March 24, 2020

Shane Daly
Vice President and Associate General Counsel
AXA Equitable Life Insurance Company
1290 Avenue of the Americas
New York, NY 10104

       Re: AXA Equitable Life Insurance Company
           Registration Statement on Form S-3
           Filed February 14, 2020
           File No. 333-236443

Dear Mr. Daly:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

       Please contact David Lin, Staff Attorney, at (202) 551-3552 with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Finance