TEXT-EXTRACT 2 filename2.txt March 24, 2020 Shane Daly Vice President and Associate General Counsel AXA Equitable Life Insurance Company 1290 Avenue of the Americas New York, NY 10104 Re: AXA Equitable Life Insurance Company Registration Statement on Form S-3 Filed February 14, 2020 File No. 333-236443 Dear Mr. Daly: 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 David Lin, Staff Attorney, at (202) 551-3552 with any questions. Sincerely, Division of Corporation Finance Office of Finance