AXA Equitable Holdings, Inc.
1290 Avenue of the Americas
New York, NY 10104
November 13, 2018
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-7010
Registration Statement on FormS-1
of AXA Equitable Holdings, Inc.
Ladies and Gentlemen:
Pursuant to the provisions of Rule 461 under the Securities Act of 1933, as amended, AXA Equitable Holdings, Inc., a Delaware corporation (the “Company”), hereby respectfully requests that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 5:15 P.M. on November 15, 2018, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Debevoise & Plimpton LLP, by calling Peter J. Loughran at212-909-6375 or Eric T. Juergens at212-909-6301.
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| Very truly yours, | ||
| AXA Equitable Holdings, Inc. | ||
| By: | /s/ Mark Pearson | |
| Name: Mark Pearson | ||
| Title: President and Chief Executive Officer | ||
[Signature Page to Acceleration Request]
