EXECUTION VERSION
J.P. Morgan Securities LLC
383 Madison Avenue
New York, New York 10179
Morgan Stanley & Co. LLC
1585 Broadway
New York, New York 10036
Citigroup Global Markets Inc.
388 Greenwich St.
New York, New York 10013
November 13, 2018
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Re: | AXA Equitable Holdings, Inc. (the “Company”) |
Registration Statement on FormS-1 |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness at 5:15 pm New York City time on November 15, 2018, or as soon thereafter as practicable.
Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus. The undersigned advise that the underwriters have complied and will continue to comply with Rule15c2-8 under the Securities Exchange Act of 1934, as amended.
[Signature Pages Follow]
| Very truly yours, | ||
| J.P. MORGAN SECURITIES LLC | ||
| By: | /s/ Alaoui Zenere | |
| Name: | Alaoui Zenere | |
| Title: | Vice President |
[EQH—Signature Page to Underwriter Acceleration Request]
| MORGAN STANLEY & CO. LLC | ||
| By: | /s/ Michael Occi | |
| Name: | Michael Occi | |
| Title: | Executive Director |
[EQH—Signature Page to Underwriter Acceleration Request]
| CITIGROUP GLOBAL MARKETS INC. | ||
| By: | /s/ Aaron Lissner | |
| Name: | Aaron Lissner | |
| Title: | Director |
[EQH—Signature Page to Underwriter Acceleration Request]
