September 21, 2011 BY EDGAR Mr. Jim B. Rosenberg Senior Assistant Chief Accountant Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549 United States RE: AXA Financial, Inc. Form 10-K for the Fiscal Year Ended December 31, 2010 Filed on March 10, 2011 File No. 001-11166 Dear Mr. Rosenberg, We received your comment letter dated September 12, 2011 concerning AXA Financial, Inc.'s Form 10-K for the year ended December 31, 2010 filed on March 10, 2011. As discussed, we submit this letter as confirmation that we intend to provide you with a response to the comment letter on or before October 7, 2011. Please do not hesitate to contact me directly at (212) 314-3863 or by email at dave.hattem@axa-equitable.com if you have any questions or if I can be of any further assistance. Sincerely yours, /s/ Dave S. Hattem ------------------------ Dave S. Hattem Senior Vice President and General Counsel cc: Richard S. Dziadzio Alvin H. Fenichel Ralph A. Petruzzo Allen J. Zabusky