euro/U.S. dollar, Pound/U.S. dollar, Australian dollar/U.S. dollar, and Yen/U.S. dollar, having initial margin requirements of $40 million and $60 million.
Collateral Arrangements
The Company generally has executed a Credit Support Annex (“CSA”) under the International Swaps and Derivatives Association Master Agreement (“ISDA Master Agreement”) it maintains with each of its over-the-counter (“OTC”) derivative counterparties that requires both posting and accepting collateral either in the form of cash or high-quality securities, such as U.S. Treasury securities, U.S. government and government agency securities and investment grade corporate bonds. The Company nets the fair value of all derivative financial instruments with counterparties for which
32

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
an ISDA Master Agreement and related CSA have been executed. At September 30, 2020 and December 31, 2019, respectively, the Company held $5.0 billion and $3.0 billion in cash and securities collateral delivered by trade counterparties, representing the fair value of the related derivative agreements. The unrestricted cash collateral is reported in Other invested assets. The Company posted collateral of $14 million and $72 million at September 30, 2020 and December 31, 2019, respectively, in the normal operation of its collateral arrangements.
The following table presents information about the Company’s offsetting of financial assets and liabilities and derivative instruments at September 30, 2020:
Offsetting of Financial Assets and Liabilities and Derivative Instruments
At September 30, 2020
Gross Amount RecognizedGross Amount Offset in the Balance SheetsNet Amount Presented in the Balance SheetsGross Amount not Offset in the Balance Sheets (1)Net Amount
(in millions)
Assets:
Derivative assets$7,330 $7,241 $89 $(54)$35 
Other financial assets1,434 0 1,434 0 1,434 
Other invested assets$8,764 $7,241 $1,523 $(54)$1,469 
Liabilities:
Derivative liabilities$8,181 $7,241 $940 $0 $940 
Other financial liabilities1,579 0 1,579 0 1,579 
Other liabilities$9,760 $7,241 $2,519 $0 $2,519 
______________
(1) Financial instruments sent (held).
The following table presents information about the Company’s offsetting of financial assets and liabilities and derivative instruments at December 31, 2019.
Offsetting of Financial Assets and Liabilities and Derivative Instruments
At December 31, 2019
Gross Amount RecognizedGross Amount Offset in the Balance SheetsNet Amount Presented in the Balance SheetsGross Amount not Offset in the Balance Sheets (1)Net Amount
(in millions)
Assets:
Derivative assets$5,804 $5,429 $375 $(77)$298 
Other financial instruments1,781 1,781 1,781 
Other invested assets$7,585 $5,429 $2,156 $(77)$2,079 
Liabilities:
Derivative liabilities$5,474 $5,429 $45 $$45 
Other financial liabilities1,724 1,724 1,724 
Other liabilities$7,198 $5,429 $1,769 $$1,769 
______________
(1)Financial instruments sent (held).
5)    CLOSED BLOCK
As a result of demutualization, the Company’s Closed Block was established in 1992 for the benefit of certain individual participating policies that were in force on that date. Assets, liabilities and earnings of the Closed Block are specifically identified to support its participating policyholders.
Assets allocated to the Closed Block inure solely to the benefit of the Closed Block policyholders and will not revert to the benefit of the Company. No reallocation, transfer, borrowing or lending of assets can be made between the Closed Block and other portions of the Company’s General Account, any of its Separate Accounts or any affiliate of the
33

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited)
Company without the approval of the New York State Department of Financial Services (the “NYDFS”). Closed Block assets and liabilities are carried on the same basis as similar assets and liabilities held in the General Account. For more information on the Closed Block, see Note 5 to the Company’s consolidated financial statements included in the Annual Report on Form 10-K for the year ended December 31, 2019.

Summarized financial information for the Company’s Closed Block is as follows:
 September 30, 2020December 31, 2019
(in millions)
Closed Block Liabilities:
Future policy benefits, policyholders’ account balances and other$6,260 $6,478 
Policyholder dividend obligation149 
Other liabilities58 38 
Total Closed Block liabilities6,467 6,518 
Assets Designated to the Closed Block:
Fixed maturities available-for-sale, at fair value (amortized cost of $3,440 and $3,558) (allowance for credit losses of $0 at September 30, 2020)3,788 3,754 
Mortgage loans on real estate (net of allowance for credit losses of $6 at September 30, 2020)1,782 1,759 
Policy loans656 706 
Cash and other invested assets3 82 
Other assets172 145 
Total assets designated to the Closed Block6,401 6,446 
Excess of Closed Block liabilities over assets designated to the Closed Block66 72 
Amounts included in accumulated other comprehensive income (loss):
Net unrealized investment gains (losses), net of policyholders’ dividend obligation: $149 and $2; and net of income tax: $42 and $41168 164 
Maximum future earnings to be recognized from Closed Block assets and liabilities$234 $236 
The Company’s Closed Block revenues and expenses were as follows:
Three Months Ended September 30,Nine Months Ended September 30,
2020201920202019
(in millions)
Revenues:
Premiums and other income$36 $42 $118 $136 
Net investment income (loss)61 69 190 208 
Investment gains (losses), net1 (1)(1)
Total revenues98 111 307 343 
Benefits and Other Deductions:
Policyholders’ benefits and dividends96 108 302 343 
Other operating costs and expenses0 
Total benefits and other deductions96 108 303 344 
Net income (loss), before income taxes2 4 (1)
Income tax (expense) benefit(1)(2)(2)
Net income (loss)$1 $$2 $(3)
34

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
6)    INSURANCE LIABILITIES
Variable Annuity Contracts – GMDB, GMIB, GIB and GWBL and Other Features
The Company has certain variable annuity contracts with GMDB, GMIB, GIB and GWBL and other features in-force that guarantee one of the following:
Return of Premium: the benefit is the greater of current account value or premiums paid (adjusted for withdrawals);
Ratchet: the benefit is the greatest of current account value, premiums paid (adjusted for withdrawals), or the highest account value on any anniversary up to contractually specified ages (adjusted for withdrawals);
Roll-Up: the benefit is the greater of current account value or premiums paid (adjusted for withdrawals) accumulated at contractually specified interest rates up to specified ages;
Combo: the benefit is the greater of the ratchet benefit or the roll-up benefit, which may include either a five year or an annual reset; or
Withdrawal: the withdrawal is guaranteed up to a maximum amount per year for life.
Liabilities for Variable Annuity Contracts with GMDB and GMIB Features without No-Lapse Guarantee Rider (“NLG”) Feature
The change in the liabilities for variable annuity contracts with GMDB and GMIB features and without a NLG feature are summarized in the tables below. The amounts for the direct contracts (before reinsurance ceded) and assumed contracts are reflected in the consolidated balance sheets in Future policy benefits and other policyholders’ liabilities. The amounts for the ceded contracts are reflected in the consolidated balance sheets in Amounts due from reinsurers. The amounts for the ceded IB are reflected in the consolidated balance sheets in GMIB reinsurance contract asset, at fair value.
Change in Liability for Variable Annuity Contracts with GMDB and GMIB Features and No NLG Feature
For the Three and Nine Months Ended September 30, 2020 and 2019

GMDBGMIB
DirectCededDirectCeded
(in millions)
Balance at July 1, 2020$4,998 $(99)$6,121 $(3,433)
Paid guarantee benefits(121)3 (110)21 
Other changes in reserve235 9 113 165 
Balance at September 30, 2020$5,112 $(87)$6,124 $(3,247)
Balance at July 1, 2019$4,709 $(100)$3,757 $(2,197)
Paid guarantee benefits(102)(70)20 
Other changes in reserve155 (4)979 (676)
Balance at September 30, 2019$4,762 $(101)$4,666 $(2,853)
GMDBGMIB
DirectCededDirectCeded
(in millions)
Balance at January 1, 2020$4,775 $(99)$4,671 $(2,466)
Paid guarantee benefits(372)12 (287)58 
Other changes in reserve709 0 1,740 (839)
Balance at September 30, 2020$5,112 $(87)$6,124 $(3,247)
Balance at January 1, 2019$4,657 $(107)$3,744 $(1,993)
Paid guarantee benefits(328)11 (182)55 
Other changes in reserve433 (5)1,104 (915)
Balance at September 30, 2019$4,762 $(101)$4,666 $(2,853)
35

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Liabilities for Embedded and Freestanding Insurance Related Derivatives
The liability for the GMxB derivative features, the liability for SCS, SIO, MSO and IUL indexed features and the asset and liability for the GMIB reinsurance contracts are considered embedded or freestanding insurance derivatives and are reported at fair value. For the fair value of the assets and liabilities associated with these embedded or freestanding insurance derivatives, see Note 7 Fair Value Disclosures.
Account Values and Net Amount at Risk
Account Values and Net Amount at Risk (“NAR”) for direct variable annuity contracts in force with GMDB and GMIB features as of September 30, 2020 are presented in the following tables by guarantee type. For contracts with the GMDB feature, the NAR in the event of death is the amount by which the GMDB feature exceeds the related Account Values. For contracts with the GMIB feature, the NAR in the event of annuitization is the amount by which the present value of the GMIB benefits exceed the related Account Values, taking into account the relationship between current annuity purchase rates and the GMIB guaranteed annuity purchase rates. Since variable annuity contracts with GMDB features may also offer GMIB guarantees in the same contract, the GMDB and GMIB amounts listed are not mutually exclusive.
Direct Variable Annuity Contracts with GMDB and GMIB Features
at September 30, 2020
Guarantee Type
Return of PremiumRatchetRoll-UpComboTotal
(in millions, except age and interest rate)
Variable annuity contracts with GMDB features
Account Values invested in:
General Account$15,155 $89 $57 $171 $15,472 
Separate Accounts48,407 8,812 3,021 31,083 91,323 
Total Account Values$63,562 $8,901 $3,078 $31,254 $106,795 
Net Amount at Risk, gross$125 $94 $1,864 $19,561 $21,644 
Net Amount at Risk, net of amounts reinsured$125 $91 $1,319 $19,561 $21,096 
Average attained age of policyholders (in years)51.3 68.1 74.7 70.0 55.3 
Percentage of policyholders over age 7011.0 %47.7 %69.8 %53.3 %20.0 %
Range of contractually specified interest ratesN/AN/A3% - 6%3% - 6.5%3% - 6.5%
Variable annuity contracts with GMIB features
Account Values invested in:
General Account$0 $0 $17 $220 $237 
Separate Accounts0 0 23,124 33,217 56,341 
Total Account Values$0 $0 $23,141 $33,437 $56,578 
Net Amount at Risk, gross$0 $0 $1,100 $14,461 $15,561 
Net Amount at Risk, net of amounts reinsured$0 $0 $349 $13,066 $13,415 
Average attained age of policyholders (in years)N/AN/A64.0 70.0 67.8 
Weighted average years remaining until annuitizationN/AN/A5.7 0.7 2.5 
Range of contractually specified interest ratesN/AN/A3% - 6%3% - 6.5%3% - 6.5%
For more information about the reinsurance programs of the Company’s GMDB and GMIB exposure, see “Reinsurance” in Note 10 to the Company’s consolidated financial statements included in the Annual Report on Form 10-K for the year ended December 31, 2019.
36

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Separate Accounts Investments by Investment Category Underlying Variable Annuity Contracts with GMDB and GMIB Features
The total Account Values of variable annuity contracts with GMDB and GMIB features include amounts allocated to the guaranteed interest option, which is part of the General Account and variable investment options that invest through Separate Accounts in variable insurance trusts. The following table presents the aggregate fair value of assets, by major investment category, held by Separate Accounts that support variable annuity contracts with GMDB and GMIB features. The investment performance of the assets impacts the related Account Values and, consequently, the NAR associated with the GMDB and GMIB benefits and guarantees. Because the Company’s variable annuity contracts offer both GMDB and GMIB features, GMDB and GMIB amounts are not mutually exclusive.
Investment in Variable Insurance Trust Mutual Funds
 September 30, 2020December 31, 2019
Mutual Fund TypeGMDBGMIBGMDBGMIB
 (in millions)
Equity$41,259 $16,739 $42,489 $17,941 
Fixed income5,371 2,679 5,263 2,699 
Balanced43,685 36,656 45,872 38,445 
Other1,008 267 865 263 
Total$91,323 $56,341 $94,489 $59,348 
Hedging Programs for GMDB, GMIB, GIB and Other Features
The Company has a program intended to hedge certain risks associated first with the GMDB feature and with the GMIB feature of the Accumulator series of variable annuity products. The program has also been extended to cover other guaranteed benefits as they have been made available. This program utilizes derivative contracts, such as exchange-traded equity, currency and interest rate futures contracts, total return and/or equity swaps, interest rate swap and floor contracts, swaptions, variance swaps as well as equity options, that collectively are managed in an effort to reduce the economic impact of unfavorable changes in guaranteed benefits’ exposures attributable to movements in the capital markets. At the present time, this program hedges certain economic risks on products sold from 2001 forward, to the extent such risks are not externally reinsured.
These programs do not qualify for hedge accounting treatment. Therefore, gains (losses) on the derivatives contracts used in these programs, including current period changes in fair value, are recognized in Net derivative gains (losses) in the period in which they occur, and may contribute to income (loss) volatility.
Variable and Interest-Sensitive Life Insurance Policies - NLG
The NLG feature contained in variable and interest-sensitive life insurance policies keeps them in force in situations where the policy value is not sufficient to cover monthly charges then due. The NLG remains in effect so long as the policy meets a contractually specified premium funding test and certain other requirements.
The change in the NLG liabilities, reflected in Future policy benefits and other policyholders’ liabilities in the consolidated balance sheets, is summarized in the table below.
20202019
Direct LiabilityReinsurance CededNetDirect LiabilityReinsurance CededNet
(in millions)
37

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
20202019
Direct LiabilityReinsurance CededNetDirect LiabilityReinsurance CededNet
Balance at July 1,$941 $(841)$100 $821 $(756)$65 
Paid guarantee benefits(6)0 (6)(7)(7)
Other changes in reserves61 (31)30 54 (31)23 
Balance at September 30,$996 $(872)$124 $868 $(787)$81 
Balance at January 1,$894 $(808)$86 $788 $(734)$54 
Paid guarantee benefits(32)0 (32)(16)(16)
Other changes in reserves134 (64)70 96 (53)43 
Balance at September 30,$996 $(872)$124 $868 $(787)$81 
7)    FAIR VALUE DISCLOSURES
U.S. GAAP establishes a fair value hierarchy that requires an entity to maximize the use of observable inputs and minimize the use of unobservable inputs when measuring fair value, and identifies three levels of inputs that may be used to measure fair value:
Level 1    Unadjusted quoted prices for identical instruments in active markets. Level 1 fair values generally are supported by market transactions that occur with sufficient frequency and volume to provide pricing information on an ongoing basis.
Level 2    Observable inputs other than Level 1 prices, such as quoted prices for similar instruments, quoted prices in markets that are not active, and inputs to model-derived valuations that are directly observable or can be corroborated by observable market data.
Level 3    Unobservable inputs supported by little or no market activity and often requiring significant management judgment or estimation, such as an entity’s own assumptions about the cash flows or other significant components of value that market participants would use in pricing the asset or liability.
The Company uses unadjusted quoted market prices to measure fair value for those instruments that are actively traded in financial markets. In cases where quoted market prices are not available, fair values are measured using present value or other valuation techniques. The fair value determinations are made at a specific point in time, based on available market information and judgments about the financial instrument, including estimates of the timing and amount of expected future cash flows and the credit standing of counterparties. Such adjustments do not reflect any premium or discount that could result from offering for sale at one time the Company’s entire holdings of a particular financial instrument, nor do they consider the tax impact of the realization of unrealized gains or losses. In many cases, the fair value cannot be substantiated by direct comparison to independent markets, nor can the disclosed value be realized in immediate settlement of the instrument.
Management is responsible for the determination of the value of investments carried at fair value and the supporting methodologies and assumptions. Under the terms of various service agreements, the Company often utilizes independent valuation service providers to gather, analyze, and interpret market information and derive fair values based upon relevant methodologies and assumptions for individual securities. These independent valuation service providers typically obtain data about market transactions and other key valuation model inputs from multiple sources and, through the use of widely accepted valuation models, provide a single fair value measurement for individual securities for which a fair value has been requested. As further described below with respect to specific asset classes, these inputs include, but are not limited to, market prices for recent trades and transactions in comparable securities, benchmark yields, interest rate yield curves, credit spreads, quoted prices for similar securities, and other market-observable information, as applicable. Specific attributes of the security being valued also are considered, including its term, interest rate, credit rating, industry sector, and when applicable, collateral quality and other security- or issuer-specific information. When insufficient market observable information is available upon which to measure fair value, the Company either will request brokers knowledgeable about these securities to provide a non-binding quote or will employ internal valuation models. Fair values received from independent valuation service providers and brokers and those internally modeled or otherwise estimated are assessed for reasonableness.
38

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Assets and Liabilities Measured at Fair Value on a Recurring Basis
Assets and liabilities measured at fair value on a recurring basis are summarized below. At September 30, 2020 and December 31, 2019, no assets were required to be measured at fair value on a non-recurring basis. Fair value measurements are required on a non-recurring basis for certain assets, including goodwill and mortgage loans on real estate, only when an impairment or other event occurs. When such fair value measurements are recorded, they must be classified and disclosed within the fair value hierarchy.
Fair Value Measurements at September 30, 2020
Level 1Level 2Level 3Total
 (in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate (1)$0 $50,040 $1,479 $51,519 
U.S. Treasury, government and agency0 17,284 0 17,284 
States and political subdivisions0 776 39 815 
Foreign governments0 902 0 902 
Residential mortgage-backed (2)0 145 0 145 
Asset-backed (3)0 2,578 13 2,591 
Commercial mortgage-backed0 1,117 0 1,117 
Redeemable preferred stock367 74 0 441 
Total fixed maturities, AFS367 72,916 1,531 74,814 
Other equity investments20 0 4 24 
Trading securities258 5,529 0 5,787 
Other invested assets:
Short-term investments0 106 0 106 
Assets of consolidated VIEs/VOEs0 0 12 12 
Swaps0 1,367 0 1,367 
Credit default swaps0 5 0 5 
Options0 2,752 0 2,752 
Total other invested assets0 4,230 

12 

4,242 
Cash equivalents2,488 1,031 0 3,519 
GMIB reinsurance contracts asset0 0 3,247 3,247 
Separate Accounts assets (4)118,085 2,424 0 120,509 
Total Assets$121,218 $86,130 $4,794 $212,142 
Liabilities:
GMxB derivative features’ liability$0 $0 $11,985 $11,985 
SCS, SIO, MSO and IUL indexed features’ liability0 2,502 0 2,502 
Total Liabilities$0 $2,502 $11,985 $14,487 
______________
(1)Corporate fixed maturities includes both public and private issues.
(2)Includes publicly traded agency pass-through securities and collateralized obligations.
(3)Includes credit-tranched securities collateralized by sub-prime mortgages and other asset types and credit tenant loans.
(4)Separate Accounts assets included in the fair value hierarchy exclude investments in entities that calculate NAV per share (or its equivalent) as a practical expedient. Such investments excluded from the fair value hierarchy include investments in real estate and commercial mortgages. At September 30, 2020 the fair value of such investments was $356 million.
39

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Fair Value Measurements at December 31, 2019
Level 1Level 2Level 3Total
 (in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate (1)$$43,218 $1,246 $44,464 
U.S. Treasury, government and agency15,231 15,231 
States and political subdivisions610 39 649 
Foreign governments490 490 
Residential mortgage-backed (2)173 173 
Asset-backed (3)744 100 844 
Redeemable preferred stock237 274 511 
Total fixed maturities, AFS237 60,740 1,385 62,362 
Other equity investments13 13 
Trading securities321 6,277 6,598 
Other invested assets:
Short-term investments468 468 
Assets of consolidated VIEs/VOEs16 16 
Swaps(326)(326)
Credit default swaps18 18 
Options3,331 3,331 
Total other invested assets3,491 16 3,507 
Cash equivalents1,155 1,155 
GMIB reinsurance contracts asset2,466 2,466 
Separate Accounts assets (4)121,184 2,878 124,062 
Total Assets$122,910 $73,386 $3,867 $200,163 
Liabilities:
GMxB derivative features’ liability$$$8,316 $8,316 
SCS, SIO, MSO and IUL indexed features’ liability3,150 3,150 
Total Liabilities$$3,150 $8,316 $11,466 
______________
(1)Corporate fixed maturities includes both public and private issues.
(2)Includes publicly traded agency pass-through securities and collateralized obligations.
(3)Includes credit-tranched securities collateralized by sub-prime mortgages and other asset types and credit tenant loans.
(4)Separate Accounts assets included in the fair value hierarchy exclude investments in entities that calculate NAV per share (or its equivalent) as a practical expedient. Such investments excluded from the fair value hierarchy include investments in real estate and commercial mortgages. At December 31, 2019 the fair value of such investments was $356 million.
Public Fixed Maturities
The fair values of the Company’s public fixed maturities are generally based on prices obtained from independent valuation service providers and for which the Company maintains a vendor hierarchy by asset type based on historical pricing experience and vendor expertise. Although each security generally is priced by multiple independent valuation service providers, the Company ultimately uses the price received from the independent valuation service provider highest in the vendor hierarchy based on the respective asset type, with limited exception. To validate reasonableness, prices also are internally reviewed by those with relevant expertise through comparison with directly observed recent market trades. Consistent with the fair value hierarchy, public fixed maturities validated in this manner generally are reflected within Level 2, as they are primarily based on observable pricing for similar assets and/or other market observable inputs.
40

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Private Fixed Maturities
The fair values of the Company’s private fixed maturities are determined from prices obtained from independent valuation service providers. Prices not obtained from an independent valuation service provider are determined by using a discounted cash flow model or a market comparable company valuation technique. In certain cases, these models use observable inputs with a discount rate based upon the average of spread surveys collected from private market intermediaries who are active in both primary and secondary transactions, taking into account, among other factors, the credit quality and industry sector of the issuer and the reduced liquidity associated with private placements. Generally, these securities have been reflected within Level 2. For certain private fixed maturities, the discounted cash flow model or a market comparable company valuation technique may also incorporate unobservable inputs, which reflect the Company’s own assumptions about the inputs market participants would use in pricing the asset. To the extent management determines that such unobservable inputs are significant to the fair value measurement of a security, a Level 3 classification generally is made.
Freestanding Derivative Positions
The net fair value of the Company’s freestanding derivative positions as disclosed in Note 4 are generally based on prices obtained either from independent valuation service providers or derived by applying market inputs from recognized vendors into industry standard pricing models. The majority of these derivative contracts are traded in the OTC derivative market and are classified in Level 2. The fair values of derivative assets and liabilities traded in the OTC market are determined using quantitative models that require use of the contractual terms of the derivative instruments and multiple market inputs, including interest rates, prices, and indices to generate continuous yield or pricing curves, including overnight index swap (“OIS”) curves, and volatility factors, which then are applied to value the positions. The predominance of market inputs is actively quoted and can be validated through external sources or reliably interpolated if less observable.
Level Classifications of the Company’s Financial Instruments
Financial Instruments Classified as Level 1
Investments classified as Level 1 primarily include redeemable preferred stock, trading securities, cash equivalents and Separate Accounts assets. Fair value measurements classified as Level 1 include exchange-traded prices of fixed maturities, equity securities and derivative contracts, and net asset values for transacting subscriptions and redemptions of mutual fund shares held by Separate Accounts. Cash equivalents classified as Level 1 include money market accounts, overnight commercial paper and highly liquid debt instruments purchased with an original maturity of three months or less and are carried at cost as a proxy for fair value measurement due to their short-term nature.
Financial Instruments Classified as Level 2
Investments classified as Level 2 are measured at fair value on a recurring basis and primarily include U.S. government and agency securities and certain corporate debt securities, such as public and private fixed maturities. As market quotes generally are not readily available or accessible for these securities, their fair value measures are determined utilizing relevant information generated by market transactions involving comparable securities and often are based on model pricing techniques that effectively discount prospective cash flows to present value using appropriate sector-adjusted credit spreads commensurate with the security’s duration, also taking into consideration issuer-specific credit quality and liquidity.
Observable inputs generally used to measure the fair value of securities classified as Level 2 include benchmark yields, reported secondary trades, issuer spreads, benchmark securities and other reference data. Additional observable inputs are used when available, and as may be appropriate, for certain security types, such as prepayment, default, and collateral information for the purpose of measuring the fair value of mortgage- and asset-backed securities. The Company’s AAA-rated mortgage- and asset-backed securities are classified as Level 2 for which the observability of market inputs to their pricing models is supported by sufficient, albeit more recently contracted, market activity in these sectors.
Certain Company products, such as the SCS and EQUI-VEST variable annuity products, IUL and the MSO fund available in some life contracts offer investment options which permit the contract owner to participate in the performance of an index, ETF or commodity price. These investment options, which depending on the product and on the index selected can currently have one, three, five or six year terms, provide for participation in the performance of specified indices, ETF or commodity price movement up to a segment-specific declared maximum rate. Under certain conditions that vary by product, e.g., holding these segments for the full term, these segments also shield policyholders
41

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
from some or all negative investment performance associated with these indices, ETF or commodity prices. These investment options have defined formulaic liability amounts, and the current values of the option component of these segment reserves are accounted for as Level 2 embedded derivatives. The fair values of these embedded derivatives are based on data obtained from independent valuation service providers.
Financial Instruments Classified as Level 3
The Company’s investments classified as Level 3 primarily include corporate debt securities, such as private fixed maturities and asset-backed securities. Determinations to classify fair value measures within Level 3 of the valuation hierarchy generally are based upon the significance of the unobservable factors to the overall fair value measurement. Included in the Level 3 classification are fixed maturities with indicative pricing obtained from brokers that otherwise could not be corroborated to market observable data.
The Company also issues certain benefits on its variable annuity products that are accounted for as derivatives and are also considered Level 3. The GMIBNLG feature allows the policyholder to receive guaranteed minimum lifetime annuity payments based on predetermined annuity purchase rates applied to the contract’s benefit base if and when the contract account value is depleted and the NLG feature is activated. The GMWB feature allows the policyholder to withdraw at minimum, over the life of the contract, an amount based on the contract’s benefit base. The GWBL feature allows the policyholder to withdraw, each year for the life of the contract, a specified annual percentage of an amount based on the contract’s benefit base. The GMAB feature increases the contract account value at the end of a specified period to a GMAB base. The GIB feature provides a lifetime annuity based on predetermined annuity purchase rates if and when the contract account value is depleted. This lifetime annuity is based on predetermined annuity purchase rates applied to a GIB base.
Level 3 also includes the GMIB reinsurance contract assets which are accounted for as derivative contracts. The GMIB reinsurance contract asset and liabilities’ fair value reflects the present value of reinsurance premiums and recoveries and risk margins over a range of market consistent economic scenarios while GMxB derivative features liability reflects the present value of expected future payments (benefits) less fees, adjusted for risk margins and nonperformance risk, attributable to GMxB derivative features’ liability over a range of market-consistent economic scenarios.
The valuations of the GMIB reinsurance contract asset and GMxB derivative features liability incorporate significant non-observable assumptions related to policyholder behavior, risk margins and projections of equity Separate Accounts funds. The credit risks of the counterparty and of the Company are considered in determining the fair values of its GMIB reinsurance contract asset and GMxB derivative features liability positions, respectively, after taking into account the effects of collateral arrangements. Incremental adjustment to the swap curve for non-performance risk is made to the fair values of the GMIB reinsurance contract asset and liabilities and GMIBNLG feature to reflect the claims-paying ratings of counterparties and the Company. Equity and fixed income volatilities were modeled to reflect current market volatilities. Due to the unique, long duration of the GMIBNLG feature, adjustments were made to the equity volatilities to remove the illiquidity bias associated with the longer tenors and risk margins were applied to the non-capital markets inputs to the GMIBNLG valuations.
After giving consideration to collateral arrangements, the Company reduced the fair value of its GMIB reinsurance contract asset by $263 million and $175 million at September 30, 2020 and December 31, 2019, respectively, to recognize incremental counterparty non-performance risk.
Lapse rates are adjusted at the contract level based on a comparison of the actuarial calculated guaranteed values and the current policyholder account value, which include other factors such as considering surrender charges. Generally, lapse rates are assumed to be lower in periods when a surrender charge applies. A dynamic lapse function reduces the base lapse rate when the guaranteed amount is greater than the account value as in the money contracts are less likely to lapse. For valuing the embedded derivative, lapse rates vary throughout the period over which cash flows are projected.
The Company’s consolidated VIEs/VOEs hold investments that are classified as Level 3, primarily corporate bonds that are vendor priced with no ratings available, bank loans, non-agency collateralized mortgage obligations and asset-backed securities.
Transfers of Financial Instruments Between Levels 2 and 3
During the nine months ended September 30, 2020, AFS fixed maturities with fair values of $103 million were transferred out of Level 3 and into Level 2 principally due to the availability of trading activity and/or market
42

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
observable inputs to measure and validate their fair values. In addition, AFS fixed maturities with fair value of $189 million were transferred from Level 2 into the Level 3 classification. These transfers in the aggregate represent approximately 2.0% of total equity at September 30, 2020.
During the nine months ended September 30, 2019, AFS fixed maturities with fair values of $104 million were transferred out of Level 3 and into Level 2 principally due to the availability of trading activity and/or market observable inputs to measure and validate their fair values. In addition, AFS fixed maturities with fair value of $14 million were transferred from Level 2 into the Level 3 classification. These transfers in the aggregate represent approximately 0.9% of total equity at September 30, 2019.
The tables below present reconciliations for all Level 3 assets and liabilities for the three and nine months ended September 30, 2020 and 2019, respectively.
Level 3 Instruments - Fair Value Measurements
CorporateState and Political SubdivisionsAsset-backed
(in millions)
Balance, July 1, 2020$1,652 $40 $0 
Total gains and (losses), realized and unrealized, included in:
Net income (loss) as:
Net investment income (loss)0 0 0 
Investment gains (losses), net(1)0 0 
Subtotal(1)0 0 
Other comprehensive income (loss)18 (1)0 
Purchases(138)0 13 
Sales(22)0 0 
Transfers into Level 3 (1)(30)0 0 
Transfers out of Level 3 (1)0 0 0 
Balance, September 30, 2020$1,479 $39 $13 
Balance, July 1, 2019$1,290 $39 $534 
Total gains and (losses), realized and unrealized, included in:
Net income (loss) as:
Net investment income (loss)
Investment gains (losses), net
Subtotal
Other comprehensive income (loss)(7)
Purchases(2)71 
Sales(42)(1)(73)
Transfers into Level 3 (1)
Transfers out of Level 3 (1)(31)
Balance, September 30, 2019$1,208 $39 $532 
______________
(1)Transfers into/out of the Level 3 classification are reflected at beginning-of-period fair values.
CorporateState and Political SubdivisionsAsset-backed
(in millions)
Balance, January 1, 2020$1,246 $39 $100 
Total gains and (losses), realized and unrealized, included in:
Net income (loss) as:
Net investment income (loss)2 0 0 
Investment gains (losses), net(14)0 0 
Subtotal(12)0 0 
43

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
CorporateState and Political SubdivisionsAsset-backed
(in millions)
Other comprehensive income (loss)(36)1 0 
Purchases207 0 13 
Sales(112)(1)0 
Transfers into Level 3 (1)189 0 0 
Transfers out of Level 3 (1)(3)0 (100)
Balance, September 30, 2020$1,479 $39 $13 
Balance, January 1, 2019$1,174 $38 $519 
Total gains and (losses), realized and unrealized, included in:
Net income (loss) as:
Net investment income (loss)
Investment gains (losses), net
Subtotal
Other comprehensive income (loss)
Purchases219 81 
Sales(101)(2)(73)
Transfers into Level 3 (1)14 
Transfers out of Level 3 (1)(104)
Balance, September 30, 2019$1,208 $39 $532 
______________
(1)Transfers into/out of the Level 3 classification are reflected at beginning-of-period fair values.
Other Equity InvestmentsGMIB Reinsurance Contract AssetSeparate Accounts AssetsGMxB Derivative Features Liability
(in millions)
Balance, July 1, 2020$16 $3,433 $0 $(12,458)
Realized and unrealized gains (losses), included in Net income (loss) as:
Investment gains (losses), net0 0 0 0 
Net derivative gains (losses) (1)0 (177)0 570 
Total realized and unrealized gains (losses)0 

(177)

0 

570 
Other comprehensive income (loss)0 0 0 0 
Purchases (2)3 11 0 (113)
Sales (3)0 (21)0 16 
Change in estimate (4)0 1 0 0 
Activity related to consolidated VIEs/VOEs(3)0 0 0 
Transfers into Level 3 (5)0 0 0 0 
Transfers out of Level 3 (5)0 0 0 0 
Balance, September 30, 2020$16 $3,247 $0 $(11,985)
Balance, July 1, 2019$16 $2,198 $25 $(6,813)
Realized and unrealized gains (losses), included in Net income (loss) as:
Investment gains (losses), net
Net derivative gains (losses)664 (2,535)
Total realized and unrealized gains (losses)0 

664 

0 

(2,535)
Other comprehensive income (loss)
Purchases (2)11 (5)(100)
44

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Sales (3)(20)(1)12 
Settlements(1)
Activity related to consolidated VIEs/VOEs
Transfers into Level 3 (5)
Transfers out of Level 3 (5)(11)
Balance, September 30, 2019$16 $2,853 $$(9,436)
______________
(1)The Company’s nonperformance risk impact of ($458) million for the GMxB derivative features liability and $6 million for the GMIB reinsurance contract asset the three months ended September 2020, respectively, is recorded through Net derivative gains (losses).
(2)For the GMIB reinsurance contract asset and GMxB derivative features liability, represents attributed fee.
(3)For the GMIB reinsurance contract asset, represents recoveries from reinsurers and for GMxB derivative features liability, represents benefits paid.
(4)For the GMIB reinsurance contract asset, represents a transfer from amounts due from reinsurers.
(5)Transfers into/out of the Level 3 classification are reflected at beginning-of-period fair values.
Other Equity InvestmentsGMIB Reinsurance Contract AssetSeparate Accounts AssetsGMxB Derivative Features Liability
(in millions)
Balance, January 1, 2020$16 $2,466 $0 $(8,316)
Realized and unrealized gains (losses), included in Net income (loss) as:
Investment gains (losses), net0 0 0 0 
Net derivative gains (losses) (1)0 849 0 (3,382)
Total realized and unrealized gains (losses)0 

849 

0 

(3,382)
Other comprehensive income (loss)0 
Purchases (2)4 34 0 (328)
Sales (3)0 (58)0 41 
Settlements0 0 0 0 
Change in estimate (4)0 (44)0 0 
Activity related to consolidated VIEs/VOEs(4)0 0 0 
Transfers into Level 3 (5)0 0 0 0 
Transfers out of Level 3 (5)0 0 0 0 
Balance, September 30, 2020$16 $3,247 $0 $(11,985)
Balance, January 1, 2019$48 $1,993 $21 $(5,491)
Realized and unrealized gains (losses), included in Net income (loss) as:
Investment gains (losses), net
Net derivative gains (losses)881 (3,656)
Total realized and unrealized gains (losses)881 (3,656)
Other comprehensive income (loss)
Purchases (2)34 (309)
Sales (3)(55)(1)20 
Settlements(4)
Activity related to consolidated VIEs/VOEs(3)
Transfers into Level 3 (5)
Transfers out of Level 3 (5)(29)(12)
Balance, September 30, 2019$16 $2,853 $$(9,436)
    ______________
45

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
(1)The Company’s nonperformance risk impact of $35 million for the GMxB derivative features liability and ($50) million for the GMIB reinsurance contract asset the nine months ended September 2020, respectively, is recorded through Net derivative gains (losses).
(2)For the GMIB reinsurance contract asset and GMxB derivative features liability, represents attributed fee.
(3)For the GMIB reinsurance contract asset, represents recoveries from reinsurers and for GMxB derivative features liability, represents benefits paid.
(4)For the GMIB reinsurance contract asset, represents a transfer from amounts due from reinsurers.
(5)Transfers into/out of the Level 3 classification are reflected at beginning-of-period fair values.
The table below details changes in unrealized gains (losses) for the nine months ended September 30, 2020 and 2019 by category for Level 3 assets and liabilities still held at September 30, 2020 and 2019, respectively.
Change in Unrealized Gains (Losses) for Level 3 Instruments
 Net Income (Loss)
 Investment Gains (Losses), NetNet Derivative Gains (Losses)OCI
(in millions)
Held at September 30, 2020:
Change in unrealized gains (losses):
Fixed maturities, AFS:
Corporate$0 $0 $(37)
State and political subdivisions0 0 2 
Total fixed maturities, AFS0 0 (35)
GMIB reinsurance contracts0 849 0 
GMxB derivative features liability0 (3,382)0 
Total$0 $(2,533)$(35)
Held at September 30, 2019:
Change in unrealized gains (losses):
Fixed maturities, AFS:
Corporate$$$
State and political subdivisions
Asset-backed
Total fixed maturities, AFS10 
GMIB reinsurance contracts881 
Separate Account assets(14)
GMxB derivative features liability(3,656)
Total$(14)$(2,775)$10 
Quantitative and Qualitative Information about Level 3 Fair Value Measurements
The following tables disclose quantitative information about Level 3 fair value measurements by category for assets and liabilities at September 30, 2020 and December 31, 2019, respectively.
Quantitative Information about Level 3 Fair Value Measurements at September 30, 2020
Fair
Value
Valuation Technique
Significant
Unobservable Input
RangeWeighted Average (2)
(in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate$25Matrix pricing 
model
Spread over Benchmark270 - 610 bps288 bps
1,105Market 
comparable 
companies
EBITDA multiples
Discount rate
Cash flow multiples
3.5x-31.8x
5.1% - 25.4%
0.9x -25.0x
14.4x
10.0%
10.7x
46

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Fair
Value
Valuation Technique
Significant
Unobservable Input
RangeWeighted Average (2)
(in millions)
Other equity investments4Market  comparable  companiesRevenue multiple3.5x - 18.0x9.5x
GMIB reinsurance contract asset3,247Discounted cash flowNon-performance risk
Lapse rates
Withdrawal rates
Utilization rates
Volatility rates - Equity
Mortality Rates (1):
Ages 0 - 40
Ages 41 - 60
Ages 61 - 115
60 - 125 bps
0.6%-16%
0%-2%
0%-61%
16%-34%

0.01%-0.18%
0.07%-0.54%
0.42%-42.20%
72 bps
1.56%
0.96%
6.37%
25%

2.72%
(same for all ages)
(same for all ages)
Liabilities:
GMIBNLG11,682Discounted cash flowNon-performance risk
Lapse rates
Withdrawal rates
Annuitization rates
Mortality Rates (1):
Ages 0 - 40
Ages 41 - 60
Ages 61 - 115
141.0 bps
1.1%-25.7%
0.4%-2%
0%-100%

0.01%-0.19%
0.06%-0.53%
0.41%-41.39%

3.06%
0.96%
5.92%

1.48%
(same for all ages)
(same for all ages)
GWBL/GMWB220Discounted cash flowNon-performance risk
Lapse rates
Withdrawal rates
Utilization rates
Volatility rates - Equity
141.0 bps
0.8%-16%
0%-8%
100% once starting
16%-34%

1.56%
0.96%

24.57%
GIB77Discounted cash flowNon-performance risk
Lapse rates
Withdrawal rates
Utilization rates
Volatility rates - Equity
141.0 bps
0.8%-15.6%
0%-2%
0%-100%
16%-34%

1.56%
0.96%
6.37%
25%
GMAB6Discounted cash flowNon-performance risk
Lapse rates
Volatility rates - Equity
141.0 bps
0.8%-16%
16%-34%

1.56%
25%
    ______________
(1)Mortality rates vary by age and demographic characteristic such as gender. Mortality rate assumptions are based on a combination of company and industry experience. A mortality improvement assumption is also applied. For any given contract, mortality rates vary throughout the period over which cash flows are projected for purposes of valuating the embedded derivatives.
(2)For Lapses, Withdrawals, and Utilizations the rates were weighted by counts, for Mortality weighted average rates are shown for all ages combined and for Withdrawals the weighted averages were based on an estimated split of partial withdrawal and dollar-for-dollar withdrawals.
Quantitative Information about Level 3 Fair Value Measurements at December 31, 2019
Fair
Value
Valuation Technique
Significant
Unobservable Input
RangeWeighted Average
(in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate$51 Matrix pricing modelSpread over benchmark65 - 580 bps186 bps
1,025 Market comparable companiesEBITDA multiples
Discount rate
Cash flow multiples
3.3x - 56.7x
3.9% - 16.5%
0.8x - 48.1x
14.3x
10.0%
10.7x
47

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
GMIB reinsurance contract asset2,466 Discounted cash flowNon-performance risk
Lapse rates
Withdrawal rates
Utilization rates
Volatility rates - Equity
Mortality rates (1):
Ages 0 - 40
Ages 41 - 60
Ages 60 - 115
55 - 109 bps
0.8% - 10%
0.0% - 8.0%
0.0% - 49.0%
9.0% - 30.0%

0.01% - 0.18%
0.07% - 0.54%
0.42% - 42.20%
Liabilities:
GMIBNLG8,135 Discounted cash flowNon-performance risk
Lapse rates
Withdrawal rates
Annuitization rates

Mortality rates (1):
Ages 0 - 40
Ages 41 - 60
Ages 60 - 115
124 bps
0.8% - 19.9%
0.3% - 11.0%
0.0% - 100.0%


0.01% - 0.19%
0.06% - 0.53%
0.41% - 41.39%
GWBL/GMWB172 Discounted cash flowNon-performance risk
Lapse rates
Withdrawal rates
Utilization rates
Volatility rates - Equity
124 bps
0.8% - 10.0%
0.0% - 7.0%
100% after starting
9.0% - 30.0%
GIBDiscounted cash flowNon-performance risk
Lapse rates
Withdrawal rates
Utilization rates
Volatility rates - Equity
124 bps
1.2% - 19.9%
0.0% - 8.0%
0.0% - 100.0%
9.0% - 30.0%
GMABDiscounted cash flowLapse rates
Volatility rates - Equity
1.0% - 10.0%
9.0% - 30.0%
______________
(1)Mortality rates vary by age and demographic characteristic such as gender. Mortality rate assumptions are based on a combination of company and industry experience. A mortality improvement assumption is also applied. For any given contract, mortality rates vary throughout the period over which cash flows are projected for purposes of valuating the embedded derivatives.
Level 3 Financial Instruments for which Quantitative Inputs are Not Available
Certain Privately Placed Debt Securities with Limited Trading Activity
Excluded from the tables above at September 30, 2020 and December 31, 2019, respectively, are approximately $417 million and $325 million of Level 3 fair value measurements of investments for which the underlying quantitative inputs are not developed by the Company and are not readily available. These investments primarily consist of certain privately placed debt securities with limited trading activity, including residential mortgage- and asset-backed instruments, and their fair values generally reflect unadjusted prices obtained from independent valuation service providers and indicative, non-binding quotes obtained from third-party broker-dealers recognized as market participants. Significant increases or decreases in the fair value amounts received from these pricing sources may result in the Company’s reporting significantly higher or lower fair value measurements for these Level 3 investments.
The fair value of private placement securities is determined by application of a matrix pricing model or a market comparable company value technique. The significant unobservable input to the matrix pricing model valuation technique is the spread over the industry-specific benchmark yield curve. Generally, an increase or decrease in spreads would lead to directionally inverse movement in the fair value measurements of these securities. The significant unobservable input to the market comparable company valuation technique is the discount rate. Generally, a significant increase (decrease) in the discount rate would result in significantly lower (higher) fair value measurements of these securities.
Residential mortgage-backed securities classified as Level 3 primarily consist of non-agency paper with low trading activity. Included in the tables above at September 30, 2020 and December 31, 2019, there were no Level 3 securities that were determined by application of a matrix pricing model and for which the spread over the U.S. Treasury curve is the most significant unobservable input to the pricing result. Generally, a change in spreads would lead to directionally inverse movement in the fair value measurements of these securities.
Asset-backed securities classified as Level 3 primarily consist of non-agency mortgage loan trust certificates, including subprime and Alt-A paper, credit tenant loans, and equipment financings. Included in the tables
48

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
above at September 30, 2020 and December 31, 2019, there were no securities that were determined by the application of matrix-pricing for which the spread over the U.S. Treasury curve is the most significant unobservable input to the pricing result. Significant increases (decreases) in spreads would have resulted in significantly lower (higher) fair value measurements.
GMIB Reinsurance Contract Asset and GMxB Derivative Features Liability
Significant unobservable inputs with respect to the fair value measurement of the Level 3 GMIB reinsurance contract asset and the Level 3 liabilities identified in the table above are developed using the Company data.
The significant unobservable inputs used in the fair value measurement of the Company’s GMIB reinsurance contract asset are lapse rates, withdrawal rates and GMIB utilization rates. Significant increases in GMIB utilization rates or decreases in lapse or withdrawal rates in isolation would tend to increase the GMIB reinsurance contract asset.
Fair value measurement of the GMIB reinsurance contract asset and liabilities includes dynamic lapse and GMIB utilization assumptions whereby projected contractual lapses and GMIB utilization reflect the projected net amount of risks of the contract. As the net amount of risk of a contract increases, the assumed lapse rate decreases and the GMIB utilization increases. Increases in volatility would increase the asset and liabilities.
The significant unobservable inputs used in the fair value measurement of the Company’s GMIBNLG liability are lapse rates, withdrawal rates, GMIB utilization rates, adjustment for Non-performance risk and NLG forfeiture rates. NLG forfeiture rates are caused by excess withdrawals above the annual GMIB accrual rate that cause the NLG to expire. Significant decreases in lapse rates, NLG forfeiture rates, adjustment for non-performance risk and GMIB utilization rates would tend to increase the GMIBNLG liability, while decreases in withdrawal rates and volatility rates would tend to decrease the GMIBNLG liability.
The significant unobservable inputs used in the fair value measurement of the Company’s GMWB and GWBL liability are lapse rates and withdrawal rates. Significant increases in withdrawal rates or decreases in lapse rates in isolation would tend to increase these liabilities. Increases in volatility would increase these liabilities.
Carrying Value of Financial Instruments Not Otherwise Disclosed in Note 3 and Note 4
The carrying values and fair values at September 30, 2020 and December 31, 2019 for financial instruments not otherwise disclosed in Note 3 and Note 4 are presented in the table below.
Carrying Values and Fair Values for Financial Instruments Not Otherwise Disclosed
 
Carrying
Value
Fair Value
 Level 1Level 2Level 3Total
(in millions)
September 30, 2020:
Mortgage loans on real estate$12,785 $0 $0 $13,032 $13,032 
Policy loans$3,647 $0 $0 $4,726 $4,726 
Loans to affiliates$1,200 $0 $1,241 $0 $1,241 
Policyholders’ liabilities: Investment contracts$2,063 $0 $0 $2,280 $2,280 
FHLB funding agreements (1)$6,848 $0 $6,940 $0 $6,940 
FABN funding agreements (2)$1,143 $0 $1,168 $0 $1,168 
Separate Accounts liabilities$9,000 $0 $0 $9,000 $9,000 
December 31, 2019:
Mortgage loans on real estate$12,090 $$$12,317 $12,317 
Policy loans$3,270 $$$4,199 $4,199 
Loans to affiliates$1,200 $$1,224 $$1,224 
Policyholders’ liabilities: Investment contracts$1,922 $$$2,029 $2,029 
FHLB funding agreements (1)$6,909 $$6,957 $$6,957 
Separate Accounts liabilities$9,041 $$$9,041 $9,041 
_____________
(1)Federal Home Loan Bank of New York (“FHLB”)
49

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
(2)Funding Agreement Backed Notes Program (“FABN”)
(3)Excludes amounts reclassified as Held-for-Sale.

Mortgage Loans on Real Estate
Accrued interest receivable on commercial and agricultural mortgage loans as of September 30, 2021 was $30 million and $29 million, respectively. There was no accrued interest written off for commercial and agricultural mortgage loans for the three and nine months ended September 30, 2021.
As of September 30, 2021, the Company had no loans for which foreclosure was probable included within the individually assessed mortgage loans, and accordingly had no associated allowance for credit losses.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Allowance for Credit Losses on Mortgage Loans
The change in the allowance for credit losses for commercial mortgage loans and agricultural mortgage loans during the three and nine months ended September 30, 2021 and 2020 were as follows:
Three Months Ended September 30,Nine Months Ended September 30,
2021202020212020
(in millions)
Allowance for credit losses on mortgage loans:
Commercial mortgages:
Balance, beginning of period$59 $62 $77 $33 
Current-period provision for expected credit losses1 (17)33 
Write-offs charged against the allowance —  0
Recoveries of amounts previously written off —  0
Net change in allowance1 (17)33 
Balance, end of period$60 $66 $60 $66 
Agricultural mortgages:
Balance, beginning of period$4 $$4 $
Current-period provision for expected credit losses —  
Write-offs charged against the allowance ���  — 
Recoveries of amounts previously written off —  — 
Net change in allowance —  
Balance, end of period$4 $$4 $
Total allowance for credit losses$64 $70 $64 $70 

The change in the allowance for credit losses is attributable to:
increases/decreases in the loan balance due to new originations, maturing mortgages, and loan amortization;
changes in credit quality; and
changes in market assumptions primarily related to COVID-19 driven economic changes.
Credit Quality Information
The following tables summarize the Company’s mortgage loans segregated by risk rating exposure as of September 30, 2021 and December 31, 2020.







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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
LTV Ratios (1)
September 30, 2021
Amortized Cost Basis by Origination Year
20212020201920182017PriorTotal
(in millions)
Mortgage loans:
Commercial:
0% - 50%$ $1 $ $184 $324 $910 $1,419 
50% - 70%1,286 1,265 390 619 492 2,853 6,905 
70% - 90%97 320 413 451 275 748 2,304 
90% plus   12 5 207 224 
Total commercial$1,383 $1,586 $803 $1,266 $1,096 $4,718 $10,852 
Agricultural:
0% - 50%$113 $215 $130 $131 $133 $774 $1,496 
50% - 70%174 270 105 134 88 359 1,130 
70% - 90%     17 17 
90% plus       
Total agricultural$287 $485 $235 $265 $221 $1,150 $2,643 
Total mortgage loans:
0% - 50%$113 $216 $130 $315 $457 $1,684 $2,915 
50% - 70%1,460 1,535 495 753 580 3,212 8,035 
70% - 90%97 320 413 451 275 765 2,321 
90% plus   12 5 207 224 
Total mortgage loans$1,670 $2,071 $1,038 $1,531 $1,317 $5,868 $13,495 

Debt Service Coverage Ratios (2)
September 30, 2021
Amortized Cost Basis by Origination Year
20212020201920182017PriorTotal
(in millions)
Mortgage loans:
Commercial:
Greater than 2.0x$705 $1,276 $328 $772 $408 $2,194 $5,683 
1.8x to 2.0x132 136 233 93 269 385 1,248 
1.5x to 1.8x183 115 167 223 166 825 1,679 
1.2x to 1.5x64 59 75 54 253 838 1,343 
1.0x to 1.2x299   88  255 642 
Less than 1.0x   36  221 257 
Total commercial$1,383 $1,586 $803 $1,266 $1,096 $4,718 $10,852 
Agricultural:
Greater than 2.0x$37 $66 $25 $16 $33 $217 $394 
1.8x to 2.0x38 37 26 21 14 74 210 
1.5x to 1.8x50 114 29 28 44 198 463 
1.2x to 1.5x122 180 114 117 73 375 981 
1.0x to 1.2x40 84 32 78 56 247 537 
Less than 1.0x 4 9 5 1 39 58 
Total agricultural$287 $485 $235 $265 $221 $1,150 $2,643 
Total mortgage loans:
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
September 30, 2021
Amortized Cost Basis by Origination Year
20212020201920182017PriorTotal
(in millions)
Greater than 2.0x$742 $1,342 $353 $788 $441 $2,411 $6,077 
1.8x to 2.0x170 173 259 114 283 459 1,458 
1.5x to 1.8x233 229 196 251 210 1,023 2,142 
1.2x to 1.5x186 239 189 171 326 1,213 2,324 
1.0x to 1.2x339 84 32 166 56 502 1,179 
Less than 1.0x 4 9 41 1 260 315 
Total mortgage loans$1,670 $2,071 $1,038 $1,531 $1,317 $5,868 $13,495 
_____________
(1)The LTV ratio is derived from current loan balance divided by the fair value of the property. The fair value of the underlying commercial properties is updated annually for each mortgage loan.
(2)The DSC ratio is calculated using the most recently reported operating income results from property operations divided by annual debt service.
LTV Ratios (1)
December 31, 2020
Amortized Cost Basis by Origination Year
20202019201820172016PriorTotal
(in millions)
Mortgage loans:
Commercial:
0% - 50%$— $— $— $324 $170 $505 $999 
50% - 70%1,294 357 803 656 2,190 1,697 6,997 
70% - 90%321 457 452 219 203 538 2,190 
90% plus— — 12 — 288 305 
Total commercial$1,615 $814 $1,267 $1,204 $2,563 $3,028 $10,491 
Agricultural:
0% - 50%$218 $135 $169 $157 $236 $652 $1,567 
50% - 70%277 129 161 102 124 351 1,144 
70% - 90%— — — — 18 21 
90% plus— — — — — — — 
Total agricultural$495 $264 $333 $259 $360 $1,021 $2,732 
Total mortgage loans:
0% - 50%$218 $135 $169 $481 $406 $1,157 $2,566 
50% - 70%1,571 486 964 758 2,314 2,048 8,141 
70% - 90%321 457 455 219 203 556 2,211 
90% plus— — 12 — 288 305 
Total mortgage loans$2,110 $1,078 $1,600 $1,463 $2,923 $4,049 $13,223 











27

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Debt Service Coverage Ratios (2)
December 31, 2020
Amortized Cost Basis by Origination Year
20202019201820172016PriorTotal
(in millions)
Mortgage loans:
Commercial:
Greater than 2.0x$1,230 $492 $772 $268 $1,942 $1,230 $5,934 
1.8x to 2.0x227 83 118 378 184 329 1,319 
1.5x to 1.8x98 138 187 479 437 616 1,955 
1.2x to 1.5x60 57 154 79 — 658 1,008 
1.0x to 1.2x— 44 — — — 123 167 
Less than 1.0x— — 36 — — 72 108 
Total commercial$1,615 $814 $1,267 $1,204 $2,563 $3,028 $10,491 
Agricultural:
Greater than 2.0x$67 $26 $36 $38 $71 $167 $405 
1.8x to 2.0x38 35 14 15 20 82 204 
1.5x to 1.8x117 38 41 45 52 209 502 
1.2x to 1.5x183 120 141 90 142 313 989 
1.0x to 1.2x86 35 93 70 57 233 574 
Less than 1.0x10 18 17 58 
Total agricultural$495 $264 $333 $259 $360 $1,021 $2,732 
Total mortgage loans:
Greater than 2.0x$1,297 $518 $808 $306 $2,013 $1,397 $6,339 
1.8x to 2.0x265 118 132 393 204 411 1,523 
1.5x to 1.8x215 176 228 524 489 825 2,457 
1.2x to 1.5x243 177 295 169 142 971 1,997 
1.0x to 1.2x86 79 93 70 57 356 741 
Less than 1.0x10 44 18 89 166 
Total mortgage loans$2,110 $1,078 $1,600 $1,463 $2,923 $4,049 $13,223 
_____________
(1)The LTV ratio is derived from current loan balance divided by the fair value of the property. The fair value of the underlying commercial properties is updated annually for each mortgage loan.
(2)The DSC ratio is calculated using the most recently reported operating income results from property operations divided by annual debt service.
The following tables provide information relating to the LTV and DSC ratios for commercial and agricultural mortgage loans as of September 30, 2021 and December 31, 2020. The values used in these ratio calculations were developed as part of the periodic review of the commercial and agricultural mortgage loan portfolio, which includes an evaluation of the underlying collateral value.










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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued

Mortgage Loans by LTV and DSC Ratios
 DSC Ratio (2) (3)
LTV Ratio (1) (3):Greater than 2.0x1.8x to 2.0x1.5x to 1.8x1.2x to 1.5x1.0x to 1.2xLess than 1.0xTotal
 (in millions)
September 30, 2021:
Mortgage loans:
Commercial:
0% - 50%$860 $ $390 $31 $40 $98 $1,419 
50% - 70%4,026 680 993 755 421 30 6,905 
70% - 90%797 568 210 492 181 56 2,304 
90% plus  86 65  73 224 
Total commercial$5,683 $1,248 $1,679 $1,343 $642 $257 $10,852 
Agricultural:
0% - 50%$289 $98 $283 $501 $296 $29 $1,496 
50% - 70%105 110 180 480 241 14 1,130 
70% - 90% 2    15 17 
90% plus       
Total agricultural$394 $210 $463 $981 $537 $58 $2,643 
Total mortgage loans:
0% - 50%$1,149 $98 $673 $532 $336 $127 $2,915 
50% - 70%4,131 790 1,173 1,235 662 44 8,035 
70% - 90%797 570 210 492 181 71 2,321 
90% plus  86 65  73 224 
Total mortgage loans$6,077 $1,458 $2,142 $2,324 $1,179 $315 $13,495 
December 31, 2020:
Mortgage loans:
Commercial:
0% - 50%$839 $— $160 $— $— $— $999 
50% - 70%4,095 870 1,452 555 25 — 6,997 
70% - 90%844 449 343 376 142 36 2,190 
90% plus156 — — 77 — 72 305 
Total commercial$5,934 $1,319 $1,955 $1,008 $167 $108 $10,491 
Agricultural:
0% - 50%$297 $108 $291 $520 $317 $34 $1,567 
50% - 70%108 94 211 450 257 24 1,144 
70% - 90%— — 19 — — 21 
90% plus— — — — — — — 
Total agricultural$405 $204 $502 $989 $574 $58 $2,732 
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
 DSC Ratio (2) (3)
LTV Ratio (1) (3):Greater than 2.0x1.8x to 2.0x1.5x to 1.8x1.2x to 1.5x1.0x to 1.2xLess than 1.0xTotal
 (in millions)
Total mortgage loans:
0% - 50%$1,136 $108 $451 $520 $317 $34 $2,566 
50% - 70%4,203 964 1,663 1,005 282 24 8,141 
70% - 90%844 451 343 395 142 36 2,211 
90% plus156 — — 77 — 72 305 
Total mortgage loans$6,339 $1,523 $2,457 $1,997 $741 $166 $13,223 
______________
(1)The LTV ratio is derived from current loan balance divided by the fair value of the property. The fair value of the underlying commercial properties is updated annually for each mortgage loan.
(2)The DSC ratio is calculated using the most recently reported operating income results from property operations divided by annual debt service.
(3)Amounts presented at amortized cost basis.
Past-Due and Nonaccrual Mortgage Loan Status
The following table provides information relating to the aging analysis of past-due mortgage loans as of September 30, 2021 and December 31, 2020, respectively:
Age Analysis of Past Due Mortgage Loans (1)
Accruing LoansNon-accruing LoansTotal LoansNon-accruing Loans with No AllowanceInterest Income on Non-accruing Loans
Past DueCurrentTotal
30-59 Days
60-89
Days
90
Days
or  More
Total
(in millions)
September 30, 2021:
Mortgage loans:
Commercial$ $ $ $ $10,852 $10,852 $ $10,852 $ $ 
Agricultural8 3 66 77 2,566 2,643  2,643   
Total$8 $3 $66 $77 $13,418 $13,495 $ $13,495 $ $ 
December 31, 2020:
Mortgage loans:
Commercial$162 $— $— $162 $10,329 $10,491 $— $10,491 $— $— 
Agricultural76 29 112 2,620 2,732 — 2,732 — — 
Total$238 $$29 $274 $12,949 $13,223 $— $13,223 $— $— 
_______________
(1)Amounts presented at amortized cost basis.

As of September 30, 2021 and December 31, 2020, the carrying values of problem mortgage loans that had been classified as non-accrual loans were $0 million and $0 million, respectively.
Troubled Debt Restructuring
There were no privately negotiated fixed maturity modifications accounted for as a TDR during the three months ended September 30, 2021. During the nine months ended September 30, 2021, the Company had 1 new privately negotiated fixed maturity TDR with a pre-modification cost basis of $9 million and post-modification carrying value of $4 million. This TDR did not have subsequent payment defaults nor additional commitments to lend. The 1 privately negotiated fixed maturity TDR is 0.004% of the Company’s total invested assets. There were no mortgage loan on real estate modifications accounted for as a TDR during three and nine months ended September 30, 2021.

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued

During the three and nine months ended September 30, 2020, the Company had 2 and 6 new privately negotiated fixed maturity TDRs with a pre-modification cost basis of $8 million and $50 million and post-modification carrying value of $7 million and $44 million, respectively. These TDRs did not have subsequent payment defaults nor additional commitments to lend. The 6 privately negotiated fixed maturity TDRs were 0.04% of the Company’s total invested assets. During the three and nine months ended September 30, 2020, there was 1 commercial mortgage loan on real estate accounted for as a TDR with pre-modification cost basis of $75 million and post-modification carrying value of $75 million. The 1 commercial mortgage loan TDR was 0.07% of the Company’s total invested assets.
Equity Securities
The table below presents a breakdown of unrealized and realized gains and (losses) on equity securities during the three and nine months ended September 30, 2021.
Unrealized and Realized Gains (Losses) from Equity Securities (1)
Three Months Ended September 30,Nine Months Ended September 30,
20212021
(in millions)
Net investment gains (losses) recognized during the period on securities held at the end of the period$(1)$19 
Net investment gains (losses) recognized on securities sold during the period(3)1 
Unrealized and realized gains (losses) on equity securities$(4)$20 
______________     
(1) Effective January 1, 2021, certain preferred stock have been reclassified to other equity investments (see Note 2 Significant Accounting Policies – Investments).
Trading Securities
As of September 30, 2021 and December 31, 2020, respectively, the fair value of the Company’s trading securities was $409 million and $5.3 billion. As of September 30, 2021 and December 31, 2020, respectively, trading securities included the General Account’s investment in Separate Accounts, which had carrying values of $43 million and $43 million.
The table below shows a breakdown of net investment income (loss) from trading securities during the three and nine months ended September 30, 2021 and 2020:
Net Investment Income (Loss) from Trading Securities
Three Months Ended September 30,Nine Months Ended September 30,
2021202020212020
(in millions)
Net investment gains (losses) recognized during the period on securities held at the end of the period$(47)$(1)$(264)$86 
Net investment gains (losses) recognized on securities sold during the period40 (5)215 12 
Unrealized and realized gains (losses) on trading securities(7)(6)(49)98 
Interest and dividend income from trading securities4 58 80 152 
Net investment income (loss) from trading securities$(3)$52 $31 $250 

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
4)    DERIVATIVES
The Company uses derivatives as part of its overall asset/liability risk management primarily to reduce exposures to equity market and interest rate risks. Derivative hedging strategies are designed to reduce these risks from an economic perspective and are all executed within the framework of a “Derivative Use Plan” approved by applicable states’ insurance law. Derivatives are generally not accounted for using hedge accounting, with the exception of TIPS, which is discussed further below. Operation of these hedging programs is based on models involving numerous estimates and assumptions, including, among others, mortality, lapse, surrender and withdrawal rates, election rates, fund performance, market volatility and interest rates. A wide range of derivative contracts are used in these hedging programs, including exchange traded equity, currency and interest rate futures contracts, total return and/or other equity swaps, interest rate swap and floor contracts, bond and bond-index total return swaps, swaptions, variance swaps and equity options, credit and foreign exchange derivatives, as well as bond and repo transactions to support the hedging. The derivative contracts are collectively managed in an effort to reduce the economic impact of unfavorable changes in guaranteed benefits’ exposures attributable to movements in capital markets. In addition, as part of its hedging strategy, the Company targets an asset level for all variable annuity products at or above a CTE98 level under most economic scenarios (CTE is a statistical measure of tail risk which quantifies the total asset requirement to sustain a loss if an event outside a given probability level has occurred. CTE98 denotes the financial resources a company would need to cover the average of the worst 2% of scenarios.)
Derivatives Utilized to Hedge Exposure to Variable Annuities with Guarantee Features
The Company has issued and continues to offer variable annuity products with GMxB features. The risk associated with the GMDB feature is that under-performance of the financial markets could result in GMDB benefits, in the event of death, being higher than what accumulated policyholders’ account balances would support. The risk associated with the GMIB feature is that under-performance of the financial markets could result in the present value of GMIB, in the event of annuitization, being higher than what accumulated policyholders’ account balances would support, taking into account the relationship between current annuity purchase rates and the GMIB guaranteed annuity purchase rates. The risk associated with products that have a GMxB derivative features liability is that under-performance of the financial markets could result in the GMxB derivative features’ benefits being higher than what accumulated policyholders’ account balances would support.
For GMxB features, the Company retains certain risks including basis, credit spread and some volatility risk and risk associated with actual experience versus expected actuarial assumptions for mortality, lapse and surrender, withdrawal and policyholder election rates, among other things. The derivative contracts are managed to correlate with changes in the value of the GMxB features that result from financial markets movements. A portion of exposure to realized equity volatility is hedged using equity options and variance swaps and a portion of exposure to credit risk is hedged using total return swaps on fixed income indices. Additionally, the Company is party to total return swaps for which the reference U.S. Treasury securities are contemporaneously purchased from the market and sold to the swap counterparty. As these transactions result in a transfer of control of the U.S. Treasury securities to the swap counterparty, the Company derecognizes these securities with consequent gain or loss from the sale. The Company has also purchased reinsurance contracts to mitigate the risks associated with GMDB features and the impact of potential market fluctuations on future policyholder elections of GMIB features contained in certain annuity contracts issued by the Company. The reinsurance of the GMIB features is accounted for as a derivative. In addition, on June 1, 2021, we ceded legacy variable annuity policies sold by the Company between 2006-2008 (the “Block”), comprised of non-New York “Accumulator” policies containing fixed rate GMIB and/or GMDB guarantees. As this contract provides full risk transfer, the benefits of this treaty are accounted for in the same manner as the underlying gross reserves and therefore the Amounts Due from Reinsurers related to the GMIB with NLG are accounted for as an embedded derivative.
The Company has in place an economic hedge program using interest rate swaps and U.S. Treasury futures to partially protect the overall profitability of future variable annuity sales against declining interest rates.
Derivatives Utilized to Hedge Crediting Rate Exposure on SCS, SIO, MSO and IUL Products/Investment Options
The Company hedges crediting rates in the SCS variable annuity, SIO in the EQUI-VEST variable annuity series, MSO in the variable life insurance products and IUL insurance products. These products permit the contract owner to participate in the performance of an index, ETF or commodity price movement up to a cap for a set period of time. They also contain a protection feature, in which the Company will absorb, up to a certain percentage, the loss of value in an index, ETF or commodity price, which varies by product segment.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
In order to support the returns associated with these features, the Company enters into derivative contracts whose payouts, in combination with fixed income investments, emulate those of the index, ETF or commodity price, subject to caps and buffers, thereby substantially reducing any exposure to market-related earnings volatility.
Derivatives Used to Hedge Equity Market Risks Associated with the General Account’s Seed Money Investments in Retail Mutual Funds
The Company’s General Account seed money investments in retail mutual funds expose us to market risk, including equity market risk which is partially hedged through equity-index futures contracts to minimize such risk.
Derivatives Used to Hedge ULSG Policy
The Company implemented a hedge program using fixed income total return swaps to mitigate the interest rate exposure in the ULSG policy statutory liability.
Derivatives Used for General Account Investment Portfolio
The Company maintains a strategy in its General Account investment portfolio to replicate the credit exposure of fixed maturity securities otherwise permissible for investment under its investment guidelines through the sale of CDS. Under the terms of these swaps, the Company receives quarterly fixed premiums that, together with any initial amount paid or received at trade inception, replicate the credit spread otherwise currently obtainable by purchasing the referenced entity’s bonds of similar maturity. These credit derivatives generally have remaining terms of five years or less and are recorded at fair value with changes in fair value, including the yield component that emerges from initial amounts paid or received, reported in net derivative gains (losses).
The Company manages its credit exposure taking into consideration both cash and derivatives based positions and selects the reference entities in its replicated credit exposures in a manner consistent with its selection of fixed maturities. In addition, the Company generally transacts the sale of CDS in single name reference entities of investment grade credit quality and with counterparties subject to collateral posting requirements. If there is an event of default by the reference entity or other such credit event as defined under the terms of the swap contract, the Company is obligated to perform under the credit derivative and, at its option, either pay the referenced amount of the contract less an auction-determined recovery amount or pay the referenced amount of the contract and receive in return the defaulted or similar security of the reference entity for recovery by sale at the contract settlement auction. The Company purchased CDS to mitigate its exposure to a reference entity through cash positions. These positions do not replicate credit spreads.
To date, there have been no events of default or circumstances indicative of a deterioration in the credit quality of the named referenced entities to require or suggest that the Company will have to perform under the CDS that it sold. The maximum potential amount of future payments the Company could be required to make under the credit derivatives sold is limited to the par value of the referenced securities which is the dollar or euro-equivalent of the derivative’s notional amount. The Standard North American CDS Contract or Standard European Corporate Contract under which the Company executes these CDS sales transactions does not contain recourse provisions for recovery of amounts paid under the credit derivative.
The Company purchased 30-year TIPS and other sovereign bonds, both inflation-linked and non-inflation linked, as General Account investments and enters into asset or cross-currency basis swaps, to result in payment of the given bond’s coupons and principal at maturity in the bond’s specified currency to the swap counterparty in return for fixed dollar amounts. These swaps, when considered in combination with the bonds, together result in a net position that is intended to replicate a dollar-denominated fixed-coupon cash bond with a yield higher than a term-equivalent U.S. Treasury bond.
Derivatives Utilized to Hedge Exposure to Foreign Currency Denominated Cash Flows

The Company purchases private placement debt securities and issues funding agreements in the FABN program in currencies other than its functional US dollar currency. The Company enters into cross currency swaps with external counterparties to hedge the exposure of the foreign currency denominated cash flows of these instruments. The foreign currency received from or paid to the cross currency swap counterparty is exchanged for fixed US dollar amounts with improved net investment yields or net product costs over equivalent US dollar denominated instruments issued at that time. The transactions are accounted for as cash flow hedges when they are designated in hedging relationships and qualify for hedge accounting. The first cross currency swap hedges were designated and applied hedge accounting during the quarter ended June 30, 2021.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued

These cross currency swaps are for the period the foreign currency denominated private placement debt securities and funding agreement are outstanding, with the longest cross currency swap expiring in 2033. Since designation and qualification as cash flow hedges, cross currency swap interest accruals are recognized in Net investment income and in Interest credited to policyholders’ account balances.
The tables below present quantitative disclosures about the Company’s derivative instruments designated in hedging relationships and derivative instruments which have not been designated in hedging relationships, including those embedded in other contracts required to be accounted for as derivative instruments.
The following table presents the gross notional amount and estimated fair value of the Company’s derivatives:
Derivative Instruments by Category
September 30, 2021December 31, 2020
 Fair ValueFair Value
 Notional
Amount
Derivative AssetsDerivative
Liabilities
Notional
Amount
Derivative AssetsDerivative
Liabilities
(in millions)
 Derivatives: Designated for hedge accounting (1)
 Cash flow hedges:
 Currency swaps$807 $8 $33 $— $— $— 
 Interest swaps958  335 957 — 219 
 Total: designated for hedge accounting1,765 8 368 957 — 219 
 Derivatives: Not designated for hedge accounting (1)
Equity contracts:
Futures (5)3,107   4,267   
Swaps (5)12,879 4  22,404 — 
Options55,382 10,394 4,505 35,786 8,383 3,715 
Interest rate contracts:
Futures (5)10,999   18,161 — — 
Swaps (5)2,861  243 22,816 551 434 
Swaptions   — — — 
Credit contracts:
Credit default swaps781 4 3 919 
Currency contracts:
Currency swaps516 3  347 — — 
Currency forwards   — — — 
Other contracts:
Margin 90  — 26 66 
Collateral 157 6,092 — 212 3,835 
 Total: Not designated for hedge accounting86,525 10,652 10,843 104,700 9,186 8,051 
Embedded derivatives:
Amounts due from reinsurers (6) 5,869  — — — 
GMIB reinsurance contracts (2) 2,156  — 2,859 — 
GMxB derivative features liability (3)  8,938 — — 10,936 
SCS, SIO, MSO and IUL indexed features (4)  5,446 — — 4,378 
 Total embedded derivatives 8,025 14,384 — 2,859 15,314 
Total derivative instruments$88,290 $18,685 $25,595 $105,657 $12,045 $23,584 
______________
(1)Reported in other invested assets in the consolidated balance sheets.
(2)    Reported in GMIB reinsurance contract asset in the consolidated balance sheets.
(3)    Reported in future policy benefits and other policyholders’ liabilities in the consolidated balance sheets.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
(4)    Reported in policyholders’ account balances in the consolidated balance sheets.
(5)    Decrease in futures and swaps notional as of September 30, 2021 primarily due to the Venerable transaction (see Note 1 Organization).
(6)    Represents GMIB NLG ceded related to the Venerable transaction.

The following table presents the effects of derivative instruments on the consolidated statements of income and comprehensive income (loss).

Three Months Ended September 30, 2021Nine Months Ended September 30, 2021
 
 Net
Derivatives
Gain(Losses) (1) (2)
Net Investment IncomeInterest Credited To Policyholders Account BalancesAOCINet
Derivatives
Gain(Losses) (1) (2)
Net Investment IncomeInterest Credited To Policyholders Account BalancesAOCI
(in millions)
Derivatives: Designated for hedge accounting
Cash flow hedges:
Currency swaps$ $ $(15)$7 $ $ $(32)$7 
Interest swaps(26)  (9)(54)  (42)
Total: Designated for hedge accounting(26) (15)(2)(54) (32)(35)
Derivatives: Not designated for hedge accounting
Equity contracts:
Futures(6)   (466)   
Swaps(3)   (2,609)   
Options(169)   2,175    
Interest rate contracts:
Futures(92)   (888)   
Swaps67    (2,375)   
Swaptions        
Credit contracts:
Credit default swaps    2    
Currency contracts:
Currency swaps3    3    
Currency forwards        
Other contracts:
Margin        
Collateral        
Total: Not designated for hedge accounting(200)   (4,158)   
Embedded derivatives:
Amounts due from reinsurers344    586    
GMIB reinsurance contracts(128)   (694)   
GMxB derivative features liability(395)   2,291    
SCS, SIO, MSO and IUL indexed features173    (2,113)   
Total embedded derivatives(6)   70    
Total Derivatives$(232)$ $(15)$(2)$(4,142)$ $(32)$(35)

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued




Three Months Ended September 30, 2020Nine Months Ended September 30, 2020
 
 Net
Derivatives
Gain(Losses) (1) (2)
Net Investment IncomeInterest Credited To Policyholders Account BalancesAOCINet
Derivatives
Gain(Losses) (1) (2)
Net Investment IncomeInterest Credited To Policyholders Account BalancesAOCI
(in millions)
Derivatives: Designated for hedge accounting
Cash flow hedges:
Interest swaps$(12)$— $— $(65)$(4)$— $— $(64)
Total: Designated for hedge accounting(12)— — (65)(4)— — (64)
Derivatives: Not designated for hedge accounting
Equity contracts:
Futures(221)— — — (347)— — — 
Swaps(1,557)— — — (594)— — — 
Options907 — — — (480)— — — 
Interest rate contracts:
Futures(14)— — — 2,058 — — — 
Swaps(59)— — — 3,592 — — — 
Swaptions— — — — — — — 
Credit contracts:
Credit default swaps— — — (4)— — — 
Currency contracts:
Currency swaps— — — — — — — — 
Currency forwards— — — — (3)— — — 
Other contracts:
Margin— — — — — — — — 
Collateral— — — — — — — — 
Total: Not designated for hedge accounting(941)— — — 4,231 — — — 
Embedded derivatives:
Amounts due from reinsurers— — — — — — — — 
GMIB reinsurance contracts(177)— — — 849 — — — 
GMxB derivative features liability570 — — — (3,382)— — — 
SCS, SIO, MSO and IUL indexed features(967)— — — 410 — — — 
Total embedded derivatives(574)— — — (2,123)— — — 
Total Derivatives$(1,527)$— $— $(65)$2,104 $— $— $(64)
______________
(1)Reported in net derivative gains (losses) in the consolidated statements of income (loss).
(2)For the three and nine months ended September 30, 2021 and 2020, investment fees of $4 million and $10 million , $3 million and $9 million respectively, are reported in net derivative gains (losses) in the consolidated statements of income (loss).


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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
The table that follow below present a roll-forward of cash flow hedges recognized in AOCI.
Rollforward of Cash flow hedges in AOCI

Three Months Ended September 30,Nine Months Ended September 30,
2021202020212020
(in millions)
Balance, beginning of period$(158)$$(126)$(38)
Amount recorded in AOCI —  — 
Currency Swaps7 — 7 — 
Interest Swaps(40)(81)(118)(46)
Total Amount recorded in AOCI(33)(81)(111)(46)
Amount reclassified from AOCI to income —  — 
Currency Swaps —  — 
Interest Swaps31 16 77 20 
Total Amount reclassified from AOCI to income31 16 77 20 
Ending Balance, September 30 (1)$(160)$(64)$(160)$(64)
______________
(1) The Company does not estimate the amount of the deferred losses in AOCI at three and nine months ended September 30, 2021 and 2020 which will be released and reclassified into Net income (loss) over the next 12 months as the amounts cannot be reasonably estimated.
Equity-Based and Treasury Futures Contracts Margin
All outstanding equity-based and treasury futures contracts as of September 30, 2021 and December 31, 2020 are exchange-traded and net settled daily in cash. As of September 30, 2021 and December 31, 2020, respectively, the Company had open exchange-traded futures positions on: (i) the S&P 500, Nasdaq, Russell 2000 and Emerging Market indices, having initial margin requirements of $150 million and $135 million, (ii) the 2-year, 5-year and 10-year U.S. Treasury Notes on U.S. Treasury bonds and ultra-long bonds, having initial margin requirements of $116 million and $263 million, and (iii) the Euro Stoxx, FTSE 100, Topix, ASX 200 and EAFE indices as well as corresponding currency futures on the Euro/U.S. dollar, Pound/U.S. dollar, Australian dollar/U.S. dollar, and Yen/U.S. dollar, having initial margin requirements of $16 million and $35 million.
Collateral Arrangements
The Company generally has executed a CSA under the ISDA Master Agreement it maintains with each of its OTC derivative counterparties that requires both posting and accepting collateral either in the form of cash or high-quality securities, such as U.S. Treasury securities, U.S. government and government agency securities and investment grade corporate bonds. The Company nets the fair value of all derivative financial instruments with counterparties for which an ISDA Master Agreement and related CSA have been executed. As of September 30, 2021 and December 31, 2020, respectively, the Company held $6,092 million and $3.8 billion in cash and securities collateral delivered by trade counterparties, representing the fair value of the related derivative agreements. The unrestricted cash collateral is reported in other invested assets. The Company posted collateral of $157 million and $212 million as of September 30, 2021 and December 31, 2020, respectively, in the normal operation of its collateral arrangements.
The following tables presents information about the Company’s offsetting of financial assets and liabilities and derivative instruments as of September 30, 2021 and December 31, 2020:







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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Offsetting of Financial Assets and Liabilities and Derivative Instruments
As of September 30, 2021
Gross Amount RecognizedGross Amount Offset in the Balance SheetsNet Amount Presented in the Balance SheetsGross Amount not Offset in the Balance Sheets (1)Net Amount
(in millions)
Assets:
Derivative assets$10,660 $9,750 $910 $(817)$93 
Other financial assets1,429  1,429  1,429 
Other invested assets$12,089 $9,750 $2,339 $(817)$1,522 
Liabilities:
Derivative liabilities$10,393 $9,750 $643 $ $643 
Other financial liabilities1,867  1,867  1,867 
Other liabilities$12,260 $9,750 $2,510 $ $2,510 
______________
(1)Financial instruments sent (held).
As of December 31, 2020
Gross Amount RecognizedGross Amount Offset in the Balance SheetsNet Amount Presented in the Balance SheetsGross Amount not Offset in the Balance Sheets (1)Net Amount
(in millions)
Assets:
Derivative assets$9,186 $8,206 $980 $(53)$927 
Other financial assets1,403 — 1,403 — 1,403 
Other invested assets$10,589 $8,206 $2,383 $(53)$2,330 
Liabilities:
Derivative liabilities$8,218 $8,206 $12 $— $12 
Other financial liabilities1,568 — 1,568 — 1,568 
Other liabilities$9,786 $8,206 $1,580 $— $1,580 
______________
(1)Financial instruments sent (held).

5)    CLOSED BLOCK
As a result of demutualization, the Company’s Closed Block was established in 1992 for the benefit of certain individual participating policies that were in force on that date. Assets, liabilities and earnings of the Closed Block are specifically identified to support its participating policyholders.
Assets allocated to the Closed Block inure solely to the benefit of the Closed Block policyholders and will not revert to the benefit of the Company. No reallocation, transfer, borrowing or lending of assets can be made between the Closed Block and other portions of the Company’s General Account, any of its Separate Accounts or any affiliate of the Company without the approval of the New York State Department of Financial Services (the “NYDFS”). Closed Block assets and liabilities are carried on the same basis as similar assets and liabilities held in the General Account. For more information on the Closed Block, see Note 5 to the Company’s consolidated financial statements included in the Annual Report on Form 10-K for the year ended December 31, 2020.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued

Summarized financial information for the Company’s Closed Block is as follows:
 September 30, 2021December 31, 2020
(in millions)
Closed Block Liabilities:
Future policy benefits, policyholders’ account balances and other$6,022 $6,201 
Policyholder dividend obligation25 160 
Other liabilities40 39 
Total Closed Block liabilities6,087 6,400 
Assets Designated to the Closed Block:
Fixed maturities AFS, at fair value (amortized cost of $3,283 and $3,359) (allowance for credit losses of $0)3,537 3,718 
Mortgage loans on real estate (net of allowance for credit losses of $5 and $6)1,770 1,773 
Policy loans615 648 
Cash and other invested assets18 28 
Other assets98 169 
Total assets designated to the Closed Block6,038 6,336 
Excess of Closed Block liabilities over assets designated to the Closed Block49 64 
Amounts included in AOCI:
Net unrealized investment gains (losses), net of policyholders’ dividend obligation: $25 and $160; and net of income tax: $(48) and $(42)191 167 
Maximum future earnings to be recognized from Closed Block assets and liabilities$240 $231 

The Company’s Closed Block revenues and expenses were as follows:
Three Months Ended September 30,Nine Months Ended September 30,
2021202020212020
(in millions)
Revenues:
Premiums and other income$33 $36 $109 $118 
Net investment income (loss)59 61 179 190 
Investment gains (losses), net 2 (1)
Total revenues92 98 290 307 
Benefits and Other Deductions:
Policyholders’ benefits and dividends108 96 304 302 
Other operating costs and expenses2 — 3 
Total benefits and other deductions110 96 307 303 
Net income (loss), before income taxes(18)(17)
Income tax (expense) benefit(2)(1)(3)(2)
Net income (loss)$(20)$$(20)$

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
A reconciliation of the Company’s policyholder dividend obligation follows:
Three Months Ended September 30,Nine Months Ended September 30,
2021202020212020
(in millions)
Beginning balance$72 $$160 $
Unrealized investment gains (losses)(47)— (135)— 
Ending balance$25 $$25 $

6)    INSURANCE LIABILITIES
Variable Annuity Contracts – GMDB, GMIB, GIB and GWBL and Other Features
The Company has certain variable annuity contracts with GMDB, GMIB, GIB and GWBL and other features in-force that guarantee one of the following:
Return of Premium: the benefit is the greater of current account value or premiums paid (adjusted for withdrawals);
Ratchet: the benefit is the greatest of current account value, premiums paid (adjusted for withdrawals), or the highest account value on any anniversary up to contractually specified ages (adjusted for withdrawals);
Roll-Up: the benefit is the greater of current account value or premiums paid (adjusted for withdrawals) accumulated at contractually specified interest rates up to specified ages;
Combo: the benefit is the greater of the ratchet benefit or the roll-up benefit, which may include either a five year or an annual reset; or
Withdrawal: the withdrawal is guaranteed up to a maximum amount per year for life.

Liabilities for Variable Annuity Contracts with GMDB and GMIB Features without NLG Rider Feature
The change in the liabilities for variable annuity contracts with GMDB and GMIB features and without a NLG feature are summarized in the tables below. The amounts for the direct contracts (before reinsurance ceded) and assumed contracts are reflected in the consolidated balance sheets in future policy benefits and other policyholders’ liabilities. The amounts for the ceded contracts are reflected in the consolidated balance sheets in amounts due from reinsurers. The amounts for the ceded IB are reflected in the consolidated balance sheets in GMIB reinsurance contract asset, at fair value.
Change in Liability for Variable Annuity Contracts with GMDB and GMIB Features and No NLG Feature
Three and Nine Months Ended September 30, 2021 and 2020

GMDBGMIB
DirectCededDirectCeded
(in millions)
Balance, July 1, 2021$5,140 $(2,281)$5,945 $(4,444)
Paid guarantee benefits(104)42 (87)15 
Other changes in reserve7 (3)152 126 
Impact of the Venerable transaction (1)    
Balance, September 30, 2021$5,043 $(2,242)$6,010 $(4,303)
Balance, July 1, 2020$4,998 $(99)$6,121 $(3,433)
Paid guarantee benefits(121)(110)21 
Other changes in reserve235 113 165 
Balance, September 30, 2020$5,112 $(87)$6,124 $(3,247)
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued

GMDBGMIB
DirectCededDirectCeded
(in millions)
Balance, January 1, 2021$5,093 $(84)$6,025 $(2,859)
Paid guarantee benefits(351)65 (271)41 
Other changes in reserve301 (47)256 656 
Impact of the Venerable transaction (1) (2,176) (2,141)
Balance, September 30, 2021$5,043 $(2,242)$6,010 $(4,303)
Balance, January 1, 2020$4,775 $(99)$4,671 $(2,466)
Paid guarantee benefits(372)12 (287)58 
Other changes in reserve709 — 1,740 (839)
Balance, September 30, 2020$5,112 $(87)$6,124 $(3,247)
____________
(1)Includes the impact as of June 1, 2021 on the ceded reserves to Venerable. See Note 1- Organization, for details of the Venerable transaction.
Liabilities for Embedded and Freestanding Insurance Related Derivatives
The liability for the GMxB derivative features, the liability for SCS, SIO, MSO and IUL indexed features and the asset and liability for the GMIB reinsurance contracts and amounts due from reinsurers related to GMIB NLG product features (GMIB NLG Reinsurance) are considered embedded or freestanding insurance derivatives and are reported at fair value. For the fair value of the assets and liabilities associated with these embedded or freestanding insurance derivatives, see Note 7 Fair Value Disclosures.
Account Values and Net Amount at Risk
Account Values and NAR for direct variable annuity contracts in force with GMDB and GMIB features as of September 30, 2021 are presented in the following tables by guarantee type. For contracts with the GMDB feature, the NAR in the event of death is the amount by which the GMDB feature exceeds the related Account Values. For contracts with the GMIB feature, the NAR in the event of annuitization is the amount by which the present value of the GMIB benefits exceed the related Account Values, taking into account the relationship between current annuity purchase rates and the GMIB guaranteed annuity purchase rates. Since variable annuity contracts with GMDB features may also offer GMIB guarantees in the same contract, the GMDB and GMIB amounts listed are not mutually exclusive.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Direct Variable Annuity Contracts with GMDB and GMIB Features
as of September 30, 2021
Guarantee Type
Return of PremiumRatchetRoll-UpComboTotal
(in millions, except age and interest rate)
Variable annuity contracts with GMDB features
Account Values invested in:
General Account$16,038$85$52$161$16,336
Separate Accounts57,0639,6093,32533,862103,859
Total Account Values$73,101$9,694$3,377$34,023$120,195
NAR, gross$104$80$1,441$16,473$18,098
NAR, net of amounts reinsured$102$71$1,013$8,394$9,580
Average attained age of policyholders (in years)51.568.875.470.655.4
Percentage of policyholders over age 7011.6%50.6%72.0%56.5%20.7%
Range of contractually specified interest ratesN/AN/A3% - 6%3% - 6.5%3% - 6.5%
Variable annuity contracts with GMIB features
Account Values invested in:
General Account$$$15$210$225
Separate Accounts25,50536,15261,657
Total Account Values$$$25,520$36,362$61,882
NAR, gross$$$693$9,492$10,185
NAR, net of amounts reinsured$$$223$3,896$4,119
Average attained age of policyholders (in years)N/AN/A64.870.768.5
Weighted average years remaining until annuitizationN/AN/A5.80.62.6
Range of contractually specified interest ratesN/AN/A3% - 6%3% - 6.5%3% - 6.5%


For more information about the reinsurance programs of the Company’s GMDB and GMIB exposure, see “Reinsurance” in Note 10 of the 2020 Form 10-K.
Separate Accounts Investments by Investment Category Underlying Variable Annuity Contracts with GMDB and GMIB Features
The total Account Values of variable annuity contracts with GMDB and GMIB features include amounts allocated to the guaranteed interest option, which is part of the General Account and variable investment options that invest through Separate Accounts in variable insurance trusts. The following table presents the aggregate fair value of assets, by major investment category, held by Separate Accounts that support variable annuity contracts with GMDB and GMIB features. The investment performance of the assets impacts the related Account Values and, consequently, the NAR associated with the GMDB and GMIB benefits and guarantees. Because the Company’s variable annuity contracts offer both GMDB and GMIB features, GMDB and GMIB amounts are not mutually exclusive.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Investment in Variable Insurance Trust Mutual Funds
 September 30, 2021December 31, 2020
Mutual Fund TypeGMDBGMIBGMDBGMIB
 (in millions)
Equity$50,042 $19,261 $46,850 $18,771 
Fixed income5,448 2,569 5,506 2,701 
Balanced47,332 39,562 47,053 39,439 
Other1,037 265 1,111 275 
Total$103,859 $61,657 $100,520 $61,186 

Hedging Programs for GMDB, GMIB, GIB and Other Features
The Company has a program intended to hedge certain risks associated first with the GMDB feature and with the GMIB feature of the Accumulator series of variable annuity products. The program has also been extended to cover other guaranteed benefits as they have been made available. This program utilizes derivative contracts, such as exchange-traded equity, currency and interest rate futures contracts, total return and/or equity swaps, interest rate swap and floor contracts, swaptions, variance swaps as well as equity options, that collectively are managed in an effort to reduce the economic impact of unfavorable changes in guaranteed benefits’ exposures attributable to movements in the capital markets. At the present time, this program hedges certain economic risks on products sold from 2001 forward, to the extent such risks are not externally reinsured.
These programs do not qualify for hedge accounting treatment. Therefore, gains (losses) on the derivatives contracts used in these programs, including current period changes in fair value, are recognized in net derivative gains (losses) in the period in which they occur, and may contribute to income (loss) volatility.
Variable and Interest-Sensitive Life Insurance Policies - NLG
The NLG feature contained in variable and interest-sensitive life insurance policies keeps them in force in situations where the policy value is not sufficient to cover monthly charges then due. The NLG remains in effect so long as the policy meets a contractually specified premium funding test and certain other requirements.
The change in the NLG liabilities, reflected in future policy benefits and other policyholders’ liabilities in the consolidated balance sheets, is summarized in the table below.
20212020
Direct LiabilityReinsurance CededNetDirect LiabilityReinsurance CededNet
(in millions)
Balance, July 1,$1,064 $(909)$155 $941 $(841)$100 
Paid guarantee benefits(24) (24)(6)— (6)
Other changes in reserves38 (11)27 61 (31)30 
Balance, September 30,$1,078 $(920)$158 $996 $(872)$124 
Balance, January 1,$1,016 $(883)$133 $894 $(808)$86 
Paid guarantee benefits(52) (52)(32)— (32)
Other changes in reserves114 (37)77 134 (64)70 
Balance, September 30,$1,078 $(920)$158 $996 $(872)$124 
7)    REINSURANCE
The Company assumes and cedes reinsurance with other insurance companies. The Company evaluates the financial condition of its reinsurers to minimize its exposure to significant losses from reinsurer insolvencies. Ceded reinsurance does not relieve the originating insurer of liability.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
On June 1, 2021, Holdings completed the sale of CSLRC to VIAC. Immediately following the closing of the Transaction, CSLRC and Equitable Financial entered into the Reinsurance Agreement, pursuant to which Equitable Financial ceded to CSLRC, on a combined coinsurance and modified coinsurance basis, legacy variable annuity policies sold by Equitable Financial between 2006-2008. See Note 1- Organization for details of the Venerable transactions.
The following table summarizes the effect of reinsurance. The impact of the reinsurance transaction described above results in an increase in reinsurance ceded.
Three Months Ended September 30,Nine Months Ended September 30,
2021202020212020
(in millions)
Direct premiums$195 $175 $579 $575 
Reinsurance assumed47 45 136 145 
Reinsurance ceded(61)(42)(141)(107)
Premiums$181 $178 $574 $613 
Direct charges and fee income$986 $945 $2,095 $1,997 
Reinsurance ceded(175)(92)486 585 
Policy charges and fee income$811 $853 $2,581 $2,582 
Direct policyholders’ benefits$793 $1,006 $2,782 $4,419 
Reinsurance assumed57 52 172 177 
Reinsurance ceded(142)(108)(571)(329)
Policyholders’ benefits$708 $950 $2,383 $4,267 
Ceded Reinsurance
As of September 30, 2021 and December 31, 2020, the Company had reinsured with non-affiliates in the aggregate approximately 47.1% and 2.6%, respectively, of its current exposure to the GMDB obligation on annuity contracts in-force and, subject to certain maximum amounts or caps in any one period, approximately 59.6% and 13.4% of its current liability exposure, respectively, resulting from the GMIB feature. For additional information, see Note 6.
The following table summarizes the ceded reinsurance GMIB reinsurance contracts, third-party recoverables and amount due to reinsurance.
 September 30, 2021December 31, 2020
(in millions)
Ceded Reinsurance:
Estimated net fair values of ceded GMIB reinsurance contracts, considered derivatives (1)$2,156 $2,859 
Third-party reinsurance recoverables related to insurance contracts12,566 2,245 
Top reinsurers:
Venerable Insurance and Annuity Company (BBB+ SAP rating)10,440 N/A
Zurich Life Insurance Company, Ltd. (AA- SAP rating)1,340 1,421 
Third-party reinsurance payables related to insurance contracts202 113 
Top reinsurers:
Venerable Insurance and Annuity Company129 N/A
______________
(1)The estimated fair values increased $(134) million, $(186) million, $(703) million and $781 million for the three and nine months ended September 30, 2021 and 2020, respectively.
8)    FAIR VALUE DISCLOSURES
U.S. GAAP establishes a fair value hierarchy that requires an entity to maximize the use of observable inputs and minimize the use of unobservable inputs when measuring fair value, and identifies three levels of inputs that may be used to measure fair value:
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Notes to Consolidated Financial Statements (Unaudited), Continued
Level 1    Unadjusted quoted prices for identical instruments in active markets. Level 1 fair values generally are supported by market transactions that occur with sufficient frequency and volume to provide pricing information on an ongoing basis.
Level 2    Observable inputs other than Level 1 prices, such as quoted prices for similar instruments, quoted prices in markets that are not active, and inputs to model-derived valuations that are directly observable or can be corroborated by observable market data.
Level 3    Unobservable inputs supported by little or no market activity and often requiring significant management judgment or estimation, such as an entity’s own assumptions about the cash flows or other significant components of value that market participants would use in pricing the asset or liability.
The Company uses unadjusted quoted market prices to measure fair value for those instruments that are actively traded in financial markets. In cases where quoted market prices are not available, fair values are measured using present value or other valuation techniques. The fair value determinations are made at a specific point in time, based on available market information and judgments about the financial instrument, including estimates of the timing and amount of expected future cash flows and the credit standing of counterparties. Such adjustments do not reflect any premium or discount that could result from offering for sale at one time the Company’s entire holdings of a particular financial instrument, nor do they consider the tax impact of the realization of unrealized gains or losses. In many cases, the fair value cannot be substantiated by direct comparison to independent markets, nor can the disclosed value be realized in immediate settlement of the instrument.
Management is responsible for the determination of the value of investments carried at fair value and the supporting methodologies and assumptions. Under the terms of various service agreements, the Company often utilizes independent valuation service providers to gather, analyze, and interpret market information and derive fair values based upon relevant methodologies and assumptions for individual securities. These independent valuation service providers typically obtain data about market transactions and other key valuation model inputs from multiple sources and, through the use of widely accepted valuation models, provide a single fair value measurement for individual securities for which a fair value has been requested. As further described below with respect to specific asset classes, these inputs include, but are not limited to, market prices for recent trades and transactions in comparable securities, benchmark yields, interest rate yield curves, credit spreads, quoted prices for similar securities, and other market-observable information, as applicable. Specific attributes of the security being valued also are considered, including its term, interest rate, credit rating, industry sector, and when applicable, collateral quality and other security- or issuer-specific information. When insufficient market observable information is available upon which to measure fair value, the Company either will request brokers knowledgeable about these securities to provide a non-binding quote or will employ internal valuation models. Fair values received from independent valuation service providers and brokers and those internally modeled or otherwise estimated are assessed for reasonableness.
Assets and Liabilities Measured at Fair Value on a Nonrecurring Basis
Fair value measurements are required on a non-recurring basis for certain assets only when an impairment or other events occur. For the periods ended September 30, 2021 and December 31, 2020, no assets or liabilities were required to be measured at fair value on a non-recurring basis.
Assets and Liabilities Measured at Fair Value on a Recurring Basis
Assets and liabilities measured at fair value on a recurring basis are summarized below.

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Fair Value Measurements as of September 30, 2021
Level 1Level 2Level 3Total
 (in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate (1)$ $46,012 $1,440 $47,452 
U.S. Treasury, government and agency 15,083  15,083 
States and political subdivisions 541 37 578 
Foreign governments 1,003  1,003 
Residential mortgage-backed (2) 98  98 
Asset-backed (3) 5,561 5 5,566 
Commercial mortgage-backed 1,864 10 1,874 
Redeemable preferred stock 54  54 
Total fixed maturities, AFS 70,216 1,492 71,708 
Other equity investments307 392 5 704 
Trading securities214 195  409 
Other invested assets:
Short-term investments 3  3 
Assets of consolidated VIEs/VOEs  11 11 
Swaps (596) (596)
Credit default swaps 1  1 
Options 5,889  5,889 
Total other invested assets 5,297 

11 

5,308 
Cash equivalents424 259  683 
Amounts due from reinsurer (5)  5,869 5,869 
GMIB reinsurance contracts asset  2,156 2,156 
Separate Accounts assets (4)135,764 2,555  138,319 
Total Assets$136,709 $78,914 $9,533 $225,156 
Liabilities:
GMxB derivative features’ liability$ $ $8,938 $8,938 
SCS, SIO, MSO and IUL indexed features’ liability 5,446  5,446 
Total Liabilities$ $5,446 $8,938 $14,384 
______________
(1)Corporate fixed maturities includes both public and private issues.
(2)Includes publicly traded agency pass-through securities and collateralized obligations.
(3)Includes credit-tranched securities collateralized by sub-prime mortgages, credit risk transfer securities and other asset types.
(4)Separate Accounts assets included in the fair value hierarchy exclude investments in entities that calculate NAV per share (or its equivalent) as a practical expedient. Such investments excluded from the fair value hierarchy include investments in real estate. As of September 30, 2021 the fair value of such investments was $379 million.
(5)This represents GMIB NLG ceded reserves related to Venerable transaction. See Note 1- Organization for details of the Venerable transaction.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Fair Value Measurements as of December 31, 2020
Level 1Level 2Level 3Total
 (in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate (1)$— $51,415 $1,687 $53,102 
U.S. Treasury, government and agency— 15,943 — 15,943 
States and political subdivisions— 535 39 574 
Foreign governments— 1,103 — 1,103 
Residential mortgage-backed (2)— 131 — 131 
Asset-backed (3)— 3,636 20 3,656 
Commercial mortgage-backed— 1,203 — 1,203 
Redeemable preferred stock402 239 — 641 
Total fixed maturities, AFS402 74,205 1,746 76,353 
Other equity investments13 — 15 
Trading securities285 5,055 — 5,340 
Other invested assets:
Short-term investments— 82 83 
Assets of consolidated VIEs/VOEs— — 12 12 
Swaps— (96)— (96)
Credit default swaps— — 
Options— 4,668 — 4,668 
Total other invested assets— 4,661 13 4,674 
Cash equivalents1,183 287 — 1,470 
GMIB reinsurance contracts asset— — 2,859 2,859 
Separate Accounts assets (4)130,106 2,668 132,775 
Total Assets$131,989 $86,876 $4,621 $223,486 
Liabilities:
GMxB derivative features’ liability$— $— $10,936 $10,936 
SCS, SIO, MSO and IUL indexed features’ liability— 4,378 — 4,378 
Total Liabilities$— $4,378 $10,936 $15,314 
______________
(1)Corporate fixed maturities includes both public and private issues.
(2)Includes publicly traded agency pass-through securities and collateralized obligations.
(3)Includes credit-tranched securities collateralized by sub-prime mortgages and other asset types and credit tenant loans.
(4)Separate Accounts assets included in the fair value hierarchy exclude investments in entities that calculate NAV per share (or its equivalent) as a practical expedient. Such investments excluded from the fair value hierarchy include investments in real estate and commercial mortgages. As of December 31, 2020 the fair value of such investments was $356 million.
Public Fixed Maturities
The fair values of the Company’s public fixed maturities are generally based on prices obtained from independent valuation service providers and for which the Company maintains a vendor hierarchy by asset type based on historical pricing experience and vendor expertise. Although each security generally is priced by multiple independent valuation service providers, the Company ultimately uses the price received from the independent valuation service provider highest in the vendor hierarchy based on the respective asset type, with limited exception. To validate reasonableness, prices also are internally reviewed by those with relevant expertise through comparison with directly observed recent market trades. Consistent with the fair value hierarchy, public fixed maturities validated in this manner generally are reflected within Level 2, as they are primarily based on observable pricing for similar assets and/or other market observable inputs.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Private Fixed Maturities
The fair values of the Company’s private fixed maturities are determined from prices obtained from independent valuation service providers. Prices not obtained from an independent valuation service provider are determined by using a discounted cash flow model or a market comparable company valuation technique. In certain cases, these models use observable inputs with a discount rate based upon the average of spread surveys collected from private market intermediaries who are active in both primary and secondary transactions, taking into account, among other factors, the credit quality and industry sector of the issuer and the reduced liquidity associated with private placements. Generally, these securities have been reflected within Level 2. For certain private fixed maturities, the discounted cash flow model or a market comparable company valuation technique may also incorporate unobservable inputs, which reflect the Company’s own assumptions about the inputs market participants would use in pricing the asset. To the extent management determines that such unobservable inputs are significant to the fair value measurement of a security, a Level 3 classification generally is made.
Freestanding Derivative Positions
The net fair value of the Company’s freestanding derivative positions as disclosed in Note 4 are generally based on prices obtained either from independent valuation service providers or derived by applying market inputs from recognized vendors into industry standard pricing models. The majority of these derivative contracts are traded in the OTC derivative market and are classified in Level 2. The fair values of derivative assets and liabilities traded in the OTC market are determined using quantitative models that require use of the contractual terms of the derivative instruments and multiple market inputs, including interest rates, prices, and indices to generate continuous yield or pricing curves, including overnight index swap curves, and volatility factors, which then are applied to value the positions. The predominance of market inputs is actively quoted and can be validated through external sources or reliably interpolated if less observable.
Level Classifications of the Company’s Financial Instruments
Financial Instruments Classified as Level 1
Investments classified as Level 1 primarily include redeemable preferred stock, trading securities, cash equivalents and Separate Accounts assets. Fair value measurements classified as Level 1 include exchange-traded prices of fixed maturities, equity securities and derivative contracts, and net asset values for transacting subscriptions and redemptions of mutual fund shares held by Separate Accounts. Cash equivalents classified as Level 1 include money market accounts, overnight commercial paper and highly liquid debt instruments purchased with an original maturity of three months or less and are carried at cost as a proxy for fair value measurement due to their short-term nature.
Financial Instruments Classified as Level 2
Investments classified as Level 2 are measured at fair value on a recurring basis and primarily include U.S. government and agency securities and certain corporate debt securities, such as public and private fixed maturities. As market quotes generally are not readily available or accessible for these securities, their fair value measures are determined utilizing relevant information generated by market transactions involving comparable securities and often are based on model pricing techniques that effectively discount prospective cash flows to present value using appropriate sector-adjusted credit spreads commensurate with the security’s duration, also taking into consideration issuer-specific credit quality and liquidity.
Observable inputs generally used to measure the fair value of securities classified as Level 2 include benchmark yields, reported secondary trades, issuer spreads, benchmark securities and other reference data. Additional observable inputs are used when available, and as may be appropriate, for certain security types, such as prepayment, default, and collateral information for the purpose of measuring the fair value of mortgage- and asset-backed securities. The Company’s AAA-rated mortgage- and asset-backed securities are classified as Level 2 for which the observability of market inputs to their pricing models is supported by sufficient, albeit more recently contracted, market activity in these sectors.
Certain Company products, such as the SCS, EQUI-VEST variable annuity products, IUL and the MSO fund available in some life contracts offer investment options which permit the contract owner to participate in the performance of an index, ETF or commodity price. These investment options, which depending on the product and on the index selected can currently have one, three, five or six year terms, provide for participation in the performance of specified indices, ETF or commodity price movement up to a segment-specific declared maximum rate. Under certain conditions that vary by product, e.g., holding these segments for the full term, these segments also shield policyholders from some or
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
all negative investment performance associated with these indices, ETF or commodity prices. These investment options have defined formulaic liability amounts, and the current values of the option component of these segment reserves are classified as Level 2 embedded derivatives. The fair values of these embedded derivatives are based on data obtained from independent valuation service providers.
Financial Instruments Classified as Level 3
The Company’s investments classified as Level 3 primarily include corporate debt securities, such as private fixed maturities and asset-backed securities. Determinations to classify fair value measures within Level 3 of the valuation hierarchy generally are based upon the significance of the unobservable factors to the overall fair value measurement. Included in the Level 3 classification are fixed maturities with indicative pricing obtained from brokers that otherwise could not be corroborated to market observable data.
The Company also issues certain benefits on its variable annuity products that are accounted for as derivatives and are also considered Level 3. The GMIBNLG feature allows the policyholder to receive guaranteed minimum lifetime annuity payments based on predetermined annuity purchase rates applied to the contract’s benefit base if and when the contract account value is depleted and the NLG feature is activated. The GMWB feature allows the policyholder to withdraw at minimum, over the life of the contract, an amount based on the contract’s benefit base. The GWBL feature allows the policyholder to withdraw, each year for the life of the contract, a specified annual percentage of an amount based on the contract’s benefit base. The GMAB feature increases the contract account value at the end of a specified period to a GMAB base. The GIB feature provides a lifetime annuity based on predetermined annuity purchase rates if and when the contract account value is depleted. This lifetime annuity is based on predetermined annuity purchase rates applied to a GIB base.
Level 3 also includes the GMIB reinsurance contract assets which are accounted for as derivative contracts. The GMIB reinsurance contract asset and liabilities’ fair value reflects the present value of reinsurance premiums, net of recoveries, and risk margins over a range of market consistent economic scenarios while GMxB derivative features liability reflects the present value of expected future payments (benefits) less fees, adjusted for risk margins and nonperformance risk, attributable to GMxB derivative features’ liability over a range of market-consistent economic scenarios.
Also included are the Amounts due from Reinsurers related to the GMIB NLG product features (GMIB NLG Reinsurance). The fair value reflects the present value of reinsurance premiums, net of recoveries, adjusted for risk margins and nonperformance risk over a range of market consistent economic scenarios.
The valuations of the GMIB reinsurance contract asset, GMIB NLG Reinsurance and GMxB derivative features liability incorporate significant non-observable assumptions related to policyholder behavior, risk margins and projections of equity Separate Accounts funds. The credit risks of the counterparty and of the Company are considered in determining the fair values of its GMIB reinsurance contract asset, GMIB NLG Reinsurance and GMxB derivative features liability positions, respectively, after taking into account the effects of collateral arrangements. Incremental adjustment to the swap curve for non-performance risk is made to the fair values of the GMIB reinsurance contract asset, GMIB NLG Reinsurance and GMIBNLG feature to reflect the claims-paying ratings of counterparties and the Company. Equity and fixed income volatilities were modeled to reflect current market volatilities. Due to the unique, long duration of the GMIBNLG feature and GMIB NLG Reinsurance , adjustments were made to the equity volatilities to remove the illiquidity bias associated with the longer tenors and risk margins were applied to the non-capital markets inputs to the GMIBNLG valuations.
After giving consideration to collateral arrangements, the Company reduced the fair value of its GMIB reinsurance contract asset by $123 million and $160 million as of September 30, 2021 and December 31, 2020, respectively, to recognize incremental counterparty non-performance risk.
After giving consideration to collateral arrangements, the Company reduced the fair value of its Amounts due from Reinsurers by $195 million at September 30, 2021 to recognize incremental counterparty non-performance risk.
Lapse rates are adjusted at the contract level based on a comparison of the actuarial calculated guaranteed values and the current policyholder account value, which include other factors such as considering surrender charges. Generally, lapse rates are assumed to be lower in periods when a surrender charge applies. A dynamic lapse function reduces the base lapse rate when the guaranteed amount is greater than the account value as in the money contracts are less likely to lapse. For valuing the embedded derivative, lapse rates vary throughout the period over which cash flows are projected.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
The Company’s consolidated VIEs/VOEs hold investments that are classified as Level 3, primarily corporate bonds that are vendor priced with no ratings available, bank loans, non-agency collateralized mortgage obligations and asset-backed securities.
Transfers of Financial Instruments Between Levels 2 and 3
During the nine months ended September 30, 2021, fixed maturities with fair values of $713 million were transferred out of Level 3 and into Level 2 principally due to the availability of trading activity and/or market observable inputs to measure and validate their fair values. In addition, fixed maturities with fair value of $0 million were transferred from Level 2 into the Level 3 classification. These transfers in the aggregate represent approximately 8.3% of total equity as of September 30, 2021.
During the nine months ended September 30, 2020, fixed maturities with fair values of $103 million were transferred out of Level 3 and into Level 2 principally due to the availability of trading activity and/or market observable inputs to measure and validate their fair values. In addition, fixed maturities with fair value of $189 million were transferred from Level 2 into the Level 3 classification. These transfers in the aggregate represent approximately 2.0% of total equity as of September 30, 2020.
The tables below present reconciliations for all Level 3 assets and liabilities and changes in unrealized gains (losses) for the three and nine months ended September 30, 2021 and 2020, respectively.





































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Notes to Consolidated Financial Statements (Unaudited), Continued
Level 3 Instruments - Fair Value Measurements
CorporateState and Political SubdivisionsCMBSAsset-backed
(in millions)
Balance, July 1, 2021$1,249 $37 $11 $127 
Total gains and (losses), realized and unrealized, included in:
Net income (loss) as:
Net investment income (loss)1    
Investment gains (losses), net(1)   
Subtotal    
Other comprehensive income (loss)4    
Purchases259  (1)(120)
Sales(70)  (2)
Activity related to consolidated VIEs/VOEs    
Transfers into Level 3 (1)(2)   
Transfers out of Level 3 (1)    
Balance, September 30, 2021$1,440 $37 $10 $5 
Change in unrealized gains or losses for the period included in earnings for instruments held at the end of the reporting period (2)$ $ $ $ 
Change in unrealized gains or losses for the period included in other comprehensive income for instruments held at the end of the reporting period (2)$4 $ $ $ 
Balance, July 1, 2020$1,652 $40 $— $— 
Total gains and (losses), realized and unrealized, included in:
Net income (loss) as:
Net investment income (loss)— — — — 
Investment gains (losses), net(1)— — — 
Subtotal(1)— — — 
Other comprehensive income (loss)18 (1)— — 
Purchases(138)— — 13 
Sales(22)— — — 
Activity related to consolidated VIEs/VOEs— — — — 
Transfers into Level 3 (1)(30)— — — 
Transfers out of Level 3 (1)0— — — 
Balance, September 30, 2020$1,479 $39 $— $13 
Change in unrealized gains or losses for the period included in earnings for instruments held at the end of the reporting period (2)$— $— $— $— 
Change in unrealized gains or losses for the period included in other comprehensive income for instruments held at the end of the reporting period (2)$18 $(1)$— $— 





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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
CorporateState and Political SubdivisionsCMBSAsset-backed
(in millions)
Balance, January 1, 2021$1,687 $39 $ $20 
Total gains and (losses), realized and unrealized, included in:
Net income (loss) as:
Net investment income (loss)4    
Investment gains (losses), net(14)   
Subtotal(10)   
Other comprehensive income (loss)30 (1)  
Purchases718  10 3 
Sales(272)(1) (18)
Activity related to consolidated VIEs/VOEs  0 
Transfers into Level 3 (1)    
Transfers out of Level 3 (1)(713)   
Balance, September 30, 2021$1,440 $37 $10 $5 
Change in unrealized gains or losses for the period included in earnings for instruments held at the end of the reporting period (2)$ $ $ $ 
Change in unrealized gains or losses for the period included in other comprehensive income for instruments held at the end of the reporting period (2)$30 $(2)$ $ 
Balance, January 1, 2020$1,246 $39 $— $100 
Total gains and (losses), realized and unrealized, included in:
Net income (loss) as:
Net investment income (loss)— — — 
Investment gains (losses), net(14)— — — 
Subtotal(12)— — — 
Other comprehensive income (loss)(36)— — 
Purchases207 — — 13 
Sales(112)(1)— — 
Activity related to consolidated VIEs/VOEs— — — — 
Transfers into Level 3 (1)189 — — — 
Transfers out of Level 3 (1)(3)— — (100)
Balance, September 30, 2020$1,479 $39 $— $13 
Change in unrealized gains or losses for the period included in earnings for instruments held at the end of the reporting period (2)$— $— $— $— 
Change in unrealized gains or losses for the period included in other comprehensive income for instruments held at the end of the reporting period (2)$(36)$$— $— 
______________
(1)Transfers into/out of the Level 3 classification are reflected at beginning-of-period fair values.
(2)For instruments held as of September 30, 2021 or September 30, 2020, amounts are included in net investment income or net derivative gains (losses) in the consolidated statements of income (loss) or unrealized gains (losses) on investments in the consolidated statements of comprehensive income.

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Notes to Consolidated Financial Statements (Unaudited), Continued
Other Equity Investments (7)Amounts Due from ReinsurersGMIB Reinsurance Contract AssetSeparate Accounts AssetsGMxB Derivative Features Liability
(in millions)
Balance, July 1, 2021$13 $5,510 $2,290 $1 $(8,455)
Realized and unrealized gains (losses), included in Net income (loss) as:
Investment gains (losses), reported in net investment income1     
Net derivative gains (losses) (1) 344 (128) (395)
Total realized and unrealized gains (losses)1 

344 (128)

 

(395)
Other comprehensive income (loss)     
Purchases (2) 31 10 (1)(109)
Sales (3)(1)(16)(16) 21 
Other (5)     
Activity related to consolidated VIEs/VOEs1     
Transfers into Level 3 (4)     
Transfers out of Level 3 (4)1     
Balance, September 30, 2021$15 $5,869 $2,156 $ $(8,938)
Change in unrealized gains or losses for the period included in earnings for instruments held at the end of the reporting period (6)$1 $344 $(128)$ $(395)
Change in unrealized gains or losses for the period included in other comprehensive income for instruments held at the end of the reporting period (6)$ $ $ $ $ 
Balance, July 1, 2020$16 $— $3,433 $— $(12,458)
Realized and unrealized gains (losses), included in Net income (loss) as:
Investment gains (losses), reported in net investment income— — — — — 
Net derivative gains (losses)— — (177)— 570 
Total realized and unrealized gains (losses) 

 (177)

 

570 
Other comprehensive income (loss)— — — — — 
Purchases (2)— 11 — (113)
Sales (3)— — (21)— 16 
Change in estimate (4)— — — — 
Activity related to consolidated VIEs/VOEs(3)— — — — 
Transfers into Level 3 (4)— — — — — 
Transfers out of Level 3 (4)— — — — — 
Balance, September 30, 2020$16 $— $3,247 $— $(11,985)
Change in unrealized gains or losses for the period included in earnings for instruments held at the end of the reporting period (6)$— $— $(177)$— $570 
Change in unrealized gains or losses for the period included in other comprehensive income for instruments held at the end of the reporting period (6)$— $— $— $— $— 

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Notes to Consolidated Financial Statements (Unaudited), Continued
Other Equity Investments (7)Amounts Due from ReinsurersGMIB Reinsurance Contract AssetSeparate Accounts AssetsGMxB Derivative Features Liability
(in millions)
Balance, January 1, 2021$15 $ $2,859 $1 $(10,936)
Realized and unrealized gains (losses), included in Net income (loss) as:
Investment gains (losses), reported in net investment income2 0   
Net derivative gains (losses) (1) 586 (694) 2,291 
Total realized and unrealized gains (losses)2 

586 (694)

 

2,291 
Purchases (2) 40 32  (344)
Sales (3)(1)(16)(41) 51 
Settlements     
Other (5) 5,259    
Activity related to consolidated VIEs/VOEs(1)    
Transfers into Level 3 (4)     
Transfers out of Level 3 (4)   (1) 
Balance, September 30, 2021$15 $5,869 $2,156 $ $(8,938)
Change in unrealized gains or losses for the period included in earnings for instruments held at the end of the reporting period (6)$2 $586 $(694)$ $2,291 
Change in unrealized gains or losses for the period included in other comprehensive income for instruments held at the end of the reporting period (6)$ $ $ $ $ 
Balance, January 1, 2020$16 $— $2,466 $— $(8,316)
Realized and unrealized gains (losses), included in Net income (loss) as:
Investment gains (losses), reported in net investment income— — — — — 
Net derivative gains (losses)— — 849 — (3,382)
Total realized and unrealized gains (losses)— — 849 — (3,382)
Purchases (2)— 34 — (328)
Sales (3)— — (58)— 41 
Settlements— — — — — 
Change in estimate— — (44)— — 
Activity related to consolidated VIEs/VOEs(4)— — — — 
Transfers into Level 3 (4)
— — — — — 
Transfers out of Level 3 (4)— — — — — 
Balance, September 30, 2020$16 $— $3,247 $— $(11,985)
Change in unrealized gains or losses for the period included in earnings for instruments held at the end of the reporting period (6)$— $— $849 $— $(3,382)
Change in unrealized gains or losses for the period included in other comprehensive income for instruments held at the end of the reporting period (6)$— $— $— $— $— 
______________
(1)For the three and nine months ended September 30, 2021, the Company’s non-performance risk impact of $(92) million and $(68) million for the GMxB Derivative Features Liability, $8 million and $9 million for the GMIB Reinsurance Contract Asset, and $(19) million and $(7) million for the Amounts due from Reinsurers, respectively, is recorded through Net derivative gains (losses).
(2)For the GMIB reinsurance contract asset, Amounts Due from Reinsurers and GMxB derivative features liability, represents attributed fee.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
(3)For the GMIB reinsurance contract asset and Amounts Due from Reinsurers, represents recoveries from reinsurers and for GMxB derivative features liability represents benefits paid.
(4)Transfers into/out of the Level 3 classification are reflected at beginning-of-period fair values.
(5)Represents the opening ceded balance from the Venerable transaction of the GMxB with no lapse guarantee riders.
(6)For instruments held as of September 30, 2021 or September 30, 2020, amounts are included in net investment income or net derivative gains (losses) in the consolidated statements of income (loss) or unrealized gains (losses) on investments in the consolidated statements of comprehensive income.
(7)Other Equity Investments include other invested assets.

Quantitative and Qualitative Information about Level 3 Fair Value Measurements
The following tables disclose quantitative information about Level 3 fair value measurements by category for assets and liabilities as of September 30, 2021 and December 31, 2020, respectively.

Quantitative Information about Level 3 Fair Value Measurements as of September 30, 2021
Fair
Value
Valuation TechniqueSignificant
Unobservable Input
RangeWeighted Average (2)
(in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate$197Matrix pricing modelSpread over Benchmark20 - 295 bps162 bps
820Market  comparable  companies
EBITDA multiples
Discount Rate
Cashflow Multiples
Loan to Value
4.9x - 73.7x
5.9% - 15.0%
0.0x - 9.0x
0.0% - 60.8%
12.3x
9.0%
6.0x
30.4%
Other equity investments4Market  comparable  companiesRevenue multiple8.2x - 9.5x8.5x
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Fair
Value
Valuation TechniqueSignificant
Unobservable Input
RangeWeighted Average (2)
GMIB reinsurance contract asset2,156Discounted cash flow
Lapse rates
Withdrawal Rates
GMIB Utilization Rates
Non-performance risk
Volatility rates - Equity
Mortality: Ages 0-40
Ages 41-60
Ages 61-115
0.45% - 20.86%
0.27% - 8.66%
0.04% - 60.44%
40 bps - 78 bps
10% - 32%
0.01% - 0.17%
0.06% - 0.53%
0.31% - 40.00%
2.56%
0.93%
5.43%
44 bps
24%
2.76%
(same for all ages)
(same for all ages)
Amount Due from Reinsurers
5,869Discounted Cash Flow
Lapse rates
Withdrawal Rates
GMIB Utilization Rates
Non-performance risk (bps)
Volatility rates - Equity
Mortality: Ages 0-40
Ages 41-60
Ages 61-115
0.45% - 20.86%
0.27% - 8.66%
0.04% - 60.44%
34 bps - 34 bps
10% - 32%
0.01% - 0.17%
0.06% - 0.53%
0.31% - 40.00%
1.67%
1.17%
7.34%
34 bps
24%
2.13%
(same for all ages)
(same for all ages)
Liabilities:
GMIBNLG8,896Discounted cash flow
Non-performance risk
Lapse
Withdrawal
Annuitization
Mortality (1): Ages 0-40
Ages 41-60
Ages 61-115

92 bps - 92 bps
1.04% - 23.57%
0.27% - 8.66%
0.03% - 100.00%
0.01% - 0.19%
0.07% - 0.57%
0.44% - 43.60%

92 bps
3.51%
1.03%
5.35%
1.60%
(same for all ages)
(same for all ages)
GWBL/GMWB104Discounted cash flow
Lapse rates
Withdrawal Rates
Utilization Rates
Volatility rates - Equity
Non-performance risk
0.60% - 20.86%
0.00% - 8.00%
100% once starting
10% - 32%
92 bps - 92 bps
2.56%
0.93%

24%
GIB(60)Discounted cash flow
Lapse rates
Withdrawal Rates
Utilization Rates
Volatility rates - Equity
Non-performance risk
0.60% - 20.86%
0.13% - 8.66%
0.04% - 100.00%
10% - 32%
92 bps - 92 bps
2.56%
0.93%
5.43%
24%
GMAB(3)Discounted cash flow
Lapse rates
Volatility rates - Equity
Non-performance risk

0.60% - 20.86%
10% - 32%
92 bps - 92 bps
2.56%
24%
______________
(1)Mortality rates vary by age and demographic characteristic such as gender. Mortality rate assumptions are based on a combination of company and industry experience. A mortality improvement assumption is also applied. For any given contract, mortality rates vary throughout the period over which cash flows are projected for purposes of valuating the embedded derivatives.
(2)For lapses, withdrawals, and utilizations the rates were weighted by counts, for mortality weighted average rates are shown for all ages combined and for withdrawals the weighted averages were based on an estimated split of partial withdrawal and dollar-for-dollar withdrawals.
Quantitative Information about Level 3 Fair Value Measurements as of December 31, 2020
Fair
Value
Valuation Technique
Significant
Unobservable Input
RangeWeighted Average
(in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate$28 Matrix pricing modelSpread over benchmark45 - 195 bps152 bps
1,148 Market comparable companies
EBITDA multiples
Discount rate
Cash flow multiples
3.5x - 33.1x
5.6% - 28.4%
1.9x -25.0x
10.8x
8.6%
6.8x
Other equity investmentsMarket  comparable  companiesRevenue multiple
9.7x - 26.4x
18.5x
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
GMIB reinsurance contract asset2,859 Discounted cash flow
Non-performance risk
Lapse rates
Withdrawal rates
Utilization rates
Volatility rates - Equity
Mortality rates (1):
Ages 0 - 40
Ages 41 - 60
Ages 61 - 115
43 - 85 bps
0.6%-16%
0%-2%
0%-61%
7%-32%

0.01%-0.18%
0.07%-0.54%
0.42%-42.20%
50 bps
1.69%
0.91%
5.82%
24%

2.80%
(same for all ages)
(same for all ages)
Liabilities:
GMIBNLG10,713 Discounted cash flow
Non-performance risk
Lapse rates
Withdrawal rates
Annuitization rates
Mortality rates (1):
Ages 0 - 40
Ages 41 - 60
Ages 61 - 115
96.0 bps
1.1%-25.7%
0.4%-2%
0%-100%

0.01%-0.19%
0.06%-0.53%
0.41%-41.39%

3.19%
0.93%
5.51%

1.56%
(same for all ages)
(same for all ages)
GWBL/GMWB190 Discounted cash flow
Non-performance risk
Lapse rates
Withdrawal rates
Utilization rates
Volatility rates - Equity
96.0 bps
0.8%-16%
0%-8%
100% once starting
7%-32%

1.69%
0.91%

24%
GIB31 Discounted cash flow
Non-performance risk
Lapse rates
Withdrawal rates
Utilization rates
Volatility rates - Equity
96.0 bps
0.8%-15.6%
0%-2%
0%-100%
7%-32%

1.69%
0.91%
5.82%
24%
GMABDiscounted cash flow
Non-performance risk
Lapse rates
Volatility rates - Equity
96.0 bps
0.8%-16%
7%-32%

1.69%
24%
______________
(1)Mortality rates vary by age and demographic characteristic such as gender. Mortality rate assumptions are based on a combination of company and industry experience. A mortality improvement assumption is also applied. For any given contract, mortality rates vary throughout the period over which cash flows are projected for purposes of valuating the embedded derivatives.
Level 3 Financial Instruments for which Quantitative Inputs are Not Available
Certain Privately Placed Debt Securities with Limited Trading Activity
Excluded from the tables above as of September 30, 2021 and December 31, 2020, respectively, are approximately $487 million and $586 million of Level 3 fair value measurements of investments for which the underlying quantitative inputs are not developed by the Company and are not readily available. These investments primarily consist of certain privately placed debt securities with limited trading activity, including residential mortgage- and asset-backed instruments, and their fair values generally reflect unadjusted prices obtained from independent valuation service providers and indicative, non-binding quotes obtained from third-party broker-dealers recognized as market participants. Significant increases or decreases in the fair value amounts received from these pricing sources may result in the Company’s reporting significantly higher or lower fair value measurements for these Level 3 investments.
The fair value of private placement securities is determined by application of a matrix pricing model or a market comparable company value technique. The significant unobservable input to the matrix pricing model valuation technique is the spread over the industry-specific benchmark yield curve. Generally, an increase or decrease in spreads would lead to directionally inverse movement in the fair value measurements of these securities. The significant unobservable input to the market comparable company valuation technique is the discount rate. Generally, a significant increase (decrease) in the discount rate would result in significantly lower (higher) fair value measurements of these securities.
Residential mortgage-backed securities classified as Level 3 primarily consist of non-agency paper with low trading activity. Included in the tables above as of September 30, 2021 and December 31, 2020, there were no Level 3 securities that were determined by application of a matrix pricing model and for which the spread over the U.S. Treasury curve is the most significant unobservable input to the pricing result. Generally, a change in spreads would lead to directionally inverse movement in the fair value measurements of these securities.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Asset-backed securities classified as Level 3 primarily consist of non-agency mortgage loan trust certificates, including subprime and Alt-A paper, credit risk transfer securities, and equipment financings. Included in the tables above as of September 30, 2021 and December 31, 2020, there were no securities that were determined by the application of matrix-pricing for which the spread over the U.S. Treasury curve is the most significant unobservable input to the pricing result. Significant increases (decreases) in spreads would have resulted in significantly lower (higher) fair value measurements.
GMIB Reinsurance Contract Asset, Amounts Due from Reinsurers and GMxB Derivative Features
Significant unobservable inputs with respect to the fair value measurement of the Level 3 GMIB reinsurance contract asset and the Level 3 liabilities identified in the table above are developed using Company data.
The significant unobservable inputs used in the fair value measurement of the Company’s GMIB reinsurance contract asset are lapse rates, withdrawal rates, and GMIB utilization rates. Significant increases in GMIB utilization rates or decreases in lapse or withdrawal rates in isolation would tend to increase the GMIB reinsurance contract asset.
Fair value measurement of the GMIB reinsurance contract asset, GMIB NLG Reinsurance and liabilities includes dynamic lapse and GMIB utilization assumptions whereby projected contractual lapses and GMIB utilization reflect the projected net amount of risks of the contract. As the net amount of risk of a contract increases, the assumed lapse rate decreases and the GMIB utilization increases. Increases in volatility would increase the asset and liabilities.
The significant unobservable inputs used in the fair value measurement of the Company’s GMIBNLG liability and GMIB NLG Reinsurance are lapse rates, withdrawal rates, GMIB utilization rates, adjustment for non-performance risk and NLG forfeiture rates. NLG forfeiture rates are caused by excess withdrawals above the annual GMIB accrual rate that cause the NLG to expire. Significant decreases in lapse rates, NLG forfeiture rates, adjustment for non-performance risk and GMIB utilization rates would tend to increase the GMIBNLG liability and GMIB NLG Reinsurance, while decreases in withdrawal rates and volatility rates would tend to decrease the GMIBNLG liability and GMIB NLG Reinsurance.
The significant unobservable inputs used in the fair value measurement of the Company’s GMWB and GWBL liability are lapse rates and withdrawal rates. Significant increases in withdrawal rates or decreases in lapse rates in isolation would tend to increase these liabilities. Increases in volatility would increase these liabilities.
Carrying Value of Financial Instruments Not Otherwise Disclosed in Note 3 and Note 4
The carrying values and fair values as of September 30, 2021 and December 31, 2020 for financial instruments not otherwise disclosed in Note 3 and Note 4 are presented in the table below:
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Notes to Consolidated Financial Statements (Unaudited), Continued
Carrying Values and Fair Values for Financial Instruments Not Otherwise Disclosed
 
Carrying
Value
Fair Value
 Level 1Level 2Level 3Total
(in millions)
September 30, 2021:
Mortgage loans on real estate$13,431 $ $ $13,757 $13,757 
Policy loans$3,541 $ $ $4,559 $4,559 
Loans to affiliates$1,900 $ $1,998 $ $1,998 
Policyholders’ liabilities: Investment contracts (1)$1,935 $ $ $2,056 $2,056 
FHLB funding agreements$6,807 $ $6,864 $ $6,864 
FABN funding agreements$5,732 $ $5,733 $ $5,733 
Separate Accounts liabilities$11,092 $ $ $11,092 $11,092 
December 31, 2020:
Mortgage loans on real estate$13,142 $— $— $13,474 $13,474 
Policy loans$3,635 $— $— $4,794 $4,794 
Loans to affiliates$900 $— $938 $— $938 
Policyholders’ liabilities: Investment contracts$2,069 $— $— $2,275 $2,275 
FHLB funding agreements$6,897 $— $6,990 $— $6,990 
FABN funding agreements$1,939 $— $1,971 $— $1,971 
Separate Accounts liabilities$10,081 $— $— $10,081 $10,081 
_____________
(1) As of September 30, 2021, reflects transfer of certain policyholders account balances to future policyholder benefits and other policyholders liabilities related to structured settlement contracts.
Mortgage Loans on Real Estate
Fair values for commercial and agricultural mortgage loans on real estate are measured by discounting future contractual cash flows to be received on the mortgage loan using interest rates at which loans with similar characteristics and credit quality would be made. The discount rate is derived based on the appropriate U.S. Treasury rate with a like term to the remaining term of the loan to which a spread reflective of the risk premium associated with the specific loan is added. Fair values for mortgage loans anticipated to be foreclosed and problem mortgage loans are limited to the fair value of the underlying collateral, if lower.
Policy Loans
The fair value of policy loans is calculated by discounting expected cash flows based upon the U.S. Treasury yield curve and historical loan repayment patterns.
Loans to Affiliates
The fair value of loans to affiliates is calculated by matrix or model pricing. The matrix pricing approach to fair value is a discounted cash flow methodology that incorporates market interest rates commensurate with the credit quality and duration of the investment.

FHLB Funding Agreements
The fair values of the Company’s FHLB funding agreements are determined by discounted cash flow analysis based on the indicative funding agreement rates published by the FHLB.
FABN Funding Agreements
The fair values of the Company’s FABN funding agreements are determined by Bloomberg’s evaluated pricing service, which uses direct observations or observed comparables.
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Policyholder Liabilities - Investment Contracts and Separate Accounts Liabilities
The fair values for deferred annuities and certain annuities, which are included in Policyholders’ account balances and liabilities for investment contracts with fund investments in Separate Accounts are estimated using projected cash flows discounted at rates reflecting current market rates. Significant unobservable inputs reflected in the cash flows include lapse rates and withdrawal rates. Incremental adjustments may be made to the fair value to reflect non-performance risk. Certain other products such as the Company’s association plans contracts, supplementary contracts not involving life contingencies, (“SCNILC”), Access Accounts and Escrow Shield Plus product reserves are held at book value.
Financial Instruments Exempt from Fair Value Disclosure or Otherwise Not Required to be Disclosed
Exempt from Fair Value Disclosure Requirements
Certain financial instruments are exempt from the requirements for fair value disclosure, such as insurance liabilities other than financial guarantees and investment contracts, limited partnerships accounted for under the equity method and pension and other postretirement obligations.
Otherwise Not Required to be Included in the Table Above
The Company’s investment in Corporate Owned Life Insurance (“COLI”)COLI policies are recorded at their cash surrender value and are therefore not required to be included in the table above. See Note 2 to the Company’s consolidated financial statements included in the Annual Report on Form 10-K for the year ended December 31, 2019 for further description of the Company’s accounting policy related to its investment in COLI policies.
8)    LOANS TO AFFILIATES
Loans Issued to Holdings
50

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
In April 2018, Equitable Financial made a $800 million loan to Holdings. The loan has an interest rate for details of 3.69% and maturesinvestments in April 2021. In December 2018 and in December 2019, Holdings repaid $200 million and $300 million in principal, respectively. At September 30, 2020, the amount outstanding was $300 million.
In November 2019, Equitable Financial made a $900 million loan to Holdings. The loan has an interest rate of one-month LIBOR plus 1.33%. The loan matures on November 24, 2024. At September 30, 2020, the amount outstanding was $900 million.COLI policies.
9)    INCOME TAXES
Income tax expense for the three and nine months ended September 30, 20202021 and 20192020 was computed using an estimated annual effective tax rate (“ETR”), with discrete items recognized in the period in which they occur. The estimated ETR is revised, as necessary, at the end of successive interim reporting periods.
10)    RELATED PARTY TRANSACTIONS
In June 2021, Equitable Life made a $1.0 billion 10-year term loan to Holdings. The Company did not enter into any new significant transactions with related parties during the nine months ended September 30, 2020.loan has an interest rate of 3.23% and matures in June 2031.
11)    EQUITY
AOCI represents cumulative gains (losses) on items that are not reflected in Netnet income (loss). The balances as of September 30, 20202021 and 2019December 31, 2020 follow:
September 30, September 30,December 31,
20202019 20212020
(in millions)(in millions)
Unrealized gains (losses) on investmentsUnrealized gains (losses) on investments$4,927 $2,226 Unrealized gains (losses) on investments$2,291 $4,600 
Defined benefit pension plansDefined benefit pension plans(4)(7)Defined benefit pension plans(5)(5)
Accumulated other comprehensive income (loss) attributable to Equitable FinancialAccumulated other comprehensive income (loss) attributable to Equitable Financial$4,923 $2,220 Accumulated other comprehensive income (loss) attributable to Equitable Financial$2,286 $4,595 

The components of OCI, net of taxes for the three and nine months ended September 30, 20202021 and 2019,2020, follow:
Three Months Ended September 30,Nine Months Ended September 30,
2020201920202019
(in millions)
Change in net unrealized gains (losses) on investments:
Net unrealized gains (losses) arising during the period$295 $1,224 $4,524 $3,750 
(Gains) losses reclassified into net income (loss) during the period (1)(23)(159)(205)(157)
Net unrealized gains (losses) on investments271 1,065 4,318 3,593 
Adjustments for policyholders’ liabilities, DAC, insurance liability loss recognition and other(24)(335)(992)(872)
Change in unrealized gains (losses), net of adjustments (net of deferred income tax expense (benefit) of 66, $194, $884 and $718)247 730 3,327 2,721 
Other comprehensive income (loss), attributable to Equitable Financial$247 $730 $3,327 $2,721 
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
Three Months Ended September 30,Nine Months Ended September 30,
2021202020212020
(in millions)
Change in net unrealized gains (losses) on investments:
Net unrealized gains (losses) arising during the period$(285)$295 $(2,409)$4,524 
(Gains) losses reclassified into net income (loss) during the period (1)(130)(23)(608)(205)
Net unrealized gains (losses) on investments(415)271 (3,017)4,318 
Adjustments for policyholders’ liabilities, DAC, insurance liability loss recognition and other61 (24)708 (992)
Change in unrealized gains (losses), net of adjustments (net of deferred income tax expense (benefit) of $(94), $66, $(614) and $884)(354)247 (2,309)3,327 
Other comprehensive income (loss), attributable to Equitable Financial$(354)$247 $(2,309)$3,327 
____________
(1)See “Reclassification adjustments” in Note 3. Reclassification amounts presented net of income tax expense (benefit) of $35 million, $(6) million $(42) million, $(55), $162 million and $(42)$(55) million for the three and nine months ended September 30, 2021 and 2020, and 2019, respectively.

Investment gains and losses reclassified from AOCI to Netnet income (loss) primarily consist of realized gains (losses) on sales and credit losses of AFS securities and are included in Totaltotal investment gains (losses), net on the consolidated statements of income (loss). Amounts reclassified from AOCI to Netnet income (loss) as related to defined benefit plans
51

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
primarily consist of amortization of net (gains) losses and net prior service cost (credit) recognized as a component of net periodic cost and reported in Compensationcompensation and benefits in the consolidated statements of income (loss). Amounts presented in the table above are net of tax.
Permitted Statutory Accounting Practices
Equitable Financial was granted a permitted practice by the NYDFS to apply SSAP 108, Derivatives Hedging Variable Annuity Guarantees on a retroactive basis from January 1, 2021 through June 30, 2021, after reflecting the impacts of our reinsurance transaction with Venerable. The permitted practice was amended to also permit Equitable Financial to adopt SSAP 108 prospectively as of July 1, 2021. Application of the permitted practice partially mitigates the Regulation 213 impact of the Venerable transaction on Equitable Financial’s statutory capital and surplus. The impact of the application of this permitted practice was an increase of approximately $1.5 billion in statutory special surplus funds and an increase of $1.6 billion in statutory net income as of September 30, 2021 and for the nine-month period then ended, which will be amortized over 5 years for each of the retrospective and prospective components. The permitted practice also resets Equitable Financial’s unassigned surplus to zero as of June 30, 2021 to reflect the transformative nature of the Venerable transaction.
12)     REDEEMABLE NONCONTROLLING INTEREST
The changes in the components of redeemable noncontrolling interests are presented in the table that follows:
Three Months Ended September 30,Nine Months Ended September 30,Three Months Ended September 30,Nine Months Ended September 30,
2020201920202019 2021202020212020
(in millions) (in millions)
Balance, beginning of periodBalance, beginning of period$36 $42 $39 $39 Balance, beginning of period$24 $36 $41 $39 
Net earnings (loss) attributable to redeemable noncontrolling interestsNet earnings (loss) attributable to redeemable noncontrolling interests3 0 Net earnings (loss) attributable to redeemable noncontrolling interests 1 — 
Purchase/change of redeemable noncontrolling interestsPurchase/change of redeemable noncontrolling interests(1)(1)Purchase/change of redeemable noncontrolling interests1 (1)(17)(1)
Balance, end of periodBalance, end of period$38 $46 $38 $46 Balance, end of period$25 $38 $25 $38 

13)    COMMITMENTS AND CONTINGENT LIABILITIES
Litigation and Regulatory Matters
Litigation, regulatory and other loss contingencies arise in the ordinary course of the Company’s activities as a diversified financial services firm. The Company is a defendant in a number of litigation matters arising from the conduct of its business. In some of these matters, claimants seek to recover very large or indeterminate amounts,
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Notes to Consolidated Financial Statements (Unaudited), Continued
including compensatory, punitive, treble and exemplary damages. Modern pleading practice permits considerable variation in the assertion of monetary damages and other relief. Claimants are not always required to specify the monetary damages they seek, or they may be required only to state an amount sufficient to meet a court’s jurisdictional requirements. Moreover, some jurisdictions allow claimants to allege monetary damages that far exceed any reasonably possible verdict. The variability in pleading requirements and past experience demonstrates that the monetary and other relief that may be requested in a lawsuit or claim often bears little relevance to the merits or potential value of a claim. Litigation against the Company includes a variety of claims including, among other things, insurers’ sales practices, alleged agent misconduct, alleged failure to properly supervise agents, contract administration, product design, features and accompanying disclosure, cost of insurance increases, payments of death benefits and the reporting and escheatment of unclaimed property, alleged breach of fiduciary duties, alleged mismanagement of client funds and other matters.
As with other financial services companies, the Company periodically receives informal and formal requests for information from various state and federal governmental agencies and self-regulatory organizations in connection with inquiries and investigations of the products and practices of the Company or the financial services industry. It is the practice of the Company to cooperate fully in these matters.
The outcome of a litigation or regulatory matter is difficult to predict, and the amount or range of potential losses associated with these or other loss contingencies requires significant management judgment. It is not possible to predict the ultimate outcome or to provide reasonably possible losses or ranges of losses for all pending regulatory matters, litigation and other loss contingencies. While it is possible that an adverse outcome in certain cases could have a material adverse effect upon the Company’s financial position, based on information currently known, management believes that neither the outcome of pending litigation and regulatory matters, nor potential liabilities associated with other loss contingencies, are likely to have such an effect. However, given the large and indeterminate amounts sought in certain litigation and the inherent unpredictability of all such matters, it is possible that an adverse outcome in certain of the Company’s litigation or regulatory matters, or liabilities arising from other loss contingencies, could, from time to time, have a material adverse effect upon the Company’s results of operations or cash flows in a particular quarterly or annual period.
For some matters, the Company is able to estimate a possible range of loss. For such matters in which a loss is probable, an accrual has been made. For matters where the Company believes a loss is reasonably possible, but not probable, no accrual is required. For matters for which an accrual has been made, but there remains a reasonably possible range of loss in excess of the amounts accrued or for matters where no accrual is required, the Company
52

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
develops an estimate of the unaccrued amounts of the reasonably possible range of losses. As of September 30, 2020,2021, the Company estimates the aggregate range of reasonably possible losses, in excess of any amounts accrued for these matters as of such date, to be up to approximately $100$150 million.
For other matters, the Company is currently not able to estimate the reasonably possible loss or range of loss. The Company is often unable to estimate the possible loss or range of loss until developments in such matters have provided sufficient information to support an assessment of the range of possible loss, such as quantification of a damage demand from plaintiffs, discovery from plaintiffs and other parties, investigation of factual allegations, rulings by a court on motions or appeals, analysis by experts and the progress of settlement discussions. On a quarterly and annual basis, the Company reviews relevant information with respect to litigation and regulatory contingencies and updates the Company’s accruals, disclosures and reasonably possible losses or ranges of loss based on such reviews.
In August 2015, a lawsuit was filed in Connecticut Superior Court Judicial Division of New Haven entitled Richard T. O’Donnell, on behalf of himself and all others similarly situated v. AXA Equitable Life Insurance Company. This lawsuit is a putative class action on behalf of all persons who purchased variable annuities from Equitable Financial, which were subsequently subjected to the volatility management strategy and who suffered injury as a result thereof. Plaintiff asserts a claim for breach of contract alleging that Equitable Financial implemented the volatility management strategy in violation of applicable law. Plaintiff seeks an award of damages individually and on a classwide basis, and costs and disbursements, including attorneys’ fees, expert witness fees and other costs. In November 2015, the Connecticut Federal District Courtcase was transferred this action to the United States District Court for the Southern District of New York. In March 2017, the Southern District of New York and, in 2018, transferred back to Connecticut Superior Court. In August 2019, the court granted Equitable Financial’s motion to dismiss the complaint. In April 2017, the plaintiff filed a notice of appeal. In April 2018, the United States Court of Appeals for the Second Circuit reversed the trial court’s decision with instructions to remand the case to Connecticut state court. In September 2018, the Second Circuit issued its mandate, following Equitable Financial’s notification to the court that it would not file a petition for writ of certiorari. The case was transferred in December 2018 to the Connecticut Superior Court, Judicial District of Stamford. In December 2018, Equitable Financialstrike, which sought dismissal of the complaint, by filing a motion to strike, which the court grantedand in August 2019.September 2019, Plaintiff filed an Amended Class Action Complaint in September 2019.Complaint. Equitable Financial filed a motionrenewed motions to strike and to dismiss and for an entry of judgment in October 2019. OnIn August 3, 2020, the court granted Equitable Financial’s motion for entry of judgment. In August 2020, Plaintiff filed a notice of appeal. We are vigorously defending this matter.
In February 2016, a lawsuit was filed in the United States District Court for the Southern District of New York entitled Brach Family Foundation, Inc. v. AXA Equitable Life Insurance Company. This lawsuit is a putative class action brought on behalf of all owners of universal life (“UL”)UL policies subject to Equitable Financial’s COI rate increase. In early 2016, Equitable Financial raised COI rates for certain UL policies issued between 2004 and 2007,2008, which had both issue ages 70 and above and a current face value amount of $1 million and above. A second putative class action was filed in Arizona in 2017 and consolidated with the Brach matter. The current consolidated amended class action complaint alleges the following claims: breach of contract;
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
misrepresentations by Equitable Financial in violation of Section 4226 of the New York Insurance Law; violations of New York General Business Law Section 349; and violations of the California Unfair Competition Law, and the California Elder Abuse Statute. Plaintiffs seek;seek: (a) compensatory damages, costs, and, pre- and post-judgment interest; (b) with respect to their claim concerning Section 4226, a penalty in the amount of premiums paid by the plaintiffs and the putative class; and (c) injunctive relief and attorneys’ fees in connection with their statutory claims. In August 2020, the federal district court issued a decision granting in part Brach Plaintiffs’ motion for class certification. The court certifiedcertifying nationwide breach of contract and Section 4226 classes, and a New York State Section 349 class, and class notice has gone out.class. Equitable Financial has commenced settlement discussions with the Brach class action plaintiffs through a non-binding mediation process. No assurances can be given about the outcome of that mediation process. Separately, a substantial number of policy owners have opted out of the Brach class action and are not participating in that mediation process. Most have not yet filed a petition seeking permission to appeal the decision to certify the Section 4226 class and New York State Section 349 class. NaNsuit. Others filed suit previously. They include 5 other federal actions challenging the COI rate increase that are also pending against Equitable Financial and have been coordinated with the Brach action for the purposes of pre-trial activities. They contain allegations similar to those in the Brach action as well as additional allegations for violations of various states’ consumer protection statutes and common law fraud. NaN actions are also pending against Equitable Financial in New York state court. Equitable Financial is vigorously defending each of these matters.
As with other financial services companies, the Company periodically receives informal and formal requests for information from various state and federal governmental agencies and self-regulatory organizations in connection with inquiries and investigations of the products and practices of the Company or the financial services industry. It is the practice of the Company to cooperate fully in these matters. For example, among other matters, the Company has been cooperating with the U.S. Securities and Exchange Commission (the “SEC”) concerning the SEC’s investigation into the Company’s non-ERISA K-12 403(b) and 457 sales and disclosure practices.
Obligations under Funding Agreements
Federal Home Loan Bank of New York
53

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
As a member of the FHLB, Equitable Financial has access to collateralized borrowings. It also may issue funding agreements to the FHLBNY.FHLB. Both the collateralized borrowings and funding agreements would require Equitable Financial to pledge qualified mortgage-backed assets and/or government securities as collateral. Equitable Financial issues short-term funding agreements to the FHLBNYFHLB and uses the funds for asset, liability, and cash management purposes. Equitable Financial issues long-term funding agreements to the FHLBNYFHLB and uses the funds for spread lending purposes.
Entering into FHLB membership, borrowings and funding agreements requires the ownership of FHLB stock and the pledge of assets as collateral. Equitable Financial has purchased FHLB stock of $320$318 million and pledged collateral with a carrying value of $8.7$10.4 billion as of September 30, 2020.2021. 
Funding agreements are reported in Policyholders’policyholders’ account balances in the consolidated balance sheets. For other instruments used for asset/liability and cash management purposes, see “Derivative and offsetting assets and liabilities” included in Note 4. The table below summarizes the Company’s activity of funding agreements with the FHLB.
Change in FHLB Funding Agreements during the Nine Months Ended September 30, 20202021
Outstanding Balance at December 31, 2019Issued During the PeriodRepaid During the PeriodLong-term Agreements Maturing Within One YearLong-term Agreements Maturing Within Five YearsOutstanding Balance at September 30, 2020Outstanding Balance at December 31, 2020Issued During the PeriodRepaid During the PeriodLong-term Agreements Maturing Within One YearLong-term Agreements Maturing Within Five YearsOutstanding Balance at September 30, 2021
(in millions)(in millions)
Short-term funding agreements:Short-term funding agreements:Short-term funding agreements:
Due in one year or lessDue in one year or less$4,608 $34,298 $34,358 $490 $0 $5,038 Due in one year or less$5,634 $46,301 $46,389 $322 $ $5,868 
Long-term funding agreements:Long-term funding agreements:Long-term funding agreements:
Due in years two through fiveDue in years two through five1,646 0 (490)112 1,268 Due in years two through five722 —  (322)409 809 
Due in more than five yearsDue in more than five years646 0 0 0 (112)534 Due in more than five years534    (409)125 
Total long-term funding agreementsTotal long-term funding agreements2,292 0 (490)0 1,802 Total long-term funding agreements1,256 —  (322) 934 
Total funding agreements (1)Total funding agreements (1)$6,900 $34,298 $34,358 $0 $0 $6,840 Total funding agreements (1)$6,890 $46,301 $46,389 $ $ $6,802 
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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements (Unaudited), Continued
____________
(1)The $8$5 million and $9$7 million difference between the funding agreements carrying value shown in fair value table for September 30, 20202021 and December 31, 2019,2020, respectively, reflects the remaining amortization of a hedge implemented and closed, which locked in the funding agreements borrowing rates.
Funding Agreement-Backed Notes Program
Under the FABN program, Equitable Financial may issue funding agreements in U.S. dollar or other foreign currencies to a Delaware special purpose statutory trust (the “Trust”) in exchange for the proceeds from issuances of fixed and floating rate medium-term marketable notes issued by the Trust from time to time (the “Trust notes”). The funding agreements have matching interest, maturity and maturitycurrency payment terms to the applicable Trust notes. The Company hedges the foreign currency exposure of foreign currency denominated funding agreements using cross currency swaps as discussed in Note 4. As of May 2021, the maximum aggregate principal amount of Trust notes permitted to be outstanding at any one time is $5$10 billion. Funding agreements issued to the Trust, including any foreign currency transaction adjustments, are reported in policyholders’ account balances in the consolidated balance sheets. Foreign currency transaction adjustments to policyholder’s account balances are recognized in net income (loss) as an adjustment to interest credited to policyholders’ account balances and are offset in interest credited to policyholders’ account balances by a release of AOCI from deferred changes in fair value of designated and qualifying cross currency swap cash flow hedges. The table below summarizes the Company’s activityEquitable Financial’s issuances of funding agreements under the FABN.
54

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Change in FABN Funding Agreements during the Nine Months Ended September 30, 20202021
Outstanding Balance at December 31, 2019Issued During the PeriodRepaid During the PeriodLong-term Agreements Maturing Within One YearLong-term Agreements Maturing Within Five YearsOutstanding Balance at September 30, 2020Outstanding Balance at December 31, 2020Issued During the PeriodRepaid During the PeriodLong-term Agreements Maturing Within One YearLong-term Agreements Maturing Within Five YearsForeign Currency Transaction AdjustmentOutstanding Balance at September 30, 2021
(in millions)(in millions)
Short-term funding agreements:Short-term funding agreements:Short-term funding agreements:
Due in one year or lessDue in one year or less0 $0 $0 $0 $0 $0 Due in one year or less$ $ $ $ $ $ $ 
Long-term funding agreements:Long-term funding agreements:Long-term funding agreements:
Due in years two through fiveDue in years two through five0 650 0 0 0 650 Due in years two through five1,150 2,450     3,600 
Due in more than five yearsDue in more than five years0 500 0 0 0 500 Due in more than five years800 1,359    (30)2,129 
Total long-term funding agreementsTotal long-term funding agreements0 1,150 0 0 0 1,150 Total long-term funding agreements1,950 3,809    (30)5,729 
Total funding agreements (1)Total funding agreements (1)$0 $1,150 $0 $0 $0 $1,150 Total funding agreements (1)$1,950 $3,809 $ $ $ $(30)$5,729 
_____________
(1)The $7$27 million and $11 million difference between the funding agreements notional value shown and carrying value table atas of September 30,
2021 and December 31, 2020, respectively, reflects the remaining amortization of the issuance cost of the funding agreements.agreements and the foreign currency transaction adjustment.
Guarantees and Other Commitments
The Company provides certain guarantees or commitments to affiliates and others. AtAs of September 30, 2020,2021, these arrangements include commitments by the Company to provide equity financing of $1.2$1.4 billion (including $248$380 million with affiliates) to certain limited partnerships and real estate joint ventures under certain conditions. Management believes the Company will not incur material losses as a result of these commitments.
The Company had $17 million of undrawn letters of credit related to reinsurance as of September 30, 2021. The Company had $714 million of commitments under existing mortgage loan agreements as of September 30, 2021.
The Company is the obligor under certain structured settlement agreements it had entered into with unaffiliated insurance companies and beneficiaries. To satisfy its obligations under these agreements, the Company owns single premium annuities issued by previously wholly-owned life insurance subsidiaries. The Company has directed payment under these annuities to be made directly to the beneficiaries under the structured settlement agreements. A contingent liability exists with respect to these agreements should the previously wholly-owned subsidiaries be unable to meet their obligations. Management believes the need for the Company to satisfy those obligations is remote.
The Company had $17 million
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Table of undrawn letters of credit relatedContents
EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to reinsurance at September 30, 2020. The Company had $469 million of commitments under existing mortgage loan agreements at September 30, 2020.Consolidated Financial Statements (Unaudited), Continued
Pursuant to certain assumption agreements (the “Assumption Agreements”), AXA Financial legally assumed primary liability from Equitable Financial for all current and future liabilities of Equitable Financial under certain employee benefit plans that provide participants with medical, life insurance and deferred compensation benefits as well as under the AXA Equitable Retirement plan, a frozen qualified pension plan. Equitable Financial remains secondarily liable for its obligations under these plans and would recognize such liabilities in the event AXA Financial does not perform under the terms of the Assumption Agreements. On October 1, 2018, AXA Financial merged with and into its direct parent, Holdings, with Holdings continuing as the surviving entity.
14)    REVISION OF PRIOR PERIOD FINANCIAL STATEMENTSSUBSEQUENT EVENTS
TheCoinsurance Funds Withheld Reinsurance Agreement
Effective October 1, 2021, the Company identified certain errors primarilyentered with Swiss Re Life & Health America Inc (“Swiss Re” ), into a coinsurance with funds withheld reinsurance agreement under which the Company retains the assets related to the calculationsunderlying policies, term life insurance policies issued between 2009 and 2020. While the associated interest and credit risk of actuarially determinedthese assets has been transferred to Swiss Re, reinsurance agreements that do not indemnify the Company against loss or liability relating to insurance contractrisk are recorded using the deposit method of accounting. There was no cash or assets and liabilities that impacted previously issued consolidated financial statements. Management evaluated these adjustments and concluded theyexchanged upon entering into this agreement, so no deposit liability has yet been recorded.
The coinsurance with funds withheld agreement contains embedded derivatives related to the withheld assets, which were not material to any previously reported quarterly or annual financial statements. In order to improve the consistency and comparabilityimmaterial as of the financial statements, management revisedeffective date of the financial statements and related disclosures to correct these errors as shown below.
Management assessed the materiality of this change within prior period financial statements based upon SEC Staff Accounting Bulletin Number 99, Materiality, which is since codifiedagreement. Embedded derivatives are recorded at estimated fair value with changes in Accounting Standards Codification ("ASC") 250, Accounting Changes and Error Corrections. The prior period comparative financial statements that are presented herein have been revised.
The following tables present line items for prior period financial statements that have been affected by the revision. For these line items, the tables detail the amounts as previouslyestimated fair value reported the impact upon those line items due to the revision, and the amounts as currently revised within the financial statements.
55

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
in net income.

56

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
June 30, 2020March 31, 2020
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Balance Sheets:
ASSETS
Other invested assets1,962 1,962 1,595 12 1,607 
Deferred policy acquisition costs3,746 (70)3,676 4,068 (85)3,983 
Total Assets$232,378 $(70)$232,308 $218,841 $(73)$218,768 
LIABILITIES
Future policy benefits and other policyholders’ liabilities41,382 29 41,411 37,830 32 37,862 
Current and deferred income taxes1,020 (21)999 1,637 (22)1,615 
Total Liabilities$217,176 $$217,184 $199,928 $10 $199,938 
EQUITY
Retained earnings2,658 (78)2,580 7,953 (83)7,870 
Total equity attributable to Equitable Financial15,157 (78)15,079 18,872 (83)18,789 
Total Equity15,166 (78)15,088 18,881 (83)18,798 
Total Liabilities, Redeemable Noncontrolling interest and Equity232,378 (70)232,308 $218,841 $(73)$218,768 

57

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
December 31, 2019December 31, 2018
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Balance Sheets:
ASSETS
Investments:
Deferred policy acquisition costs4,337 (115)4,222 5,011 (52)4,959 
Amounts due from reinsurers3,001 3,002 3,124 3,124 
GMIB reinsurance contract asset, at fair value2,466 2,466 1,991 1,992 
Current and deferred income taxes224 25 249 438 35 473 
Other assets3,050 3,050 2,763 22 2,785 
Total Assets$228,041 $(89)$227,952 $199,952 $$199,958 
LIABILITIES
Future policy benefits and other policyholders’ liabilities33,976 33,979 29,808 75 29,883 
Other liabilities1,768 1,769 1,460 1,460 
Total Liabilities$216,344 $$216,348 $187,485 $75 $187,560 
EQUITY
Retained earnings2,242 (97)2,145 5,098 (59)5,039 
Accumulated other comprehensive income (loss)1,592 1,596 (491)(10)(501)
Total equity attributable to Equitable Financial11,645 (93)11,552 12,416 (69)12,347 
Total Equity11,658 (93)11,565 12,428 (69)12,359 
Total Liabilities, Redeemable Noncontrolling interest and Equity$228,041 $(89)$227,952 $199,952 $$199,958 


Three Months Ended June 30, 2020Six Months Ended June 30, 2020
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Income (Loss)
REVENUES
Policy charges and fee income$825 $(1)$824 $1,729 $$1,729 
Net derivative gains (losses)(5,903)(5)(5,908)3,630 (6)3,624 
Net investment income (loss)934 (13)921 1,525 1,525 
Other income10 25 25 
Total revenues(3,557)(17)(3,574)8,031 (6)8,025 
BENEFITS AND OTHER DEDUCTIONS
Policyholders' benefits700 (9)691 3,297 20 3,317 
Amortization of deferred policy acquisition costs164 (15)149 1,222 (51)1,171 
Other operating costs and expenses218 218 431 432 
Total benefits and deductions1,563 (24)1,539 5,961 (30)5,931 
Income (loss) from continuing operations, before income taxes(5,120)(5,113)2,070 24 2,094 
Income tax (expense) benefit from continuing operations1,029 (2)1,027 (425)(5)(430)
Net income (loss)(4,091)(4,086)1,645 19 1,664 
Net income (loss) attributable to Equitable Financial$(4,095)$$(4,090)$1,648 $19 $1,667 

58

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Three Months Ended March 31, 2020
As Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Income (Loss)
REVENUES:
Policy charges and fee income904 905 
Net derivative gains (losses)9,533 (1)9,532 
Net investment income (loss)591 13 604 
Other income17 (2)15 
Total revenues11,588 11 11,599 
BENEFITS AND OTHER DEDUCTIONS
Policyholders' benefits2,597 29 2,626 
Interest credited to policyholders’ account balances289 289 
Amortization of deferred policy acquisition costs1,058 (36)1,022 
Other operating costs and expenses213 214 
Total benefits and deductions4,398 (6)4,392 
Income (loss) from continuing operations, before income taxes7,190 17 7,207 
Income tax (expense) benefit from continuing operations(1,454)(3)(1,457)
Net income (loss)5,736 14 5,750 
Net income (loss) attributable to Equitable Financial$5,743 $14 $5,757 

59

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Year Ended December 31, 2019Year Ended December 31, 2018
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Income (Loss)
REVENUES
Policy charges and fee income$3,450 $37 $3,487 $3,523 $(8)$3,515 
Net derivative gains (losses)(3,820)(11)(3,831)(1,010)(24)(1,034)
Other income56 56 65 (1)64 
Total revenues5,148 26 5,174 6,951 (33)6,918 
BENEFITS AND OTHER DEDUCTIONS
Policyholders' benefits4,119 (31)4,088 3,005 (45)2,960 
Interest credited to policyholders’ account balances1,127 22 1,149 1,002 (23)979 
Commissions629 629 620 625 
Amortization of deferred policy acquisition costs452 68 520 431 20 451 
Other operating costs and expenses912 912 2,918 2,919 
Total benefits and deductions7,578 59 7,637 8,432 (42)8,390 
Income (loss) from continuing operations, before income taxes(2,430)(33)(2,463)(1,481)(1,472)
Income tax (expense) benefit from continuing operations584 (5)579 446 10 456 
Net income (loss)(1,846)(38)(1,884)(921)19 (902)
Net income (loss) attributable to Equitable Financial$(1,851)$(38)$(1,889)$(918)$19 $(899)

60

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Three Months Ended September 30, 2019Nine Months Ended September 30, 2019
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Income (Loss)
REVENUES
Policy charges and fee income$853 $46 $899 $2,577 $42 $2,619 
Net derivative gains (losses)(342)(1)(343)(2,075)(5)(2,080)
Other income(1)(1)40 (1)39 
Total revenues1,946 44 1,990 4,707 36 4,743 
BENEFITS AND OTHER DEDUCTIONS
Policyholders' benefits1,634 1,642 3,321 35 3,356 
Interest credited to policyholders’ account balances280 16 296 837 22 859 
Amortization of deferred policy acquisition costs32 22 54 341 345 
Total benefits and deductions2,383 46 2,429 5,816 61 5,877 
Income (loss) from continuing operations, before income taxes(437)(2)(439)(1,109)(25)(1,134)
Income tax (expense) benefit from continuing operations175 175 284 289 
Net income (loss)(262)(2)(264)(825)(20)(845)
Net income (loss) attributable to Equitable Financial$(262)$(2)$(264)$(828)$(20)$(848)

61

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Three Months Ended June 30, 2019Six Months Ended June 30, 2019
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Income (Loss)
REVENUES
Policy charges and fee income$865 $(2)$863 $1,724 $(4)$1,720 
Net derivative gains (losses)(178)(1)(179)(1,733)(4)(1,737)
Total revenues2,071 (3)2,068 2,761 (8)2,753 
BENEFITS AND OTHER DEDUCTIONS
Policyholders' benefits868 (7)861 1,687 27 1,714 
Interest credited to policyholders’ account balances288 291 557 563 
Amortization of deferred policy acquisition costs144 (2)142 309 (18)291 
Total benefits and deductions1,753 (6)1,747 3,433 15 3,448 
Income (loss) from continuing operations, before income taxes318 321 (672)(23)(695)
Income tax (expense) benefit from continuing operations(53)(53)109 114 
Net income (loss)265 268 (563)(18)(581)
Net income (loss) attributable to Equitable Financial$264 $$267 $(566)$(18)$(584)


Three Months Ended March 31, 2019
As Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Income (Loss)
REVENUES:
Policy charges and fee income859 (2)857 
Net derivative gains (losses)(1,555)(3)(1,558)
Net investment income (loss)904 904 
Other income10 10 
Total revenues690 (5)685 
BENEFITS AND OTHER DEDUCTIONS
Policyholders' benefits819 34 853 
Interest credited to policyholders’ account balances269 272 
Amortization of deferred policy acquisition costs165 (16)149 
Other operating costs and expenses184 184 
Total benefits and deductions1,680 21 1,701 
Income (loss) from continuing operations, before income taxes(990)(26)(1,016)
Income tax (expense) benefit from continuing operations162 167 
Net income (loss)(828)(21)(849)
Net income (loss) attributable to Equitable Financial$(830)$(21)$(851)
62

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Year Ended December 31, 2017
As Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Income (Loss)
REVENUES:
Policy charges and fee income3,294 (5)3,289 
Net derivative gains (losses)894 (16)878 
Total revenues8,456 (21)8,435 
BENEFITS AND OTHER DEDUCTIONS
Policyholders' benefits3,473 3,481 
Commissions628 635 
Amortization of deferred policy acquisition costs900 25 925 
Total benefits and deductions6,907 40 6,947 
Income (loss) from continuing operations, before income taxes1,549 (61)1,488 
Income tax (expense) benefit from continuing operations1,210 1,218 
Net income (loss) from continuing operations2,759 (53)2,706 
Net income (loss)2,844 (53)2,791 
Net income (loss) attributable to Equitable Financial$2,843 $(53)$2,790 

Three Months Ended June 30, 2020Six Months Ended June 30, 2020
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Comprehensive Income (Loss)
Net income (loss)$(4,091)$$(4,086)$1,645 $19 $1,664 
Change in unrealized gains (losses), net of reclassification adjustment1,569 1,569 3,083 (4)3,079 
Other comprehensive income1,570 1,570 3,084 (4)3,080 
Comprehensive income (loss)(2,521)(2,516)4,729 15 4,744 
Less: Comprehensive income (loss) attributable to noncontrolling interest(3)(3)(3)
Comprehensive income (loss) attributable to Equitable Financial$(2,518)$(2)$(2,520)$4,732 $15 $4,747 

63

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Three Months Ended March 31, 2020
As Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Comprehensive Income (Loss)
Net income (loss)$5,736 $14 $5,750 
Change in unrealized gains (losses), net of reclassification adjustment1,514 (4)1,510 
Other comprehensive income1,514 (4)1,510 
Comprehensive income (loss)7,250 10 7,260 
Comprehensive income (loss) attributable to Equitable Financial$7,257 $10 $7,267 

64

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Year Ended December 31, 2019Year Ended December 31, 2018
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Comprehensive Income (Loss)
Net income (loss)$(1,846)$(38)$(1,884)$(921)$19 $(902)
Change in unrealized gains (losses), net of reclassification adjustment2,081 14 2,095 (1,230)(1,221)
Other comprehensive income2,083 14 2,097 (1,234)(1,225)
Comprehensive income (loss)237 (24)213 (2,155)28 (2,127)
Less: Comprehensive income (loss) attributable to noncontrolling interest(3)(3)
Comprehensive income (loss) attributable to Equitable Financial$237 $(29)$208 $(2,155)$31 $(2,124)

65

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Three Months Ended September 30, 2019Nine Months Ended September 30, 2019
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Comprehensive Income (Loss)
Net income (loss)$(262)$(2)$(264)$(825)$(20)$(845)
Change in unrealized gains (losses), net of reclassification adjustment574 156 730 2,629 92 2,721 
Other comprehensive income574 156 730 2,629 92 2,721 
Comprehensive income (loss)312 154 466 1,804 72 1,876 
Less: Comprehensive income (loss) attributable to noncontrolling interest
Comprehensive income (loss) attributable to Equitable Financial$312 $154 $466 $1,804 $69 $1,873 

66

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Three Months Ended June 30, 2019Six Months Ended June 30, 2019
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Comprehensive Income (Loss)
Net income (loss)$265 $$268 $(563)$(18)$(581)
Change in unrealized gains (losses), net of reclassification adjustment1,291 (65)1,226 2,055 (64)1,991 
Other comprehensive income1,291 (65)1,226 2,055 (64)1,991 
Comprehensive income (loss)1,556 (62)1,494 1,492 (82)1,410 
Less: Comprehensive income (loss) attributable to noncontrolling interest
Comprehensive income (loss) attributable to Equitable Financial$1,556 $(63)$1,493 $1,492 $(85)$1,407 

Three Months Ended March 31, 2019
As Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Comprehensive Income (Loss)
Net income (loss)$(828)$(21)$(849)
Change in unrealized gains (losses), net of reclassification adjustment764 765 
Other comprehensive income764 765 
Comprehensive income (loss)(64)(20)(84)
Less: Comprehensive income (loss) attributable to noncontrolling interest
Comprehensive income (loss) attributable to Equitable Financial$(64)$(22)$(86)
Year Ended December 31, 2017
As Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Comprehensive Income:
Net income (loss)$2,844 $(53)$2,791 
Change in unrealized gains (losses), net of reclassification adjustment584 (20)564 
Other comprehensive income602 (20)582 
Comprehensive income (loss)3,446 (73)3,373 
Less: Comprehensive income (loss) attributable to noncontrolling interest
Comprehensive income (loss) attributable to Equitable Financial$3,446 $(74)$3,372 

67

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Three Months Ended June 30, 2020Six Months Ended June 30, 2020
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Equity:
Retained earnings, beginning of year$7,953 $(83)$7,870 $2,242 $(97)$2,145 
Net income (loss) attributable to Equitable Financial(4,095)(4,090)1,648 19 1,667 
Retained earnings, end of period$2,658 $(78)$2,580 $2,658 $(78)$2,580 
Accumulated other comprehensive income (loss), beginning of year$3,106 $$3,106 $1,592 $$1,596 
Other comprehensive income (loss)1,570 1,570 3,084 (4)3,080 
Total Equitable Financial equity, end of period$15,157 $(78)$15,079 $15,157 $(78)$15,079 
Total equity, end of period$15,166 $(78)$15,088 $15,166 $(78)$15,088 

68

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Three Months Ended March 31, 2020
As Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Equity:
Retained earnings, beginning of year$2,242 $(97)$2,145 
Net income (loss) attributable to Equitable Financial5,743 $14 5,757 
Retained earnings, end of period$7,953 $(83)$7,870 
Accumulated other comprehensive income (loss), beginning of year$1,592 $$1,596 
Other comprehensive income (loss)1,514 (4)1,510 
Total Equitable Financial equity, end of period$18,872 $(83)$18,789 
Total equity, end of period$18,881 $(83)$18,798 

69

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Year Ended December 31, 2019Year Ended December 31, 2018
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Equity:
Retained earnings, beginning of year$5,098 $(59)$5,039 $8,938 $(78)$8,860 
Net income (loss) attributable to Equitable Financial(1,851)(38)(1,889)(918)19 (899)
Retained earnings, end of year$2,242 $(97)$2,145 $5,098 $(59)$5,039 
Accumulated other comprehensive income (loss), beginning of year$(491)$(10)$(501)$598 $(19)$579 
Other comprehensive income (loss)2,083 14 2,097 (1,234)(1,225)
Accumulated other comprehensive income (loss), end of year$1,592 $$1,596 $(491)$(10)$(501)
Total Equitable Financial equity, end of year$11,645 $(93)$11,552 $12,416 $(69)$12,347 
Total equity, end of year$11,658 $(93)$11,565 $12,428 $(69)$12,359 

70

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Three Months Ended September 30, 2019Nine Months Ended September 30, 2019
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Equity:
Retained earnings, beginning of year$4,532 $(77)$4,455 $5,098 $(59)$5,039 
Net income (loss) attributable to Equitable Financial(262)(2)(264)(828)(20)(848)
Retained earnings, end of period$3,270 $(79)$3,191 $3,270 $(79)$3,191 
Accumulated other comprehensive income (loss), beginning of year$1,564 $(74)$1,490 $(491)$(10)$(501)
Other comprehensive income (loss)574 156 730 2,629 92 2,721 
Accumulated other comprehensive income (loss), end of period$2,138 $82 $2,220 $2,138 $82 $2,220 
Total Equitable Financial equity, end of period$13,239 $$13,242 $13,239 $$13,242 
Total equity, end of period$13,251 $$13,254 $13,251 $$13,254 


71

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
Three Months Ended June 30, 2019Six Months Ended June 30, 2019
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Equity:
Retained earnings, beginning of year$4,268 $(80)$4,188 $5,098 $(59)$5,039 
Net income (loss) attributable to Equitable Financial264 267 (566)(18)(584)
Retained earnings, end of period$4,532 $(77)$4,455 $4,532 $(77)$4,455 
Accumulated other comprehensive income (loss), beginning of year$273 $(9)$264 $(491)$(10)$(501)
Other comprehensive income (loss)1,291 (65)1,226 2,055 (64)1,991 
Accumulated other comprehensive income (loss), end of period$1,564 $(74)$1,490 $1,564 $(74)$1,490 
Total Equitable Financial equity, end of period$13,920 $(151)$13,769 $13,920 $(151)$13,769 
Total equity, end of period$13,932 $(151)$13,781 $13,932 $(151)$13,781 

Three Months Ended March 31, 2019
As Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Equity:
Retained earnings, beginning of year$5,098 $(59)$5,039 
Net income (loss) attributable to Equitable Financial(830)$(21)(851)
Retained earnings, end of period$4,268 $(80)$4,188 
Accumulated other comprehensive income (loss), beginning of year$(491)$(10)$(501)
Other comprehensive income (loss)764 765 
Accumulated other comprehensive income (loss), end of period$273 $(9)$264 
Total Equitable Financial equity, end of period$12,358 $(89)$12,269 
Total equity, end of period$12,370 $(89)$12,281 
Year Ended December 31, 2017
As Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Equity:
Retained earnings, beginning of year$6,095 $(25)$6,070 
Net income (loss) attributable to Equitable Financial2,843 $(53)2,790 
Retained earnings, end of period$8,938 $(78)$8,860 
Accumulated other comprehensive income (loss), beginning of year$(4)$$(3)
Other comprehensive income (loss)602 (20)582 
Accumulated other comprehensive income (loss), end of period$598 $(19)$579 
Total Equitable Financial equity, end of period$16,397 $(97)$16,300 
Total equity, end of period$19,492 $(97)$19,395 

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued


June 30, 2020March 31, 2020
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Cash Flows:
Cash flow from operating activities:
Net income (loss)$1,645 $19 $1,664 $5,736 $14 $5,750 
Policy charges and fee income(1,729)(1,729)(904)(1)(905)
Net derivative (gains) losses(3,630)(3,624)(9,533)(9,532)
Amortization and depreciation1,181 (51)1,130 1,025 (35)990 
Future policy benefits1,666 20 1,686 1,817 29 1,846 
Reinsurance recoverable(149)(149)(97)(96)
Current and deferred income taxes433 439 1,462 1,465 
Net cash provided by (used in) operating activities$(868)$$(868)$(621)$12 $(609)
Change in collateralized pledged assets58 58 45 (1)44 
Change in collateralized pledged liabilities247 247 667 (11)656 
Net cash provided by (used in) financing activities$2,308 $$2,308 $2,504 $(12)$2,492 
Cash and cash equivalents, end of period$4,318 $$4,318 $7,492 $$7,492 

73

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
December 31, 2019December 31, 2018
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Cash Flows:
Cash flow from operating activities:
Net income (loss) (1)$(1,846)$(38)$(1,884)$(358)$19 $(339)
Adjustments to reconcile Net income (loss) to Net cash provided by (used in) operating activities:
Policy charges and fee income(3,450)(37)(3,487)(3,523)(3,515)
Interest credited to policyholders' account balances1,127 22 1,149 1,002 (23)979 
Net derivative (gains) losses3,820 11 3,831 1,010 24 1,034 
Amortization and depreciation323 68 391 340 20 360 
Capitalization of DAC(648)(648)(597)(592)
Future policy benefits1,115 (31)1,084 (284)(46)(330)
Current and deferred income taxes(334)(329)(556)(7)(563)
Net cash provided by (used in) operating activities$(606)$$(606)$1,418 $$1,418 
Cash and cash equivalents, end of period$1,492 $$1,492 $2,622 $$2,622 
_____________
(1) December 31, 2018 Net Income (Loss) includes $563 millionTable of discontinued operations that are not included in Net Income (Loss) in the Consolidated Statement of Income (Loss).

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
September 30, 2019June 30, 2019
As Previously
Reported
Impact of RevisionsAs RevisedAs Previously ReportedImpact of RevisionsAs Revised
(in millions)
Consolidated Statements of Cash Flows:
Cash flow from operating activities:
Net income (loss)$(825)$(20)$(845)$(563)$(18)$(581)
Adjustments to reconcile Net income (loss) to Net cash provided by (used in) operating activities:
Policy charges and fee income(2,577)(42)(2,619)(1,724)(1,720)
Interest credited to policyholders' account balances837 22 859 557 563 
Net derivative (gains) losses2,075 2,080 1,733 1,737 
Amortization and depreciation267 271 268 (18)250 
Future policy benefits1,035 40 1,075 91 27 118 
Reinsurance recoverable(123)(4)(127)(59)(59)
Current and deferred income taxes(81)(5)(86)99 (5)94 
Net cash provided by (used in) operating activities$(712)$$(712)$(283)$$(283)
Cash and cash equivalents, end of period$1,553 $$1,553 $3,093 $$3,093 










75

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
Notes to Consolidated Financial Statements(Unaudited), Continued
March 31, 2019
As Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Cash Flows:
Cash flow from operating activities:
Net income (loss)$(828)$(21)$(849)
Adjustments to reconcile Net income (loss) to Net cash provided by (used in) operating activities:
Policy charges and fee income(859)(857)
Interest credited to policyholders' account balances269 272 
Net derivative (gains) losses1,555 1,558 
Amortization and depreciation143 (16)127 
Future policy benefits41 34 75 
Current and deferred income taxes54 (5)49 
Net cash provided by (used in) operating activities$(148)$$(148)
Cash and cash equivalents, end of period2,922 2,922 

December 31, 2017
As Previously
Reported
Impact of RevisionsAs Revised
(in millions)
Consolidated Statements of Cash Flows:
Cash flow from operating activities:
Net income (loss) (1)$3,377 $(54)$3,323 
Adjustments to reconcile Net income (loss) to Net cash provided by (used in) operating activities:
Policy charges and fee income(3,294)(3,289)
Net derivative (gains) losses(870)16 (854)
Amortization and depreciation825 25 850 
Future policy benefits1,189 1,197 
Net cash provided by (used in) operating activities$(381)$$(381)
Cash and cash equivalents, end of period3,409 3,409 
_____________
(1) Net Income (Loss) includes $533 million of discontinued operations that are not included in Net Income (Loss) in the Consolidated Statement of Income (Loss).
15)    SUBSEQUENT EVENTS
On October 27, 2020, Holdings entered into a Master Transaction Agreement with Venerable Insurance and Annuity Company (“VIAC”), and Venerable Holdings, Inc., a Delaware corporation. VIAC will acquire all of the shares of the capital stock of Corporate Solutions Life Reinsurance Company (“CSLRC”), and, immediately following such sale, Equitable Financial will enter into a coinsurance and modified coinsurance agreement, pursuant to which Equitable Financial will cede to CSLRC, on a combined coinsurance and modified coinsurance basis, legacy variable annuity policies sold by Equitable Financial between 2006-2008 supported by general account assets of approximately $12 billion (the “Block”), comprised of non-New York “Accumulator” policies containing fixed rate Guaranteed Minimum Income Benefit and/or Guaranteed Minimum Death Benefit guarantees. Equitable Financial will reinsure the separate accounts relating to the Block on a modified coinsurance basis. Equitable Financial will also acquire a surplus note in aggregate principal amount of $50 million issued by VIAC in the transaction.
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Contents
Item 2.    Management’s Discussion and Analysis of Financial Condition and Results of Operations
Management’s discussion and analysis of financial condition and results of operations is presented pursuant to General Instruction (H)(2)(a) of Form 10-Q. The management’s narrative that follows should be read in conjunction with the consolidated financial statements and the related Notes to Consolidated Financial Statements included elsewhere herein, with the information provided under “Note Regarding Forward-looking Statements and Information” included elsewhere herein and Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”) in Part II, Item 7 and “Risk Factors” in Part I, Item 1A included in Equitable Financial’s Annual Report on Form 10-K for the year ended December 31, 20192020 (“20192020 Form 10-K”). The management’s narrative that follows represents a discussion and analysis of Equitable Financial’s financial condition and results of operations and not the financial condition and results of operations of Equitable Holdings, Inc. (“Holdings”).
Executive Summary
Overview
We are one of America’s leading financial services companies, providing advice and solutions for helping Americans set and meet their retirement goals and protect and transfer their wealth across generations. We operate as a single segment entity based on the manner in which we use financial information to evaluate business performance and to determine the allocation of resources. We benefit from our complementary mix of product offerings. This mix in product offerings provides diversity in our earnings sources, which helps offset fluctuations in market conditions and variability in business results, while offering growth opportunities.
Reinsurance of Legacy Variable Annuity Block and Sale of Runoff Variable Annuity Reinsurance Entity
On October 27, 2020,June 1, 2021, Holdings completed its previously announced that it had entered into a Master Transaction Agreement with Venerable Insurance and Annuity Company, an insurance company domiciled in Iowa (“VIAC”sale (the “Transaction”), and Venerable Holdings, Inc., a Delaware corporation, pursuant to which, among other things, VIAC will acquire all of the shares of the capital stock of Corporate Solutions Life Reinsurance Company, an insurance company domiciled in Delaware and wholly owned subsidiary of Holdings (“CSLRC”), to Venerable Insurance and immediately following such sale,Annuity Company, an insurance company domiciled in Iowa (“VIAC”), pursuant to the Master Transaction Agreement, dated October 27, 2020 (the “Master Transaction Agreement”), among the Company, VIAC and, solely with respect to Article XIV thereof, Venerable Holdings, Inc., a Delaware corporation (“Venerable”). VIAC issued a surplus note in aggregate principal amount of $50 million to Equitable Financial will enterfor cash consideration.
Immediately following the closing of the Transaction, CSLRC and Equitable Financial entered into a coinsurance and modified coinsurance agreement (the “Reinsurance Agreement”), pursuant to which Equitable Financial will cedeceded to CSLRC, on a combined coinsurance and modified coinsurance basis, legacy variable annuity policies sold by Equitable Financial between 2006-2008 supported by general account assets of approximately $12 billion (the “Block”), comprised of non-New York “Accumulator” policies containing fixed rate Guaranteed Minimum Income Benefit and/or Guaranteed Minimum Death Benefit guarantees. Equitable Financial will reinsureAt the separate accountsclosing of the Transaction, CSLRC deposited assets supporting the general account liabilities relating to the Block oninto a trust account for the benefit of Equitable Financial, which assets will secure its obligations to Equitable Financial under the Reinsurance Agreement. The Company transferred assets of $9.5 billion, including primarily available for sale securities and cash, to a collateral trust account as the consideration for the reinsurance transaction. In addition, the Company recorded $9.6 billion of direct insurance liabilities ceded under the reinsurance contract, of which $5.3 billion is accounted at fair value, as the reinsurance of GMxB with no lapse guarantee riders are embedded derivatives. Additionally, $16.9 billion of Separate Account liabilities were ceded under a modified coinsurance basis.portion of the agreement.
In addition, upon the completion of the Transaction, Equitable Investment Management Group, LLC (“EIMG”), a wholly owned subsidiary of the Company, acquired an approximate 9.09% equity interest in Venerable’s parent holding company, VA Capital Company LLC. In connection with such investment, EIMG designated a member to the Board of Managers of VA Capital Company LLC.
Transfer of Investment Management and Administration Agreements to EIM
On June 22, 2021, Holdings formed Equitable Investment Management, LLC (“EIM”), a wholly owned indirect subsidiary of Holdings. Effective August 1, 2021, EIMG terminated, and EIM, entered into certain administrative agreements with separate accounts held by Equitable Financial. In addition, on October 1, 2021, Equitable Financial entered into an investment advisory and management agreement in which EIM will also acquire a surplus notebecome the investment manager for the Equitable Financial’s general account portfolio. The impact in aggregate principal amountfuture net earnings is expected to be immaterial.

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Table of $50 million issued by VIAC in the transaction.Contents

COVID-19 Impact
We continue to closely monitor developments related to the COVID-19 pandemic. The COVID-19 pandemic has negatively impactedextent of the U.S. and global economies. Inpandemic’s impact on us will depend on future developments that remain highly uncertain. It is not possible to predict or estimate the third quarter, financial markets continued to experience significant volatility and unemployment levels remained high. The pandemic continues to evolve in the U.S., and while certain states and municipalities have re-opened, others are pausing re-opening plans or reinstating lockdowns due to surges in COVID-19 cases. States and municipalities have instituted varying plans for in-person instruction at schools, but surging national infection rates and the possibilitylonger-term effects of a localized outbreak create uncertainty and threaten continued in-person instruction. The effects from the pandemic, are likelyor any additional actions taken to persist for months to come. Governments aroundcontain or address the world continued to implement economic stimulus measures that are intended to steady businesses and consumers until economic activity and financial markets meaningfully recover. The timing and magnitude of any such recovery, however, remains uncertain.
As a financial services company, factors such as the volatility and strength of equity markets, interest rates, consumer spending, and government debt and spending all affect the business and economic environment and, ultimately, the amount and profitability of our business. During the current economic downturn, the demand for our products and services and our investment returns could be materially and adversely affected. In addition, the growing number of COVID-19 related deaths could have an adverse effect on our insurance business due to increased mortality and, in certain cases, morbidity rates.
To date, COVID-related impacts, including adverse mortality experience, have been manageable and below initial expectations. In response to the current environment, we are adapting our processes to meet client needs. For example, we have modified our underwriting policies to offer a fluid-less, touchless process to help more clients access the protection they need. In addition, we have accelerated our digital adoption programs, leading to improved outcomes for clients, advisors, and the company. With schools closed and an uncertain outlook on reopening, we have developed digital tools and enhanced our
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remote engagement with our educator clients, which is resulting in improved retention and increases in retirement plan contributions.
Action taken by state insurance departments, including the NYDFS, to require insurers to offer flexible premium payment plans, relax payment dates, waive late fees and penalties in order to avoid canceling or non-renewing polices may negatively affect our results of operations. Additionally, the profitability of many of our retirement, protection and investment products depends in partpandemic, on the value of the AUM supporting them, which has declinedeconomy and may continue to decline substantially depending on any of the foregoing conditions. The ongoing economic impact and the potential for continued volatility and declines in the capital markets could have a significant adverse effect on our business, results of operations, and financial condition, particularly if economic activity and financialincluding the impact on our investment portfolio or the need for us to revisit or revise targets previously provided to the markets do not recover and/or recover slowly.
While the COVID-19 pandemic significantly affected the capital markets and economy, we believe the actions we have previously taken help assure that our economic balance sheet is protected from interest rate and equity declines. These actions include redesigning our product portfolio to concentrate on offering less capital intensive products and implementing a hedging strategy that manages and protects against the economic risks associated with our in-force GMxB products. In addition to our hedging strategy, we employ various other methods to manage the risksaspects of our in-force variable annuity products, including asset-liability matching, volatility management tools within the Separate Accounts and an active in-force management program, including buyout offers for certain products. Our General Account was impacted both from declining interest rates, which had a positive effect on fair value, and sharply increased credit spreads, which had a negative impact on fair value. Due to the General Account’s exposure to U.S. government bonds and credit quality of the portfolio, we feel that our balance sheet is well positioned to withstand the extreme volatility in the capital markets.
In light of the unprecedented decline in long-term interest rates in the first quarter of 2020, we updated our long-term GAAP interest rate assumption to grade from current rates over 10-years to the 5-year historical average (currently 2.25%). For additional information, see “—Significant Factors Impacting Our Results—Assumption Updates and Model Changes.”
Operationally, we acted quickly and implemented our risk management and contingency plans as the COVID-19 pandemic evolved. For example, among other things, we implemented travel restrictions, imposed self-quarantine requirements for employees and affiliated advisors who were exposed to someone who tested positive or had traveled to certain countries with active COVID-19 outbreaks and, finally, we temporarily closed our corporate locations and affiliated advisor branch offices. As a result, most of our employee and affiliated advisors are currently working remotely. The remote working arrangement has detracted from the ability of our affiliated advisors to sell our products in the normal course and, as a result, the demand for our products and services has been adversely impacted and could decline further as the pandemic persists. We are also mindful that an extended period of remote work arrangements could strain our business continuity plans, introduce additional operational risk, including cybersecurity and privacy risks, and impair our ability to effectively manage our business.
While the COVID-19 pandemic has negatively impacted our business and financial results, the extent and nature of its full financial impact cannot reasonably be estimated at this time due to the uncertainty as to the severity and duration of the pandemic.model. For additional information regarding the potential impacts of the COVID-19 pandemic and action we have taken to mitigate certain impacts, see “Risk Factors—Risks Relating to Conditions in the Financial Markets and Economy—The novel coronavirus (COVID-19) pandemic has adversely impacted our businesspandemic” and could materially adversely affect our business, results“Management’s Discussion and Analysis of operation or financial conditionFinancial Condition and Results of Operations—Executive Summary—COVID-19 Impact” in the future.” in our Forms 10-Q for the quarters ended March 31, 2020 and June 30, 2020.Form 10-K.
Revenues
Our revenues come from three principal sources:
fee income derived from our productsproducts;
premiums from our traditional life insurance and annuity products; and
investment income from our General Account investment portfolio.
Our fee income varies directly in relation to the amount of the underlying AV or benefit base of our life insurance and annuity products which are influenced by changes in economic conditions, primarily equity market returns, as well as net flows. Our premium income is driven by the growth in new policies written and the persistency of our in-force policies, both of which are influenced by a combination of factors, including our efforts to attract and retain customers and market conditions that influence demand for our products. Our investment income is driven by the yield on our General Account investment portfolio
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and is impacted by the prevailing level of interest rates as we reinvest cash associated with maturing investments and net flows to the portfolio.
Benefits and Other Deductions
Our primary expenses are:
policyholders’ benefits and interest credited to policyholders’ account balances;
sales commissions and compensation paid to intermediaries and advisors that distribute our products and services; and
compensation and benefits provided to our employees and other operating expenses.
Policyholders’ benefits are driven primarily by mortality, customer withdrawals and benefits which change in response to changes in capital market conditions. In addition, some of our policyholders’ benefits are directly tied to the AV and benefit base of our variable annuity products. Interest credited to policyholders varies in relation to the amount of the underlying AV or benefit base. Sales commissions and compensation paid to intermediaries and advisors vary in relation to premium and fee income generated from these sources, whereas compensation and benefits to our employees are more constant and impacted by market wages and decline with increases in efficiency. Our ability to manage these expenses across various economic cycles and products is critical to the profitability of our company.
Net Income Volatility
We have offered and continue to offer variable annuity products with GMxB features. The future claims exposure on these features is sensitive to movements in the equity markets and interest rates. Accordingly, we have implemented hedging and reinsurance programs designed to mitigate the economic exposure to us from these features due to equity market and interest rate movements. Changes in the values of the derivatives associated with these programs due to equity market and interest rate movements are recognized in the periods in which they occur while corresponding changes in offsetting liabilities not measured at fair value, are recognized over time. This results in net income volatility as further described below. See “—Significant Factors Impacting Our Results—Impact of Hedging and GMIB Reinsurance on Results.”
In addition to our dynamic hedging strategy, we have static hedge positions designed to mitigate the adverse impact of changing market conditions on our statutory capital. We believe this program will continue to preserve the economic value of
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Table of Contents
our variable annuity contracts and better protect our target variable annuity asset level. However, these static hedge positions increase the size of our derivative positions and may result in higher net income volatility on a period-over-period basis.
An additional source of Netnet income (loss) volatility is the impact of the Company’s annual actuarial assumption review. See “—Significant Factors Impacting Our Results—Assumption Updates and Model Changes”, for further detail of the impact of assumption updates on Netnet income (loss) in first quarter 2020.
Significant Factors Impacting Our Results
The following significant factors have impacted, and may in the future impact, our financial condition, results of operations or cash flows.
Impact of Hedging and GMIBGMxB Reinsurance on Results
We have offered and continue to offer variable annuity products with GMxB features. The future claims exposure on these features is sensitive to movements in the equity markets and interest rates. Accordingly, we have implemented hedging and reinsurance programs designed to mitigate the economic exposure to us from these features due to equity market and interest rate movements. These programs include:
Variable annuity hedging programs. We use a dynamic hedging program (within this program, generally, we reevaluate our economic exposure at least daily and rebalance our hedge positions accordingly) to mitigate certain risks associated with the GMxB features that are embedded in our liabilities for our variable annuity products. This program utilizes various derivative instruments that are managed in an effort to reduce the economic impact of unfavorable changes in GMxB features’ exposures attributable to movements in the equity markets and interest rates. Although this program is designed to provide a measure of economic protection against the impact of adverse market conditions, it does not qualify for hedge accounting treatment. Accordingly, changes in value of the derivatives will be recognized in the period in which they occur with offsetting changes in reserves partially recognized in the current period, resulting in net income volatility. In addition to our dynamic hedging program, we have a hedging program using static hedge positions (derivative positions intended to be held-to-maturity with less frequent re-balancing) to protect our statutory capital
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against stress scenarios. This program in addition to our dynamic hedge program has increased the size of our derivative positions, resulting in an increase in net income volatility.
GMIBGMxB reinsurance contracts. Historically, GMIB reinsurance contracts were used to cede to affiliated and non-affiliated reinsurers a portion of our exposure to variable annuity products that offer a GMIB feature. We account for the GMIB reinsurance contracts as derivatives and report them at fair value. Gross GMIB reserves are calculated on the basis of assumptions related to projected benefits and related contract charges over the lives of the contracts. Accordingly, our gross reserves will not immediately reflect the offsetting impact on future claims exposure resulting from the same capital market or interest rate fluctuations that cause gains or losses on the fair value of the GMIB reinsurance contracts. Because changes in the fair value of the GMIB reinsurance contracts are recorded in the period in which they occur and a majority of the changes in gross reserves for GMIB are recognized over time, net income will be more volatile. In addition, on June 1, 2021, we ceded legacy variable annuity policies sold by EFLIC between 2006-2008 (the “Block”), comprised of non-New York “Accumulator” policies containing fixed rate GMIB and/or GMDB guarantees. As this contract provides full risk transfer, the benefits of this treaty are accounted for in the same manner as the underlying gross reserves.
Effect of Assumption Updates on Operating Results
Our actuaries oversee the valuation of the product liabilities and assets and review the underlying inputs and assumptions. We comprehensively review the actuarial assumptions underlying these valuations and update assumptions during the third quarter of each year. Assumptions are based on a combination of Company experience, industry experience, management actions and expert judgment and reflect our best estimate as of the date of the applicable financial statements. Changes in assumptions can result in a significant change to the carrying value of product liabilities and assets and, consequently, the impact could be material to earnings in the period of the change.
Most of the variable annuity products, variable universal life insurance and universal life insurance products we offer maintain policyholder deposits that are reported as liabilities and classified within either Separate Accounts liabilities or policyholder account balances. Our products and riders also impact liabilities for future policyholder benefits and unearned revenues and assets for DAC and DSI. The valuation of these assets and liabilities (other than deposits) are based on differing accounting methods depending on the product, each of which requires numerous assumptions and considerable judgment. The accounting guidance applied in the valuation of these assets and liabilities includes, but is not limited to, the following:
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(i) traditional life insurance products for which assumptions are locked in at inception; (ii) universal life insurance and variable life insurance secondary guarantees for which benefit liabilities are determined by estimating the expected value of death benefits payable when the account balance is projected to be zero and recognizing those benefits ratably over the accumulation period based on total expected assessments; (iii) certain product guarantees for which benefit liabilities are accrued over the life of the contract in proportion to actual and future expected policy assessments; and (iv) certain product guarantees reported as embedded derivatives at fair value.
For further details of our accounting policies and related judgments pertaining to assumption updates, see Note 2 toof the Notes to the Company’s consolidated financial statementsConsolidated Financial Statements and “—Summary“Summary of Critical Accounting Estimates —LiabilityEstimates—Liability for Future Policy Benefits” included in the 20192020 Form 10-K.
Assumption Updates and Model Changes
We conduct our annual review of our assumptions and models during the third quarter of each year. However, weWe also update our assumptions as needed in the event we become aware of economic conditions or events that could require a change in our assumptions that we believe may have a significant impact to the carrying value of product liabilities and assets and consequently materially impact our earnings in the period of the change.
Impact of Assumption Updates and Model Changes on Income from Continuing Operations before income taxes and Net income (loss)
The table below presents the impact of our actuarial assumption update during the three and nine months ended September 30, 20202021 and 20192020 to our Incomeincome (loss) from continuing operations, before income taxes and Netnet income (loss).
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Three Months Ended September 30,Nine Months Ended September 30, (1)
2021202020212020
(in millions)
Impact of assumption update on Net income (loss):
Variable annuity product features related assumption update$(146)$(41)$(146)$(1,496)
All other assumption updates(16)(83)(16)(750)
Impact of assumption updates on Income (loss) from continuing operations, before income tax(162)(124)(162)(2,246)
Income tax (expense) benefit on assumption update34 26 34 472 
Net income (loss) impact of assumption update$(128)$(98)$(128)$(1,774)
Three Months Ended September 30,Nine Months Ended September 30, (1)
2020201920202019
(in millions)
Impact of assumption update on Net income (loss):
Variable annuity product features related assumption update$(41)$(1,438)$(1,496)$(1,438)
Assumption updates for other business(83)84 (750)84 
Impact of assumption updates on Income (loss) from continuing operations, before income tax(124)(1,354)(2,246)(1,354)
Income tax (expense) benefit on assumption update26 284 472 284 
Net income (loss) impact of assumption update$(98)$(1,070)$(1,774)$(1,070)
______________
(1)During the first quarter of 2020, we updated interest rate assumption and the impact was a decrease to Net income (loss) of $1.7 billion. See Note 2 for further details on the assumption update.
2021 Assumption Updates
The impact of the economic assumption update in the third quarter of 2021 was a decrease of $162 million to income (loss) from continuing operations, before income taxes and a decrease to net income (loss) of $128 million. As part of this annual update, the reference interest rate utilized in our GAAP fair value calculations was updated from the LIBOR swap curve to the US Treasury curve due to the impending cessation of LIBOR and our GAAP fair value liability risk margins were increased, resulting in little impact to overall valuation as our view regarding market participant pricing of our guarantees has not changed at this time.
The net impact of this assumption update on income (loss) from continuing operations, before income taxes of $162 million consisted of a decrease in policy charges and fee income of $32 million, a decrease in policyholders’ benefits of $100 million, a decrease in net derivative gains of $249 million and a decrease in the amortization of DAC of $19 million.
2020 Assumption Updates
Annual Update
The impact of the economic assumption update in the third quarter of 2020 was a decrease of $124 million to Incomeincome (loss) from continuing operations, before income taxes and a decrease to Netnet income (loss) of $98 million.
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The net impact of this assumption update on Incomeincome (loss) from continuing operations, before income taxes of $124 million consisted of a decrease in Policypolicy charges and fee income of $21 million, an increase in Policyholders’policyholders’ benefits of $175 million, an increase in Interestinterest credited to policyholders’ account balances of $8 million, an increase in Netnet derivative gains of $106 million and an increase in the Amortizationamortization of DAC of $26 million. Third quarter
Our annual review in 2020 assumption updates include a pre-tax gain of $421 million attributable toresulted in the removal of the credit risk adjustment from our fair value scenario calibration to better align with US valuationreflect our revised view of market participant practices, offset by updates to our mortality and policyholder behavior assumptions to reflect emerging experience,experience.
First Quarter Update
In the first quarter of 2020, dueDue to the extraordinary economic conditions driven by the COVID-19 pandemic in the first quarter of 2020, we updated our interest rate assumption to grade from the current spot interest rate environmentcurve to an ultimate five-year historical average over a 10-year period. As such, the 10-year U.S. Treasury yield grades from the current level to an ultimate 5-year average of 2.25%. We determined that no assumption updates were necessary in the second quarter of 2020.
The low interest rate environment and subsequent update to the interest rate assumption caused a loss recognition event for our life interest-sensitive products, as well as to certain run-off business. This loss recognition event caused an acceleration of DAC amortization on our life interest-sensitive products and an increase in the premium deficiency reserve on the run-off business in the first quarter of 2020.
The impact of the economic assumption update in the first quarter of 2020 was a decrease of $2.1 billion to Incomeincome (loss) from continuing operations, before income taxes and a decrease to Netnet income (loss) of $1.7 billion.
The net impact of this assumption update on Incomeincome (loss) from continuing operations, before income taxes of $2.1 billion consisted of an increase in Policypolicy charges and fee income of $54 million, an increase in Policyholders’policyholders’ benefits of $1.3 billion, a decrease in Interestinterest credited to policyholders’ account balances of $6 million and an increase in the Amortizationamortization of DAC of $840 million.
2019 Assumption Updates2021 Model Changes
The impact of assumption updatesThere were no material model changes in the thirdfirst nine months of 2021.
2020 Model Changes
In the first quarter of 2019 was2020, we adopted a decreasenew economic scenario generator to calculate the fair value of $1.4 billion to Income (loss) from continuing operations, before income taxesthe GMIB reinsurance contract asset and GMxB derivative features liability, eliminating reliance on AXA for scenario production. The economic scenario generator allows for a decrease to Net income (loss)tighter calibration of $1.1 billion. This includes a $1.4 billion unfavorable impact on the reserves forU.S. indices, better reflecting our Variable annuity product features as a result of unfavorable updates to our: (i) interest rate assumptions; and (ii) policyholder behavior, primarily lapse and withdrawal assumptions, further magnified by low interest rates.
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actual portfolio. The net impact of these assumption updates on Incomethe economic scenario generator resulted in an increase in income (loss) from continuing operations, before income taxes of $1.4 billion consisted of a decrease in Policy charges$165 million, and fee income of $11 million, an increase in Policyholders’ benefitsto net income (loss) of $886$130 million for the nine months ended September 30, 2020. There were no other model changes that made a decrease in Interest creditedmaterial impact to policyholders’ account balancesour income (loss) from continuing operations, before income taxes or net income (loss).
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Table of $14 million, an increase in Net derivative losses of $548 million and a decrease in Amortization of DAC of $77 million.Contents
Impact of Assumption Update and COVID-19 Impacts on Income from Continuing Operations before income taxes and Net income (loss)
The unprecedented and rapid spread of COVID-19 and the related restrictions and social distancing measures implemented throughout the world have caused severe, lasting turmoil in the financial markets during the first nine months of 2020.
The table below presents the impact of COVID-19 pandemic related impacts on Incomeincome (loss) from continuing operations, before income taxes and on Netnet income (loss) which all occurred during the first sixnine months ofended September 30, 2020:
Nine Months Ended September 30, 2020
COVID-19 Impacts
Interest Rate Assumption UpdateImpacts other than Interest Rate Assumption
Update (1)
Total
(in millions)
Net income (loss) from continuing operations, before income taxes$(2,122)$(105)$(2,227)
Income tax (expense) benefit446 22 468 
Net income (loss) from continuing operations, net of taxes$(1,676)$(83)$(1,759)
_____________________________
(1)Includes amounts primarily due to non-variable annuity hedging impacts resulting from unprecedented volatility in equity markets and accelerated amortization of DAC due to loss recognition in the first half of 2020 resulting from first quarter 2020 interest rate assumption update.
2020 Model Changes
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In the first quarter

Table of 2020, we adopted a new economic scenario generator to calculate the fair value of the GMIB reinsurance contract asset and GMxB derivative features liability, eliminating reliance on AXA Group for scenario production. The new economic scenario generator allows for a tighter calibration of U.S. indices, better reflecting our actual portfolio. The net impact of the new economic scenario generator resulted in an increase in Income (loss) from continuing operations, before income taxes of $165 million, and an increase to Net Income (loss) of $130 million for the nine months ended September 30, 2020Contents
2019 Model Changes
There was no material impact from model changes during the first nine months of 2019 to our Income (loss) from continuing operations, before income taxes or Net income (loss).
Macroeconomic and Industry Trends
Our business and consolidated results of operations are significantly affected by economic conditions and consumer confidence, conditions in the global capital markets and the interest rate environment.
Financial and Economic Environment
In the faceA wide variety of the ongoing pandemic,factors continue to impact financial and economic conditions. These factors include, among others, significant volatility in financial markets, economic growth, inflation rates, supply chain disruptions, continued to experience significant volatilitylow interest rates and unemployment levels remained high during the third quarter. Although the financial market recovered most of the first quarter losseschanges in the months since, the prospect of continued volatility remains, especially given the uncertainty surrounding continued civil unrest across the U.S. centered around racial inequality, the presidential and congressional election and the continued economic effects of the virus. fiscal or monetary policy.
Stressed conditions, volatility and disruptions in the capital markets, particular markets, or financial asset classes can have an adverse effect on us, in part because we have a large investment portfolio and our insurance liabilities and derivatives are sensitive to changing market factors. An increase in market volatility could continue to affect our business, including through effects on the yields we earn on invested assets, changes in required reserves and capital and fluctuations in the value of our AV from which we derive our fee income. These effects could be exacerbated by uncertainty about future fiscal policy, changes in tax policy, the scope of potential deregulation and levels of global trade.
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The potential for increased volatility, coupled with prevailing interest rates continuing to fallfalling and/or remaining below historical averages, could pressure sales and reduce demand for our products as consumers consider purchasing alternative products to meet their objectives. In addition, this environment could make it difficult to consistently develop products that are attractive to customers. Financial performance can be adversely affected by market volatility and equity market declines as fees driven by AV fluctuate, hedging costs increase and revenues decline due to reduced sales and increased outflows.
We monitor the behavior of our customers and other factors, including mortality rates, morbidity rates, annuitization rates and lapse and surrender rates, which change in response to changes in capital market conditions, to ensure that our products and solutions remain attractive and profitable. For additional information on our sensitivity to interest rates and capital market prices, see “Quantitative and Qualitative Disclosures About Market Risk”.
Interest Rate Environment
We believe the interest rate environment will continue to impact our business and financial performance in the future for several reasons, including the following:
Certain of our variable annuity and life insurance products pay guaranteed minimum interest crediting rates. We are required to pay these guaranteed minimum rates even if earnings on our investment portfolio decline, with the resulting investment margin compression negatively impacting earnings. In addition, we expect more policyholders to hold policies with comparatively high guaranteed rates longer (lower lapse rates) in a low interest rate environment. Conversely, a rise in average yield on our investment portfolio should positively impact earnings. Similarly, we expect policyholders would be less likely to hold policies with existing guaranteed rates (higher lapse rates) as interest rates rise.
A prolonged low interest rate environment also may subject us to increased hedging costs or an increase in the amount of statutory reserves that our insurance subsidiaries are required to hold for GMxB features, lowering their statutory surplus, which would adversely affect their ability to pay dividends to us. In addition, it may also increase the perceived value of GMxB features to our policyholders, which in turn may lead to a higher rate of annuitization and higher persistency of those products over time. Finally, low interest rates may continue to cause an acceleration of DAC amortization or reserve increase due to loss recognition for interest-sensitive products.
For a discussion on derivatives we used to hedge interest rates, see Note 4 of the Notes to the Consolidated Financial Statements in this Form 10-Q.
Regulatory Developments
We are regulated primarily by the New York State Department of Financial Services (“NYDFS”),NYDFS, with some policies and products also subject to federal regulation. On an ongoing basis, regulators refine capital requirements and introduce new reserving standards. Regulations recently adopted or currently under review can potentially impact our statutory reserve, capital requirements and profitability of the industry and result in increased regulation and oversight for the industry.
COVID-19 Impact. In March 2020, in connection with the COVID-19 pandemic, many U.S. state insurance regulators began issuing bulletins, directives and guidance encouraging, requesting or directing licensed life insurance companies to implement life insurance policy measures such as: providing grace periods to policyholders for the payment of insurance premiums and forbearing For additional information on the cancellation or non-renewal of life insurance policies due to non-payment of premium. In addition, some states’ governors have issued emergency ordersregulatory developments and state insurance commissioners have promulgated emergency regulations requiring such actions. For example, the NYDFS promulgated emergency regulations requiring insurance company actions with respect to many lines of insurance. Among other requirements, these emergency measures temporarily required New York licensed life insurers to extend the grace period for the payment of premiumsrisk we face, see “Business—Regulation” and fees to 90 days for any life policyholder or group certificate holder facing financial hardship as a result of the COVID-19 pandemic. In addition, licensed life insurers were required to provide 90 days to exercise rights or benefits for a policyholder who was unable timely to exercise such rights as a result of the COVID-19 pandemic. New York licensed insurers were prohibited from imposing any late fees or reporting such policyholder to a credit reporting agency or debt collection agency“Risk Factors—Legal and Regulatory Risks” in the event of a policyholder’s failure to timely pay premium and were required to permit policyholders who did not make a premium payment due to financial hardship2020 Form 10-K, as a result of the COVID-19 pandemic to pay the premium over a 12-month period. These measures expired on July 6, 2020, however we cannot predict what future ordersamended or regulations, if any, will be implemented as a result of the ongoing COVID-19 pandemic.
Variable Annuity Capital Standards. In 2015, the NAIC Financial Condition (E) Committee established a working group to study and address, as appropriate, regulatory issues resulting from variable annuity captive reinsurance transactions, including reforms that would improve the current statutory reserve and RBC framework for insurance companies that sell variable
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annuity products.supplemented in our subsequently filed Quarterly Reports on Form 10-Q in “Management’s Discussion and Analysis of Financial Condition and Results of Operations—Macroeconomic and Industry Trends—Regulatory Developments.”
Regulation 213. In August 2018, the NAIC adopted the new framework developed and proposed by this working group. Following its referral to various NAIC committees to develop the full implementation details, the new framework became operational in January 2020. Among other changes, the new framework includes new prescriptions for reflecting hedge effectiveness, investment returns, interest rates, mortality and policyholder behavior in calculating statutory reserves and RBC. The new framework will materially change the level of variable annuity reserves and RBC requirements as well as their sensitivity to capital markets including interest rate, equity markets, volatility and credit spreads. Overall, we believe the NAIC reform has moved variable annuity capital standards towards an economic framework and is consistent with how we manage our business. Equitable Financial adopted the NAIC reserve and capital framework for the year ended December 31, 2019.
On February 26, 2020, the NYDFS adopted amendments toNew York, Regulation 213, that differadopted in May of 2019 and as subsequently amended, differs from the NAIC variable annuity reserve and capital framework. These amendmentsRegulation 213, as amended, will not materially affect Equitable Financial’sHoldings’ U.S. GAAP financial condition, results of operations or stockholders’ equity. However, Regulation 213, as amended, absent management action, will requirerequires Equitable Financial to carry statutory basis reserves for its variable annuity contract obligations equal to the greater of those required under (i) the NAIC standard or (ii) a revised version of the NYDFS requirement in effect prior to the adoption of the first amendment for contracts issued prior to January 1, 2020, and for policies issued after that date a new standard that we believe isin current market conditions imposes more conservative reserving requirements for variable annuity contracts than the NAIC standard. Absent management action, we believe that the amendmentsRegulation 213 will materially increase the statutory basis reserves that(i) negatively impact Equitable Financial will be required to carryFinancial’s surplus level and willRBC ratio and (ii) materially and adversely affect Equitable Financial’s dividend capacity from 2021 and moving forward. These impacts would be more adverse in periods of rising equity and/or interest rate markets, as was the capacitycase following the equity market appreciation in the second half of 2020 and the nine months of 2021. Such impacts were exacerbated upon closing of the Venerable transaction. Equitable Financial to distribute dividends to Holdings beyond 2020. Holdings is considering management actions to mitigatewas granted a permitted practice by the NYDFS which partially mitigates the Regulation 213 impact of Regulation 213. These actions could include seeking further amendment of Regulation 213 or exemptive relief therefromthe Venerable transaction to make the regulation’s application to Equitable Financial more consistent with the NAIC reserve and capital framework, as well asframework. Equitable Financial also entered into a reinsurance agreement with Swiss Re Life & Health America Inc. (“Swiss Re”) effective October 1, 2021, and we completed certain internal restructurings that increase cash flows to Holdings from non-life insurance entities, which further mitigate the impacts from Regulation 213. We are considering additional management actions intended to reduce the impact of the regulation which could include seeking further amendment of Regulation 213 or exemptive relief therefrom, changing Holdings’our underwriting practices to emphasize issuing variable annuity products out of affiliates which are not domiciled in New York, increasing the use of reinsurance and pursuing other corporate transactions intended to reduce the impact of the regulation.transactions. There can be no assurance that any management action individually or collectively will fully mitigate the impact of Regulation 213. Other state insurance regulators may also propose and adopt standards differentthat differ from the NAIC framework. See Note 10 of the Notes to the Consolidated Financial Statements for additional detail on the permitted practice granted by the NYDFS and Note 17 of the Notes to the Consolidated Financial Statements for additional detail on the reinsurance agreement with Swiss Re.
DOL Fiduciary Rule andRules / “Best Interest” PTEs. Standards of Conduct
In the wake of the March 2018 Fifth Circuit federal appeals court decision to vacate the DOL Fiduciary Rule, the DOL announced that it planned to issue revised fiduciary investment advice regulations. In JuneDecember 2020, the DOL proposedfinalized a “best interest” prohibited transaction exemption (“PTE”PTE 2020-02”) for investment advice fiduciaries under ERISA.ERISA, with an enforcement date of December 20, 2021. The proposalnew rule restores the five-part test for determining fiduciary status that was in effect prior to the 2016 DOL Fiduciary Rule, although the scope of the PTE now2020-02 extends to rollover transactions if they constitute “investment advice” under the five-part test. If fiduciary status is triggered, the PTE 2020-02 prescribes a set of impartial conduct standards and disclosure obligations that are intended to be consistent with the SEC’s Regulation Best Interest. We are currently assessingdevoting significant time and resources towards coming into compliance with PTE 2020-02 but do not expect the proposed PTEnew rules to determine thehave a material impact it may have on our business. However, in June 2021 the DOL updated its formal regulatory agenda to include issuance of a proposed rule making by year-end 2021 that would further amend its fiduciary regulations, including PTE 2020-02 and, possibly, other existing prohibited transaction exemptions.
In April 2021, the Appellate Division of the NYS Supreme Court, Third Department, overturned NY Department of Financial Services Regulation 187 — Suitability and Best Interests in Life Insurance and Annuity Transactions (“Regulation 187”) for being unconstitutionally vague. In June 2021, the NYDFS appealed this ruling to the New York State Court of Appeals, which automatically granted a stay, meaning that Regulation 187 remains in effect pending a decision by the Court of Appeals.
Other “Best Interest” Standards of ConductClimate Risks. FollowingIn September 2020, the decisionNYDFS announced that it expects insurers to vacateintegrate financial risks from climate change into their governance frameworks, risk management processes, and business strategies, and that it will integrate questions on this topic into their examinations in 2021. In March 2021, the DOL Fiduciary Rule in 2018, , the NAIC adopted, and state regulators either have adopted orNYDFS issued for public comment proposed guidance for New York domestic insurers, such as Equitable Financial, which states that insurers are currently considering whetherexpected to apply, an impartial conduct or fiduciary standardtake a proportionate approach to recommendations made in connection with certain annuities and, in one case,managing climate risks that reflects its exposure to life insurance policies.climate risks. For example, an insurer should integrate the NAIC has amendedevaluation of climate risks into its Suitabilitygovernance structure and use scenario analysis to guide risk assessment. We provided comments after reviewing the NYDFS’ proposed guidance designed to ensure that such guidance is consistent with our existing risk management framework. The NYDFS intends to formally adopt the guidance, as modified by the comment process, in Annuity Transactions Model Regulation to apply a best interestthe fourth quarter of 2021.
On July 14, 2021, the NYDFS published notice of the consumer standardadoption of amendments to insurance producers’ annuity recommendations andthe regulation governing enterprise risk management, effective August 13, 2021. The amendments require that insurers supervise such recommendations. To date, the amended regulation has been adoptedcertain additional risks, including climate change, be included in Iowaan insurance group’s enterprise risk management function, among other requirements.
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NYDFS Guidance on Diversity and Arizona.Corporate Governance. In July 2018,March 2021, the NYDFS issued a final versioncircular letter which states that the NYDFS expects the insurers that it regulates to make diversity of Regulation 187their leadership a business priority and a key element of their corporate governance. The NYDFS is collecting data from New York domestic and authorized foreign insurers that adopts a “best interest” standard for recommendationsmeet certain premium thresholds, including Equitable Financial, regarding the salediversity of life insurancecorporate boards and annuity productsmanagement, and it will include diversity-related questions in New York. Regulation 187 took effect on August 1, 2019 with respect to annuity sales and took effect on February 1, 2020 for life insurance sales.its examination process starting in 2022. We have developed our compliance framework for Regulation 187 with respect to annuity sales as well as our life insurance business. In addition, state regulators and legislatures in Nevada, New Jersey and Maryland have proposed measures that would make broker-dealers, sales agents, and investment advisers and their representatives subject to a fiduciary duty when providing products and services to customers, including pension plans and IRAs. Massachusetts has adopted such a regulation applying a fiduciary duty standard to broker-dealers and their agents, but it does not apply to insurance product sales, including variable annuities. Beyondare considering the New York regulation, the likelihood of enactment of any such state-based regulation is uncertain at this time, but if implemented, these regulations could have adverse effects on our business and consolidated results of operations.
Regulation Best Interest. In June 2019, the SEC released a set of rules that, among other things, enhance the existing standard of conduct for broker-dealers to require them to act in the best interest of their retail customers (“Regulation Best Interest”); clarify the nature of the fiduciary obligations owed by registered investment advisers to their clients; impose new disclosure requirements aimed at ensuring investors understand the nature of their relationship with their investment professionals; and restrict certain broker-dealers and their financial professionals from using the terms “adviser” or “advisor” unless they act in an investment advisory capacity. These rules became effective on June 30, 2020. Investment advisers to retail clients as well as broker-dealers serving retail customers are now required to deliver to retail clients and customers and file with
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the SEC the new Form CRS, which provides disclosures about its standard of conduct and conflicts of interest. Broker-dealers must also provide more detailed disclosures to retail clients in connection with securities transactions. The intent of these rules is to impose on broker-dealers an enhanced duty of care to their natural person customers similar to that which applies to investment advisers under existing law and to require both broker-dealers and investment advisers to provide enhanced disclosure regarding the nature of their services to retail clients and customers and associated conflicts of interest. We have developed systems and processes and put in place policies and procedures to ensure that we are in compliance with Regulation Best Interest. Meanwhile, the SEC’s examination staff and FINRA are focusing on examining compliance efforts by broker-dealers with Regulation Best Interest.
Derivatives Regulation. The amount of collateral we are required to pledge and the expenses we incur under our derivatives transactions are expected to increase as a result of the requirement to pledge initial margin for non-centrally cleared derivative transactions (“OTC” derivatives) entered into after the phase-in period, which is expected to become applicable to us in September 2021 as a result of adoption by the Office of the Comptroller of the Currency, the Federal Reserve Board, the FDIC, the Farm Credit Administration, and the Federal Housing Finance Agency and the Commodity Futures Trading Commission of final margin requirements for OTC derivatives, absent further delays. Also, the SEC has finalized and adopted the final set of rules related to security-based swaps, which triggers the compliance date for security-based swap entities registration and compliance with previously adopted rules regarding margin, capital, segregation, recordkeeping and reporting and business conduct for security-based swaps. The rules became effective on April 6, 2020. The compliance date for registration of (i) security-based swap dealers that incur a registration obligation as a result of meeting certain thresholds to be set by the SEC on August 6, 2021 will be November 1, 2021 and (ii) major security-based swap participants that incur a registration obligation as a result of security-based swap activities in their quarter ending September 30, 2021 will be December 1, 2021. We continue to monitor developments and are evaluating the potential effect these rules might have on our business.
Impact of the SECURE Act
On December 20, 2019, President Trump signed into law the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”). The SECURE Act contains a number of provisions that affect the administration and operation of defined contribution plans such as 401(k) and 403(b) plans and IRAs, including provisions that encourage additional retirement savings and lifetime income options, promote the adoption of retirement plans by small employers, provide lifetime income portability, and accelerate the distribution of retirement benefits of deceased retirees. Many provisions of the SECURE Act become effective for plan years beginning after December 31, 2019. At this time, we do not expect material impacts to our business from the SECURE Act.
Impact of the CARES Act
The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) was signed into law on March 27, 2020. Several tax provisions were includedNYDFS’ guidance as part of a broad economic relief package. These include the temporary allowanceour commitment to diversity and inclusion.
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Impact of the Tax Cut and Jobs Act
In December 2017, the Tax Cut and Jobs Act (“TCJA”) was signed into law. The TCJA reduced the federal corporate income tax rate to 21% and repealed the corporate AMT while keeping existing AMT credits. It also contained measures affecting the Company, including changes to the DRD, insurance reserves and tax DAC. As a result of the TCJA, our Net Income has improved.
In August 2018, the NAIC adopted changes to the RBC calculation, including the C-3 Phase II Total Asset Requirement for variable annuities, to reflect the 21% corporate income tax rate in RBC, which resulted in a reduction to our Combined RBC Ratio.
Overall, the TCJA had a net positive economic impact on us and we continue to monitor regulations related to this reform.
Consolidated Results of Operations
Our consolidated results of operations are significantly affected by conditions in the capital markets and the economy because we offer market sensitive products. These products have been a significant driver of our results of operations. Because the future claims exposure on these products is sensitive to movements in the equity markets and interest rates, we have in place various hedging and reinsurance programs that are designed to mitigate the economic risksrisk of movements in the equity markets and interest rates. The volatility in Netnet income attributable to Equitable Financial for the periods presented below results from the mismatch between: (i) the change in carrying value of the reserves for GMDB and certain GMIB features that do not fully
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and immediately reflect the impact of equity and interest market fluctuations; and (ii) the change in fair value of products with the GMIB feature that hashave a no-lapse guarantee,guarantee; and (iii) our hedging and reinsurance programs.
The following table summarizes our consolidated statements of income (loss) for the nine months ended September 30, 20202021 and 2019:2020:
Consolidated Statement of Income (Loss)
Nine Months Ended September 30,Nine Months Ended September 30,
2020201920212020
(in millions)(in millions)
REVENUESREVENUESREVENUES
Policy charges and fee incomePolicy charges and fee income$2,582 $2,619 Policy charges and fee income$2,581 $2,582 
PremiumsPremiums613 696 Premiums574 613 
Net derivative gains (losses)Net derivative gains (losses)2,097 (2,080)Net derivative gains (losses)(4,152)2,097 
Net investment income (loss)Net investment income (loss)2,334 2,527 Net investment income (loss)2,655 2,334 
Investment gains (losses), net:Investment gains (losses), net:Investment gains (losses), net:
Credit losses on AFS debt securities and loansCredit losses on AFS debt securities and loans(47)— Credit losses on AFS debt securities and loans4 (47)
Other investment gains (losses), netOther investment gains (losses), net262 181 Other investment gains (losses), net753 262 
Total investment gains (losses), netTotal investment gains (losses), net215 181 Total investment gains (losses), net757 215 
Investment management and service feesInvestment management and service fees744 761 Investment management and service fees791 744 
Other incomeOther income43 39 Other income65 43 
Total revenuesTotal revenues8,628 4,743 Total revenues3,271 8,628 
BENEFITS AND OTHER DEDUCTIONSBENEFITS AND OTHER DEDUCTIONSBENEFITS AND OTHER DEDUCTIONS
Policyholders’ benefitsPolicyholders’ benefits4,267 3,356 Policyholders’ benefits2,383 4,267 
Interest credited to policyholders’ account balancesInterest credited to policyholders’ account balances845 859 Interest credited to policyholders’ account balances841 845 
Compensation and benefitsCompensation and benefits210 237 Compensation and benefits246 210 
CommissionsCommissions462 462 Commissions494 462 
Interest expenseInterest expense Interest expense1 — 
Amortization of deferred policy acquisition costsAmortization of deferred policy acquisition costs1,290 345 Amortization of deferred policy acquisition costs342 1,290 
Other operating costs and expensesOther operating costs and expenses653 614 Other operating costs and expenses847 653 
Total benefits and other deductionsTotal benefits and other deductions7,727 5,877 Total benefits and other deductions5,154 7,727 
Income (loss) from continuing operations, before income taxesIncome (loss) from continuing operations, before income taxes901 (1,134)Income (loss) from continuing operations, before income taxes(1,883)901 
Income tax (expense) benefitIncome tax (expense) benefit(181)289 Income tax (expense) benefit500 (181)
Net income (loss)Net income (loss)720 (845)Net income (loss)(1,383)720 
Less: Net income (loss) attributable to the noncontrolling interestLess: Net income (loss) attributable to the noncontrolling interest(1)Less: Net income (loss) attributable to the noncontrolling interest1 (1)
Net income (loss) attributable to Equitable FinancialNet income (loss) attributable to Equitable Financial$721 $(848)Net income (loss) attributable to Equitable Financial$(1,384)$721 

The following discussion compares the results for the nine months ended September 30, 20202021 to the nine months ended September 30, 2019.2020.
Nine Months Ended September 30, 20202021 Compared to the Nine Months Ended September 30, 20192020
Net Income (Loss) Attributable to Equitable Financial
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Net income (loss) attributable to Equitable Financial increaseddecreased by $1.6$2.1 billion, to a net loss of $1.4 billion for the nine months ended September 30, 2021 from a net income of $721 million for the nine months ended September 30, 2020, from a net loss of $848 million for the nine months ended September 30, 2019, primarily driven by the following notable items:
Unfavorable items included:
Increase in Net derivative gains of $4.2decreased by $6.2 billion mainly reflecting the gains from the first quarter 2020due to a decrease in interest rates and a lower improvement in equity markets induring 2020 when compared to 2019.an increase in interest rates during 2021 and greater equity market appreciation in 2021 compared to 2020, as well as non-performance risk and credit spreads widening during 2020.
IncreaseOther operating costs and expenses increased by $194 million primarily driven by legal accruals related to the COI litigation.
Commissions increased by $32 million mainly due to higher asset balance.
These were partially offset by the following favorable items:
Policyholders’ benefits decreased by $1.9 billion mainly due to the non-recurrence of the interest rate assumption update in the first quarter of 2020 and equity markets appreciation in the nine months ended September 30, 2021. This was partially offset by an increase in death claims.
Amortization of DAC decreased by $948 million mainly due to the interest rate assumption update in the first quarter of 2020 as a result of the extraordinary economic conditions driven by COVID-19. As a result of the lower interest rate assumption, our life products experienced loss recognition resulting in an acceleration of DAC amortization in the first nine months of 2020.
Net investment gains of $34increased by $542 million primarily due to the rebalancing of our U.S. Treasury portfolio.
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Decrease in Interest credited to policyholders’ account balances of $14 million mainly driven by lower FHLB funding agreements costs due to lower interest rates partially offset by higher interest credited in SCS product due to new business growth.
Partially offsetting this increase were the following notable items:
Increase in Amortization of DAC of $945 million mainly due toGeneral Account associated with the impact of the assumption updates including the first quarter of 2020 assumption update related to COVID-19.Venerable transaction.
Increase in Policyholders’ benefits of $911 million mainly due to the higher unfavorable impact of assumption updates in 2020 including the first quarter assumption update due to COVID-19, the unfavorable impact of equity markets in our GMxB liabilities, the re-establishment of profits followed by loss (“PFBL”) reserve and an increase in term and employee benefits product reserves, partially offset by favorable net mortality.
Decrease in Net investment income of $193 million mainly drivenincreased by changes in the market value of trading securities supporting our variable annuity products and lower income from alternative investments partially offset by higher investment income from fixed maturities available-for-sale due to higher asset balances and the General Account investment portfolio optimization.
Decrease in Revenue from fees and related items (“fee-type revenue”), including Policy charges and fee income, Premiums, Investment Management service fees and Other income, of $133 million primarily due to lower average Separate Accounts AV in our variable annuity products reflecting outflows in our older fixed-rate GMxB block and lower premiums on traditional products (offset in Policyholders' benefits) as well as higher ceded premiums, partially offset by the favorable impact of assumption updates for our life products.
Increase in Compensation, benefits and other operating expenses of $12$321 million mainly driven by higher softwareprepayments, higher asset balances and consulting costshigher income from our alternative investment portfolio partially offset by productivity initiativesthe Venerable transaction.
Fee-type revenue increased by $29 million mainly due to higher base fees, performance fees and COVID 19 related expense saves.distribution revenues as a result of higher average AUM revenues and higher fees as a result of higher average Separate Accounts AV.
Income tax expense increaseddecreased by $470$681 million primarily driven by pre-tax income in 2020 compared to a pre-tax loss in 2019.the first nine months of 2021 compared to pre-tax income in the first nine months of 2020.
See “—Significant Factors Impacting Our Results—Assumption Updates and Model Changes” for more information regarding the COVID-19-related assumption update.
Summary of Critical Accounting Estimates
The preparation of financial statements in conformity with U.S. GAAP requires management to adopt accounting policies and make estimates and assumptions that affect amounts reported in our consolidated financial statements included elsewhere herein. For a discussion of our significant accounting policies, see Note 2 to the Company’s consolidated financial statements included in our 20192020 Form 10-K. The most critical estimates include those used in determining:
liabilities for future policy benefits;
accounting for reinsurance;
capitalization and amortization of DAC and policyholder bonus interest credits;
estimated fair values of investments in the absence of quoted market values and investment impairments;
estimated fair values of freestanding derivatives and the recognition and estimated fair value of embedded derivatives requiring bifurcation;
measurement of income taxes and the valuation of deferred tax assets; and
liabilities for litigation and regulatory matters.
In applying our accounting policies, we make subjective and complex judgments that frequently require estimates about matters that are inherently uncertain. Many of these policies, estimates and related judgments are common in the insurance and
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financial services industries while others are specific to our business and operations. Actual results could differ from these estimates.
Item 3.     Quantitative and Qualitative Disclosures About Market Risk
Not Applicable.There have been no material changes to the quantitative and qualitative disclosures about market risk described in the Annual Report on Form 10-K for the year ended December 31, 2020 in "Quantitative and Qualitative Disclosures About Market Risk".
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Item 4.     Controls and Procedures
Evaluation of Disclosure Controls and Procedures
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The management of the Company,Management, with the participation of the Company’s Chief Executive Officer (CEO) and Chief Financial Officer, (CFO), has evaluated the effectiveness of the design and operation of the Company’s disclosure controls and procedures, (asas defined in Rule 13a-15(e) underof the Securities Exchange Act of 1934, as amended)Act. Based on such evaluation, the Chief Executive Officer and Chief Financial Officer have concluded that, as of September 30, 2020. This evaluation is performed to determine if our disclosure controls and procedures are effective to provide reasonable assurance that information required to be disclosed by the Company in the reports that it files or submits under the Securities and Exchange Act of 1934, as amended, is accumulated and communicated to management, including the Company’s CEO and CFO, as appropriate, to allow timely decisions regarding required disclosure and are effective to provide reasonable assurance that such information is recorded, processed, summarized and reported within the time periods specified by the Securities and Exchange Commission’s rules and forms.
Due to the material weakness described below, the Company’s CEO and CFO have concluded that2021, the Company’s disclosure controls and procedures were not effective as of September 30, 2020.effective.
As previously reported, the Company identified a material weaknessNo change in the design and operation of the Company’s internal control over financial reporting.  A material weakness is a deficiency, or a combination of deficiencies,reporting, as defined in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of a company’s annual or interim financial statements will not be prevented or detected on a timely basis. The Company’s management, including the Company’s CEO and CFO, have concluded that we do not maintain effective controls to timely validate that actuarial models are properly configured to capture all relevant product features and provide reasonable assurance timely reviews of assumptions and data haveExchange Act Rule 13a-15(f), occurred and, as a result, errors were identified in future policyholders’ benefits and deferred policy acquisition costs balances.
This material weakness resulted in misstatements in the Company’s previously issued annual and interim financial statements and resulted in:
(i)     the revision of the interim financial statements for the nine, six, and three months ended September 30, June 30, and March 31, 2018 and 2017, respectively, and the annual financial statements for the year ended December 31, 2017;
(ii)    the revision for the three and six months ended March 31, 2018 and June 30, 2018, respectively, as well as the three, six and nine months ended March 31, 2017, June 30, 2017 and September 30, 2017, respectively and for the years ended December 31, 2017 and 2016;
(iii)     the revision of the interim financial statements for the three months ended March 31, 2018,during the nine months ended September 30, 2017, the six months ended June 30, 2017 and the annual financial statements for the years ended December 31, 2017 and 2016; and
(iv) the restatement of the annual financial statements for the year ended December 31, 2016, the revision to each of the quarterly interim periods for 2017 and 2016, and the revision of the annual financial statements for the year ended December 31, 2015.
These revisions and restatements were directly related to the material weakness described above and not indicative of any new material weaknesses. Until remediated, there is a reasonable possibility2021, that this material weakness could result in a material misstatement of the Company’s consolidated financial statements or disclosures that would not be prevented or detected.
Remediation Status of Material Weakness
For the material weakness related to Actuarial Models, Assumptions and Data, management has implemented and tested new or enhanced controls as described below but determined that further sustained operation is necessary.
Remediation Activities: Material Weakness Related to Actuarial Models, Assumptions and Data
We have designed, implemented and tested an enhanced model validation control framework, including a rotational schedule to periodically re-validate all U.S. GAAP models.
We have designed, implemented and tested enhanced controls and governance processes for new model implementations.
We have designed, implemented and tested enhanced controls for model changes.
We have designed, implemented and tested enhanced controls over the annual assumption setting process, including a comprehensive master assumption inventory and risk framework.
We have designed, implemented and tested new controls and are redesigning certain of these controls to validate the reliability of significant data flows feeding actuarial models and assumptions
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Third quarter 2020 controls have operated as designed. However, given that certain controls noted above have only operated effectively in one financial closing cycle during the year, and controls are still being redesigned, we have determined that further work and sustained operation is appropriate before concluding the controls are operationally effective.
Changes in Internal Control Over Financial Reporting
As described above, the Company continues to design certain controls in connection with its remediation plan. These remediation efforts related to the material weakness described above represent changes in our internal control over financial reporting for the quarter ended September 30, 2020 that have materially affected, or areis reasonably likely to materially affect, the Company’s internal control over financial reporting.

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78

Part II     OTHER INFORMATION
Item 1.     Legal Proceedings
For information regarding certain legal proceedings pending against us, see Note 13 of the Notes to the Consolidated Financial Statements (unaudited) in this Form 10-Q. SeeAlso see “Risk Factors—Legal and Regulatory Risks—Legal and regulatory” actions could have a material adverse effect on our reputation, business, results of operations or financial condition”regulatory actions” included in our Annual Report on Form 10-K for the year ended December 31, 2019.2020.

Item 1A. Risk Factors
You should carefully consider the risks described in the “Risk Factors” section included in our Annual Report on Form 10-K for the year ended December 31, 2019 and2020, as amended or supplemented in our subsequently filed Quarterly Reports on Form 10-Q for the quarters ended March 31, 2020 and June 30, 2020.10-Q. Risks to which we are subject also include, but are not limited to, the factors mentioned under Note“Note Regarding Forward-Looking Statements and InformationInformation” above and the risks of our businesses described elsewhere in this Quarterly Report on Form 10-Q.
Item 2.    Unregistered Sales of Equity Securities and Use of Proceeds
Not applicable.
Item 3.     Defaults Upon Senior Securities
Not applicable.
Item 4.    Mine Safety Disclosures
Not applicable.
Item 5.     Other Information
None.
Item 6.    Exhibits
INDEX TO EXHIBITS
NumberDescription
#By-laws of Equitable Financial Life Insurance Company, as amended September 23, 2020.
#Section 302 Certification made by the registrant’s Chief Executive Officer
#Section 302 Certification made by the registrant’s Chief Financial Officer
#Section 906 Certification made by the registrant’s Chief Executive Officer
#Section 906 Certification made by the registrant’s Chief Financial Officer
101.INSXBRL Instance Document - the instance document does not appear in the Interactive Data File because its XBRL tags are embedded within the Inline XBRL document.
101.SCHInline XBRL Taxonomy Extension Schema Document
101.CALInline XBRL Taxonomy Extension Calculation Linkbase Document
101.LABInline XBRL Taxonomy Extension Label Linkbase Document
101.PREInline XBRL Taxonomy Extension Presentation Linkbase Document
101.DEFInline XBRL Taxonomy Extension Definition Linkbase Document
104Cover Page Interactive Data File (formatted in Inline XBRL and contained in Exhibits 101).
______________
#    Filed herewith.
GLOSSARY
Selected Financial Terms
Account Value (“AV”)Generally equals the aggregate policy account value of our retirement and protection products. General Account AV refers to account balances in investment options that are backed by the General Account while Separate Accounts AV refers to Separate Accounts investment assets.
Alternative investmentsInvestments in real estate and real estate joint ventures and other limited partnerships.
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Assets under management (“AUM”)Investment assets that are managed by one of our subsidiaries and includes: (i) assets managed by AB, (ii) the assets in our GAIA portfolio and (iii) the Separate Account assets of our retirement and protection businesses. Total AUM reflects exclusions between segments to avoid double counting.
Combined RBC RatioCalculated as the overall aggregate RBC ratio for the Company’s insurance subsidiaries including capital held for its life insurance and variable annuity liabilities and non-variable annuity insurance liabilities.
Conditional tail expectation (“CTE”)
Calculated as the average amount of total assets required to satisfy obligations over the life of the contract or policy in the worst x% of scenarios. Represented as CTE (100 less x). Example: CTE95 represents the worst five percent of scenarios.
Deferred policy acquisition cost (“DAC”)Represents the incremental costs related directly to the successful acquisition of new and certain renewal insurance policies and annuity contracts and which have been deferred on the balance sheet as an asset.
Deferred sales inducements (“DSI”)Represent amounts that are credited to a policyholder’s account balance that are higher than the expected crediting rates on similar contracts without such an inducement and that are an incentive to purchase a contract and also meet the accounting criteria to be deferred as an asset that is amortized over the life of the contract.
Fee-Type RevenueRevenue from fees and related items, including policy charges and fee income, premiums, investment management and service fees, and other income.
Gross PremiumsFirst year premium and deposits and Renewal premium and deposits.
Invested assetsIncludes fixed maturity securities, equity securities, mortgage loans, policy loans, alternative investments and short-term investments.
Premium and depositsAmounts a policyholder agrees to pay for an insurance policy or annuity contract that may be paid in one or a series of payments as defined by the terms of the policy or contract.
ReinsuranceInsurance policies purchased by insurers to limit the total loss they would experience from an insurance claim.
Renewal premium and depositsPremiums and deposits after the first twelve months of the policy or contract.
Risk-based capital (“RBC”)Rules to determine insurance company statutory capital requirements. It is based on rules published by the National Association of Insurance Commissioners (“NAIC”).
Product Terms
AnnuitantThe person who receives annuity payments or the person whose life expectancy determines the amount of variable annuity payments upon annuitization of an annuity to be paid for life.
AnnuitizationThe process of converting an annuity investment into a series of periodic income payments, generally for life.
Benefit baseA notional amount (not actual cash value) used to calculate the owner’s guaranteed benefits within an annuity contract. The death benefit and living benefit within the same contract may not have the same benefit base.
Cash surrender valueThe amount an insurance company pays (minus any surrender charge) to the policyholder when the contract or policy is voluntarily terminated prematurely.
Dollar-for-dollar withdrawalA method of calculating the reduction of a variable annuity benefit base after a withdrawal in which the benefit is reduced by one dollar for every dollar withdrawn.
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Future policy benefitsFuture policy benefits for the annuities business are comprised mainly of liabilities for life-contingent income annuities, and liabilities for the variable annuity guaranteed minimum benefits accounted for as insurance.

Future policy benefits for the life business are comprised mainly of liabilities for traditional life and certain liabilities for universal and variable life insurance contracts (other than the Policyholders’ account balance).
General Account Investment PortfolioThe invested assets held in the General Account.
General AccountThe assets held in the general accounts of our insurance companies as well as assets held in our separate accounts on which we bear the investment risk.
GMxBA general reference to all forms of variable annuity guaranteed benefits, including guaranteed minimum living benefits, or GMLBs (such as GMIBs, GMWBs and GMABs), and guaranteed minimum death benefits, or GMDBs (inclusive of return of premium death benefit guarantees).
Guaranteed income benefit (“GIB”)An optional benefit which provides the policyholder with a guaranteed lifetime annuity based on predetermined annuity purchase rates applied to a GIB benefit base, with annuitization automatically triggered if and when the contract AV falls to zero.
Guaranteed minimum accumulation benefits (“GMAB”)An optional benefit (available for an additional cost) which entitles an annuitant to a minimum payment, typically in lump-sum, after a set period of time, typically referred to as the accumulation period. The minimum payment is based on the benefit base, which could be greater than the underlying AV.
Guaranteed minimum death
benefits (“GMDB”)
An optional benefit (available for an additional cost) that guarantees an annuitant’s beneficiaries are entitled to a minimum payment based on the benefit base, which could be greater than the underlying AV, upon the death of the annuitant.
Guaranteed minimum income benefits (“GMIB”)An optional benefit (available for an additional cost) where an annuitant is entitled to annuitize the policy and receive a minimum payment stream based on the benefit base, which could be greater than the underlying AV.
Guaranteed minimum living
benefits (“GMLB”)
A reference to all forms of guaranteed minimum living benefits, including GMIBs, GMWBs and GMABs (does not include GMDBs).
Guaranteed minimum withdrawal benefits (“GMWB”)An optional benefit (available for an additional cost) where an annuitant is entitled to withdraw a maximum amount of their benefit base each year, for which cumulative payments to the annuitant could be greater than the underlying AV.
Guaranteed withdrawal benefit for life (“GWBL”)An optional benefit (available for an additional cost) where an annuitant is entitled to withdraw a maximum amount of their benefit base each year, for the duration of the policyholder’s life, regardless of account performance.
Indexed Universal Life (“IUL”)A permanent life insurance offering built on a universal life insurance framework that uses an equity-linked approach for generating policy investment returns.
Living benefitsOptional benefits (available at an additional cost) that guarantee that the policyholder will get back at least his original investment when the money is withdrawn.
Mortality and expense risk fee (“M&E fee”)A fee charged by insurance companies to compensate for the risk they take by issuing life insurance and variable annuity contracts.
Net flowsNet change in customer account balances in a period including, but not limited to, gross premiums, surrenders, withdrawals and benefits. It excludes investment performance, interest credited to customer accounts and policy charges.
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Policyholder account balances
Annuities. Policyholder account balances are held for fixed deferred annuities, the fixed account portion of variable annuities and non-life contingent income annuities. Interest is credited to the policyholder’s account at interest rates we determine which are influenced by current market rates, subject to specified minimums.
Life Insurance Policies. Policyholder account balances are held for retained asset accounts, universal life policies and the fixed account of universal variable life insurance policies. Interest is credited to the policyholder’s account at interest rates we determine which are influenced by current market rates, subject to specified minimums.
Return of premium (“ROP”) death benefitThis death benefit pays the greater of the account value at the time of a claim following the owner’s death or the total contributions to the contract (subject to adjustment for withdrawals). The charge for this benefit is usually included in the M&E fee that is deducted daily from the net assets in each variable investment option. We also refer to this death benefit as the Return of Principal death benefit.
RiderAn optional feature or benefit that a policyholder can purchase at an additional cost.
Roll-up rateThe guaranteed percentage that the benefit base increases by each year.
Separate AccountRefers to the separate account investment assets of our insurance subsidiaries excluding the assets held in those separate accounts on which we bear the investment risk.
Surrender chargeA fee paid by a contract owner for the early withdrawal of an amount that exceeds a specific percentage or for cancellation of the contract within a specified amount of time after purchase.
Surrender rateRepresents annualized surrenders and withdrawals as a percentage of average AV.
Universal life (“UL”) productsLife insurance products that provide a death benefit in return for payment of specified annual policy charges that are generally related to specific costs, which may change over time. To the extent that the policyholder chooses to pay more than the charges required in any given year to keep the policy in-force, the excess premium will be placed into the AV of the policy and credited with a stated interest rate on a monthly basis.
Variable annuityA type of annuity that offers guaranteed periodic payments for a defined period of time or for life and gives purchasers the ability to invest in various markets though the underlying investment options, which may result in potentially higher, but variable, returns.
Variable Universal Life (“VUL”)Universal life products where the excess amount paid over policy charges can be directed by the policyholder into a variety of Separate Account investment options. In the Separate Account investment options, the policyholder bears the entire risk and returns of the investment results.

ACRONYMS
“AB” or “AllianceBernstein” means AB Holding and ABLP.
“AFS” means available-for-sale
“AOCI��� means accumulated other comprehensive income
“ASC” means Accounting Standards Codification
“ASU” means Accounting Standards Update
“AUM” means assets under management
“AV” means Account Value
“AXA” means AXA S.A., a société anonyme organized under the laws of France, and formerly our controlling stockholder.
“AXA Financial” means AXA Financial, Inc., a Delaware corporation and a former wholly-owned direct subsidiary of Holdings. On October 1, 2018, AXA Financial merged with and into Holdings, with Holdings assuming the obligations of AXA Financial.
“BPs” means basis points
“CDS” means credit default swaps
“CECL” means current expected credit losses
“COI” means cost of insurance
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“COLI” means corporate owned life insurance
“Holdings” means Equitable Holdings, Inc. with its consolidated subsidiaries
“CS Life” means Corporate Solutions Life Reinsurance Company, a Delaware corporation and a wholly-owned direct subsidiary of Holdings.
“CS Life RE” means CS Life RE Company, an Arizona corporation and a wholly-owned indirect subsidiary of Holdings.
“CSA” means credit support annex
“CTE” means conditional tail expectation
“DAC” means deferred policy acquisition costs
“DSC” means debt service coverage
“DSI” means deferred sales inducement
“EAFE” means European, Australasia, and Far East
“EFS” means Equitable Financial Services, LLC, a Delaware corporation and a wholly-owned direct subsidiary of Holdings.
“EIMG” means Equitable Investment Management Group, LLC, a Delaware limited liability company and a wholly-owned indirect subsidiary of Holdings.
“EIM” means Equitable Investment Management, LLC, a Delaware limited liability company and wholly-owned indirect subsidiary of Holdings.
“Equitable Distributors” means Equitable Distributors, LLC, a Delaware limited liability company, our wholesale broker/dealer for our retirement and protection businesses and a wholly-owned indirect subsidiary of Holdings.
“Equitable Financial” means Equitable Financial Life Insurance Company, a New York corporation, a life insurance company and a wholly-owned subsidiary of EFS.
“ETF” means exchange traded funds
“Exchange Act” means Securities Exchange Act of 1934, as amended
“FABN” means Funding Agreement Backed Notes Program
“FASB” means Financial Accounting Standards Board
“FHLB” means Federal Home Loan Bank
“Holdings” means Equitable Holdings, Inc.
“ISDA Master Agreement” means International Swaps and Derivatives Association Master Agreement
“IUL” means indexed universal life
“IUS” means Investments Under Surveillance
“LIBOR” means London Interbank Offered Rate
“LTV” means loan-to-value
“MD&A” means Management’s Discussion and Analysis of Financial Condition and Results of Operations
“MRBs” means market risk benefits
“MSO” means Market Stabilizer Option
“NAIC” means National Association of Insurance Commissioners
“NAR” means net amount at risk
“NAV” means net asset value
“NLG” means no-lapse guarantee
“NYDFS” means New York State Department of Financial Services
“OCI” means other comprehensive income
“OTC” means over-the-counter
“REIT” means real estate investment trusts
“SCS” means Structured Capital Strategies
“SEC” means U.S. Securities and Exchange Commission
“SIO” means structured investment option
“SPE” means special purpose entity
“TDRs” means troubled debt restructurings
“TIPS” means treasury inflation-protected securities
“U.S. GAAP” means accounting principles generally accepted in the United States of America
“UL” means universal life
“ULSG” means universal life products with secondary guarantee
“VIAC” means Venerable Insurance and Annuity Company
“VIE” means variable interest entity
“VOE” means voting interest entity

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SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, Equitable Financial Life Insurance Company has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
Date: November 5, 20204, 2021EQUITABLE FINANCIAL LIFE INSURANCE COMPANY
By:/s/ Anders MalmströmRobin M. Raju
Name:Anders MalmströmRobin M. Raju
Title:Senior Executive Director and Chief Financial Officer
(Principal Financial Officer)
Date: November 5, 20204, 2021/s/ William Eckert
Name:William Eckert
Title:Managing Director and Chief Accounting Officer
(Principal Accounting Officer)
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