AXA Equitable Holdings, Inc.
1290 Avenue of the Americas
New York, New York 10104
December 13, 2018
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-7010
Registration Statement on Form S-4
of AXA Equitable Holdings, Inc.
File No. 333-228689
Ladies and Gentlemen:
Pursuant to the provisions of Rule 461 under the Securities Act of 1933, as amended, AXA Equitable Holdings, Inc., a Delaware corporation (the “Company”), hereby respectfully requests that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 10:00 A.M. (EST) on December 17, 2018, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Debevoise & Plimpton LLP, by calling Peter J. Loughran at (212) 909-6375 or Eric T. Juergens at (212) 909-6301.
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Very truly yours, | ||||
AXA Equitable Holdings, Inc. | ||||
By: | /s/ Anders B. Malmström | |||
Name: | Anders B. Malmström | |||
Title: | Senior Executive Vice President | |||
and Chief Financial Officer |
[Signature Page to Acceleration Request]