Equitable America
Darin Smith
Vice President and
Associate General Counsel
(319) 573-2676
darin.smith@equitable.com
November 21, 2022
VIA EDGAR
Elisabeth Bentzinger, Esq.
United States Securities and Exchange
Commission Office of Insurance Products
Division of Investment Management
Mail Stop 8629
Washington, DC 20549-8629
| Re: | Variable Account AA |
Equitable Financial Life Insurance Company of America
Initial Registration Statement on Form N-4
File No. 333-266576
Dear Ms. Bentzinger:
The purpose of this letter is to provide a response to the supplemental comments you provided with respect to the above-referenced filing for Equitable Financial Life Insurance Company of America (the “Company”).
The Company has made the revisions to the EQUI-VEST® Strategies (Series 202) Prospectus as requested. Please see the revised Statutory Prospectus filed herewith.
We would like to have EQUI-VEST® Strategies (Series 202) effective on or before December 16, 2022. We will file a Pre-Effective Amendment that will address any Staff comments to the prospectus. Also, we will provide any additional exhibits (including contract forms) that might be necessary.
I trust that the responses provided in this letter address your comments adequately. If you have any questions regarding these responses, please contact the undersigned at (319) 573-2676. Thank you very much for your assistance with this filing.
Best regards,
/s/ Darin Smith |
| Darin Smith |
