| SHANE DALY Vice President and Associate General Counsel (212) 314-3912 Fax: (212) 314-3959 |
May 7, 2020
VIA EDGAR AND EMAIL
Suzanne Hayes
United States Securities and Exchange Commission
Office of Capital Markets Trends
Division of Corporate Finance
Washington, DC 20549-8629
| Re: | AXA Equitable Life Insurance Company (“AXA Equitable”) |
Acceleration Request
Registration Statement on Form S-3
FileNo. 333-236443
CIK 0000727920
Dear Ms. Hayes:
On April 21, 2020, AXA Equitable filed Pre-Effective Amendment No. 1 to the above-captioned registration statement (“Registration Statement”) under the Securities Act of 1933 (“Securities Act”) with respect to the Escrow Shield Plus contract issued by AXA Equitable.
Request for Acceleration of the Effectiveness of the Registration Statement
On behalf of the Registrant and the principal underwriter, AXA Distributors, LLC, we hereby withdraw the prior acceleration letter request dated April 29, 2020, and we hereby request acceleration of the effectiveness of the Registration Statement, pursuant to Rule 461 under the Securities Act, so that the Registration Statement will be declared effective at 5:00 p.m. on May 7, 2020, or as soon as practicable thereafter. In this connection, the Registrant and the principal underwriter, AXA Distributors, LLC, have authorized me to represent on their behalf that they are aware of their obligations under the Securities Act.
Please contact the undersigned at (212) 314-3912 if you have any questions regarding the Registration Statement or this request.
| Very truly yours, |
/s/ Shane Daly |
| Shane Daly |
| AXA Equitable Life Insurance Company |