TEXT-EXTRACT 2 filename2.txt December 13, 2018 Mark Pearson President and Chief Executive Officer AXA Equitable Holdings, Inc. 1290 Avenue of the Americas New York, New York 10104 Re: AXA Equitable Holdings, Inc. Registration Statement on Form S-4 Filed December 6, 2018 File No. 333-228689 Dear Mr. Pearson: 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 Irene Paik at 202-551-6553 with any questions. Sincerely, Division of Corporation Finance Office of Healthcare & Insurance cc: Peter J. Loughran, Esq.