March 19, 2020

John C. Weisenseel
Chief Financial Officer
AllianceBernstein L.P.
1345 Avenue of the Americas
New York, NY 10105

       Re: AllianceBernstein L.P.
           Form 10-K for the Fiscal Year Ended December, 31, 2019
           Filed February 12, 2020
           File No. 000-29961

Dear Mr. Weisenseel:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K filed February 12, 2020

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Management Operating Metrics, page 43

1.    We note your disclosure on page 44 showing an adjustment for
distribution-related
      payments to calculate Adjusted Net Revenues and Adjusted Operating
Margin. In future
      filings, please revise to adjust by distribution revenues, rather than
expenses, and provide
      supplemental information (e.g., footnote(s) to your reconciliation) to
clearly explain each
      adjustment. To the extent that these distribution revenues are recognized
in multiple
      revenue line items on the face of the income statement, disaggregate and
distinguish the
      adjustment into those multiple components in the related non-GAAP
reconciliation. In
      addition and if applicable, in periods when a material amount of fee
waivers or other
      material non-standard items impact distribution revenues, provide
disclosure quantifying
      the impact that it has or could have upon Adjusted Operating Margin, or
any equivalent.
       In closing, we remind you that the company and its management are
responsible for the
 John C. Weisenseel
AllianceBernstein L.P.
March 19, 2020
Page 2

accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

      You may contact Lory Empie, Staff Accountant at 202-551-3714 or Robert
Klein, Staff
Accountant at 202-551-3847 with any questions.



FirstName LastNameJohn C. Weisenseel                      Sincerely,
Comapany NameAllianceBernstein L.P.
                                                          Division of
Corporation Finance
March 19, 2020 Page 2                                     Office of Finance
FirstName LastName