Underwriter Acceleration Request

EXECUTION VERSION

J.P. Morgan Securities LLC

383 Madison Avenue

New York, New York 10179

Morgan Stanley & Co. LLC

1585 Broadway

New York, New York 10036

Citigroup Global Markets Inc.

388 Greenwich St.

New York, New York 10013

November 13, 2018

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re:

AXA Equitable Holdings, Inc. (the “Company”)

Registration Statement on Form S-1

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness at 5:15 pm New York City time on November 15, 2018, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus. The undersigned advise that the underwriters have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Pages Follow]


Name:		Alaoui Zenere
Title:		Vice President


Name:		Michael Occi
Title:		Executive Director


Name:		Aaron Lissner
Title:		Director


Very truly yours,

J.P. MORGAN SECURITIES LLC



By:		/s/ Alaoui Zenere


MORGAN STANLEY & CO. LLC



By:		/s/ Michael Occi