1290 Avenue of the Americas New York, NY 10104 | Darin Smith Lead Director and Associate General Counsel (319) 573-2676
LAW DEPARTMENT |
November 19, 2018
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: | AXA Equitable Life Insurance Company |
Post-Effective Amendment No. 2 to FormS-3
File Number:333-223714
Dear Ms. Bentzinger:
Per your request, AXA Equitable Life Insurance Company hereby acknowledges that the Staff of the Securities and Exchange Commission did not make a determination with respect to the Company’s right to discontinue the Performance Cap Threshold service notwithstanding the acceleration of the above-referenced filing.
Very truly yours,
|
| Darin Smith |
