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                               July 12, 2023

       Robin M. Raju
       Chief Financial Officer
       Equitable Financial Life Insurance Company
       1290 Avenue of the Americas
       New York, New York 10104

                                                        Re: Equitable Financial
Life Insurance Company
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Filed February 21,
2023
                                                            File No. 000-20501

       Dear Robin M. Raju:

              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 for the Fiscal Year Ended December 31, 2022

       Notes to Consolidated Financial Statements
       3) Investments, page 85

   1.                                                   We note your disclosure
on page 90 stating that the Company did not intend to sell the
                                                        securities nor will
likely be required to dispose of the securities with unrealized losses in
                                                        your available for sale
portfolio before the anticipated recovery of their remaining
                                                        amortized cost basis.
However, we also note your disclosure on page 133 stating that due
                                                        to the potential need
for liquidity in a macro stress environment, the Company does not
                                                        currently have the
intent to hold the underlying securities to recovery as part of your
                                                        accounting for the
deferred tax assets and related valuation allowance associated with
                                                        these securities.
Please clarify and reconcile how these disclosures are consistent with
                                                        each other, and explain
your related accounting conclusions for each. Cite the specific
                                                        authoritative
literature considered for your accounting conclusions.
 Robin M. Raju
Equitable Financial Life Insurance Company
July 12, 2023
Page 2

       In closing, 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.

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



FirstName LastNameRobin M. Raju                      Sincerely,
Comapany NameEquitable Financial Life Insurance Company
                                                     Division of Corporation
Finance
July 12, 2023 Page 2                                 Office of Finance
FirstName LastName