Separate Acct No 49 Of Axa Equitable Life Insurance
Filed: 29 Jun 12, 12:00am
| [AXA LOGO] | Shane Daly Counsel | |
| June 29, 2012 | (212) 314-3912 (212) 314-3953 |
VIA EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | AXA Equitable Life Insurance Company |
| Separate Accounts 49 and 68 of AXA Equitable Life Insurance Company |
Structured Capital StrategiesSM |
| Correspondence Filing relating to the Registration Statement on Form N-4 |
| File Nos. 333-165395 and 811-07659 (“Registration Statement”) |
Dear Ms. White:
On behalf of AXA Equitable Life Insurance Company, we are providing you with notice of additional non-material changes to the prospectus in connection with the above-referenced Registration Statement. These changes are intended to reflect the availability of the gold and oil indices to NQ contracts. The current disclosure states that the gold and oil indices are available in IRA contracts only. Attached to this correspondence filing are copies of the revised portions of the prospectus for the Staff’s review.
We intend to file these non-material changes in the next Post-Effective Amendment to the Registration Statement along with any remaining information and exhibits required in order for the Registration Statement become effective.
Please contact the undersigned at (212) 314-3912 or Christopher Palmer, Esq. of Goodwin Procter LLP at (202) 346-4253 if you have any questions or comments.
Very truly yours,
/s/ Shane E. Daly
Shane E. Daly
cc: Christopher E. Palmer, Esq.
AXA Equitable Life Insurance Company
1290 Avenue of the Americas, New York, NY 10104