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                              December 1, 2023

       Bill Siemers
       Interim Chief Financial Officer
       AllianceBernstein Holding L.P.
       501 Commerce Street
       Nashville, TN 37203

                                                        Re: AllianceBernstein
Holding L.P.
                                                            Form 10-K For the
Fiscal Year Ended December 31, 2022
                                                            Filed February 10,
2023
                                                            File No. 001-09818

       Dear Bill Siemers:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment(s).

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operation
       Relationship with EQH and its Subsidiaries, page 34

   1.                                                   We note your disclosure
regarding Equitable Financials' agreement to provide $10 billion
                                                        in permanent capital to
build out illiquid offerings, and related note 2 explaining what the
                                                        term permanent capital
means. Please revise your disclosures, in future filings, to describe
                                                        the conditions under
which this permanent capital may be withdrawn. Also, to the extent it
                                                        is material, include
risk factor disclosures regarding the potential withdrawal or any
                                                        related impacts due to
this permanent capital.
       Capital Resources and Liquidity, page 36

   2.                                                   We note your discussion
of liquidity and capital resources primarily discusses the
                                                        Company's cash flows
from operating, investing and financing activities. Please revise
                                                        your disclosures, in
future filings, to provide a more comprehensive discussion of
                                                        your major sources of
liquidity and capital resources in addition to your cash flow
 Bill Siemers
AllianceBernstein Holding L.P.
December 1, 2023
Page 2
         activities. Where applicable, quantify any relevant parameters, terms
or conditions for
         available borrowing capacity and the extent to which accessing any
funding sources
         correlates to your investment strategies, such as whether it would
require realizing
         material gains or losses and other potential consequences.
       In closing, 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 Lory Empie at 202-551-3714 or Robert Klein at
202-551-3847 with any
questions.



FirstName LastNameBill Siemers                                Sincerely,
Comapany NameAllianceBernstein Holding L.P.
                                                              Division of
Corporation Finance
December 1, 2023 Page 2                                       Office of Finance
FirstName LastName