| | |
[AXA EQUITABLE LOGO] | | |
| | DARIN SMITH |
| | Lead Director and Associate General Counsel |
| | (319) 573-2676 |
| | Fax (212) 314-3959 |
October 27, 2016
| | |
| VIA EDGAR |
|
| Securities and Exchange Commission |
| 100 F Street, N.E. |
| Washington, D.C. 20549 |
| Re: | AXA Equitable Life Insurance Company |
| | Form S-3 Registration Statement |
Commissioners:
On behalf of AXA Equitable Life Insurance Company (“AXA Equitable”), we are filing herewith, electronically via EDGAR, Post-Effective Amendment No. 1 (“Amendment”) to AXA Equitable’s Form S-3 Registration Statement (“Registration Statement”) under the Securities Act of 1933, as amended (“1933 Act”), with respect to interests in the Structured Investment Option® (“SIO”) under the Structured Capital Strategies® 16 contracts to be offered by AXA Equitable.
Purpose of the Filing
The purpose of this filing is to add a new index and two new segment types. We intend to file an additional amendment that will incorporate any Staff comments and a request for acceleration for effectiveness on December 5, 2016 or as soon thereafter as possible.
Request for Selective Review
We respectfully request selective review of the Amendment pursuant to Securities Act Release No. 6510 (Feb. 15, 1984).
In support of this request, we note that the Amendment contained in the Registration Statement is substantially similar to the prospectus contained in the currently effective registration statement (File No. 333-207256) which was reviewed by the Staff in December 2015, except that the Amendment adds a new index and two new segments types.
Please contact the undersigned at (319) 573-2676 if you have any questions.
Very truly yours,
/s/ Darin D. Smith
Darin D. Smith
AXA EQUITABLE LIFE INSURANCE COMPANY
1290 AVENUE OF THE AMERICAS, NEW YORK, NEW YORK 10104
