UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

———————————————

FORM 10-Q

☒ QUARTERLY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the quarterly period ended March 31, 2023

or

☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from              to

Commission File No. 333-65423

————————————————

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

(Exact name of registrant as specified in its charter)

Arizona	86-0222062
(State or other jurisdiction of incorporation or organization)	(I.R.S. Employer Identification No.)
525 Washington Boulevard, Jersey City, New Jersey	07310
(Address of principal executive offices)	(Zip Code)

(212) 554-1234

(Registrant’s telephone number, including area code)

Securities registered pursuant to Section 12(b) of the Act: None

Securities registered pursuant to Section 12(g) of the Act: None

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.    Yes ☒    No ☐

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).    Yes  ☒    No  ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company or an “emerging growth company”. See definition of “accelerated filer,” “large accelerated filer,” “smaller reporting company” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

Large accelerated filer	☐	Accelerated filer	☐	Non-accelerated filer	☒	Smaller reporting company	☐	Emerging growth company	☐
If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13 (a) of the Exchange Act. o

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes ☐ No ☒

As of May 10, 2023, 2,500,000 shares of the registrant’s $1.00 par value Common Stock were outstanding, all of which were owned indirectly by Equitable Holdings, Inc.

REDUCED DISCLOSURE FORMAT

Equitable Financial Life Insurance Company of America meets the conditions set forth in General Instruction (H)(1)(a) and (b) of Form 10-Q and is therefore filing this Form with the reduced disclosure format.

TABLE OF CONTENTS

		Page
PART I - FINANCIAL INFORMATION
Item 1.	Financial Statements (Unaudited)	3
	Balance Sheets, March 31, 2023 and December 31, 2022	4
	Statements of Income (Loss), Three Months Ended March 31, 2023 and 2022	5
	Statements of Comprehensive Income (Loss), Three Months Ended March 31, 2023 and 2022	6
	Statements of Equity, Three Months Ended March 31, 2023 and 2022	7
	Statements of Cash Flows, Three Months Ended March 31, 2023 and 2022	8
	Notes to Financial Statements:
	Note 1 - Organization	9
	Note 2 - Significant Accounting Policies	9
	Note 3 - Investments	14
	Note 4 - Derivatives	19
	Note 5 - DAC and Other Deferred Assets/Liabilities	22
	Note 6 - Fair Value Disclosures	23
	Note 7 - Liabilities for Future Policyholder Benefits	32
	Note 8 - Market Risk Benefits	34
	Note 9 - Policyholder Account Balances	35
	Note 10 - Income Taxes	39
	Note 11 - Related Party Transactions	39
	Note 12 - Equity	39
	Note 13 - Commitments and Contingent Liabilities	40
	Note 14 - Unpaid Claim and Claim Expenses	41
	Note 15 - Revision of Prior Period Financial Statements	41
	Note 16 - Subsequent Events	43
Item 2.	Management’s Discussion and Analysis of Financial Condition and Results of Operations	44
Item 3.	Quantitative and Qualitative Disclosures About Market Risk	51
Item 4.	Controls and Procedures	51
PART II - OTHER INFORMATION
Item 1.	Legal Proceedings	52
Item 1A.	Risk Factors	52
Item 2.	Unregistered Sales of Equity Securities and Use of Proceeds	52
Item 3.	Defaults Upon Senior Securities	52
Item 4.	Mine Safety Disclosures	52
Item 5.	Other Information	52
Item 6.	Exhibits	52
Signatures		59

1

NOTE REGARDING FORWARD-LOOKING STATEMENTS AND INFORMATION

Certain of the statements included or incorporated by reference in this Quarterly Report on Form 10-Q constitute forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Words such as “expects,” “believes,” “anticipates,” “intends,” “seeks,” “aims,” “plans,” “assumes,” “estimates,” “projects,” “should,” “would,” “could,” “may,” “will,” “shall” or variations of such words are generally part of forward-looking statements. Forward-looking statements are made based on management’s current expectations and beliefs concerning future developments and their potential effects upon Equitable Financial Life Insurance Company of America (“Equitable America”). “We,” “us” and “our” refer to Equitable America, unless the context refers only to Equitable America as a corporate entity. There can be no assurance that future developments affecting Equitable Financial will be those anticipated by management. Forward-looking statements include, without limitation, all matters that are not historical facts.

These forward-looking statements are not a guarantee of future performance and involve risks and uncertainties, and there are certain important factors that could cause actual results to differ, possibly materially, from expectations or estimates reflected in such forward-looking statements, including, among others: (i) conditions in the financial markets and economy, including the impact of plateauing or decreasing economic growth and geopolitical conflicts and related economic conditions, equity market declines and volatility, interest rate fluctuations, impacts on our goodwill and changes in liquidity and access to and cost of capital; (ii) operational factors, indebtedness, protection of confidential customer information or proprietary business information, operational failures by us or our service providers, potential strategic transactions, and changes in accounting standards, and catastrophic events, such as the outbreak of pandemic diseases including COVID-19; (iii) credit, counterparties and investments, including counterparty default on derivative contracts, failure of financial institutions, defaults by third parties and affiliates and economic downturns, defaults and other events adversely affecting our investments; (iv) our reinsurance and hedging programs; (v) our products, structure and product distribution, including variable annuity guaranteed benefits features within certain of our products, variations in statutory capital requirements, financial strength and claims-paying ratings and key product distribution relationships; (vi) estimates, assumptions and valuations, including risk management policies and procedures, potential inadequacy of reserves and experience differing from pricing expectations or reserves, amortization of deferred acquisition costs and financial models; (vii) recruitment and retention of key employees at Equitable Financial and experienced and productive financial professionals; (viii) subjectivity of the determination of the amount of allowances and impairments taken on our investments; (ix) legal and regulatory risks, including federal and state legislation affecting financial institutions, insurance regulation and tax reform; and (x) general risks, including strong industry competition, information systems failing or being compromised and protecting our intellectual property.

Forward-looking statements should be read in conjunction with the other cautionary statements, risks, uncertainties and other factors identified in Equitable America’s Annual Report on Form 10-K for the year ended December 31, 2022, as amended or supplemented in our subsequently filed Quarterly Reports on Form 10-Q, including in the section entitled “Risk Factors,” and elsewhere in this Quarterly Report on Form 10-Q. You should read this Form 10-Q completely and with the understanding that actual future results may be materially different from expectations. Further, any forward-looking statement speaks only as of the date on which it is made, and we undertake no obligation to update or revise any forward-looking statement to reflect events or circumstances after the date on which the statement is made or to reflect the occurrence of unanticipated events, except as otherwise may be required by law.

Other risks, uncertainties and factors, including those discussed under “Risk Factors”, in our Annual Report on Form 10-K could cause our actual results to differ materially from those projected in any forward-looking statements we make. Readers should read carefully the factors described in “Risk Factors” in our Annual Report on Form 10-K to better understand the risks and uncertainties inherent in our business and underlying any forward-looking statements.

Throughout this Quarterly Report on Form 10-Q we use certain defined terms and abbreviations, which are summarized in the “Glossary” and “Acronyms” sections.

2

Part I FINANCIAL INFORMATION

Item 1. Financial Statements (Unaudited)

3

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Balance Sheets

March 31, 2023 and December 31, 2022 (Unaudited)

	March 31, 2023		December 31, 2022
	(in millions, except share data)
ASSETS
Investments:
Fixed maturities available-for-sale, at fair value (amortized cost of $3,537 and $2,606) (allowance for credit losses of $0 and $0 )	$	3,225	$	2,218
Mortgage loans on real estate (net of allowance for credit losses of $0 and $0)	17		17
Policy loans	250		244
Other equity investments	18		19
Other invested assets	82		47
Total investments	3,592		2,545
Cash and cash equivalents	535		294
Deferred policy acquisition costs	824		760
Amounts due from reinsurers (allowance for credit losses of $0 and $0)	1,040		1,051
Current and deferred income taxes	147		76
Purchased market risk benefits	11		13
Other assets	131		101
Assets for market risk benefits	17		12
Separate Accounts assets	3,867		3,374
Total Assets	$	10,164	$	8,226
LIABILITIES
Policyholders’ account balances	$	4,910	$	3,751
Liability for market risk benefits	14		15
Future policy benefits and other policyholders' liabilities	707		669
Amounts due to reinsurers	109		112
Other liabilities	182		73
Separate Accounts liabilities	3,867		3,374
Total Liabilities	$	9,789	$	7,994
Commitments and contingent liabilities (1)
EQUITY
Common stock, $1.00 par value; 2,500,000 shares authorized, issued and outstanding	$	3	$	3
Additional paid-in capital	831		831
Accumulated deficit	(157)		(220)
Accumulated other comprehensive income (loss)	(302)		(382)
Total Equity	375		232
Total Liabilities and Equity	$	10,164	$	8,226

_____________

(1)See Note 13 of the Notes to these Financial Statements for details of commitments and contingent liabilities.

Prior period amounts have been adjusted for the implementation of ASU 2018-12: Targeted Improvements to the Accounting for Long-Duration Contracts.

See Notes to Financial Statements (Unaudited).

4

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Statements of Income (Loss)

Three Months Ended March 31, 2023 and 2022 (Unaudited)

	Three Months Ended March 31,
	2023		2022
	(in millions)
REVENUES
Policy charges and fee income	$	61	$	56
Premiums	69		49
Net derivative gains (losses)	6		(8)
Net investment income (loss)	29		20
Investment gains (losses), net	(5)		(1)
Investment management and service fees	5		5
Other income	6		—
Total revenues	171		121
BENEFITS AND OTHER DEDUCTIONS
Policyholders’ benefits	79		74
Remeasurement of liability for future policy benefits	(1)		(1)
Change in market risk benefits and purchased market risk benefits	—		(5)
Interest credited to policyholders’ account balances	23		19
Compensation and benefits	13		11
Commissions	31		16
Amortization of deferred policy acquisition costs	12		10
Other operating costs and expenses	23		23
Total benefits and other deductions	180		147
Income (loss) from continuing operations, before income taxes	(9)		(26)
Income tax (expense) benefit	72		6
Net income (loss)	$	63	$	(20)

Prior period amounts have been adjusted for the implementation of ASU 2018-12: Targeted Improvements to the Accounting for Long-Duration Contracts.

See Notes to Financial Statements (Unaudited).

5

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Statements of Comprehensive Income (Loss)

Three Months Ended March 31, 2023 and 2022 (Unaudited)

	Three Months Ended March 31,
	2023		2022
	(in millions)
COMPREHENSIVE INCOME (LOSS)
Net income (loss)	$	63	$	(20)
Other comprehensive income (loss), net of income taxes:
Change in unrealized gains (losses), net of adjustments (1)	75		(171)
Changes in market risk benefits - instrument-specific credit risk	5		5
Other comprehensive income (loss), net of income taxes	80		(166)
Comprehensive income (loss)	$	143	$	(186)

_____________

(1)See Note 12 of the Notes to these Financial Statements for details of change in unrealized gains (losses), net of adjustments.

Prior period amounts have been adjusted for the implementation of ASU 2018-12: Targeted Improvements to the Accounting for Long-Duration Contracts.

See Notes to Financial Statements (Unaudited).

6

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Statements of Equity

Three Months Ended March 31, 2023 and 2022 (Unaudited)

	Three Months Ended March 31,
	Equity
	Common Stock		Additional Paid-in Capital		Accumulated Deficit		Accumulated Other Comprehensive Income (Loss)		Equity
	(in millions)
January 1, 2023	$	3	$	831	$	(220)	$	(382)	$	232
Net income (loss)	—		—		63		—		63
Other comprehensive income (loss)	—		—		—		80		80
Other	—		—		—		—		—
March 31, 2023	$	3	$	831	$	(157)	$	(302)	$	375
January 1, 2022	$	3	$	680	$	(134)	$	98	$	647
Net income (loss)	—		—		(20)		—		(20)
Other comprehensive income (loss)	—		—		—		(166)		(166)
Other	—		1		—		—		1
March 31, 2022	$	3	$	681	$	(154)	$	(68)	$	462

Prior period amounts have been adjusted for the implementation of ASU 2018-12: Targeted Improvements to the Accounting for Long-Duration Contracts.

See Notes to Financial Statements (Unaudited).

7

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Statements of Cash Flows

Three Months Ended March 31, 2023 and 2022 (Unaudited)

	Three Months Ended March 31,
	2023		2022
	(in millions)
Cash flows from operating activities:
Net income (loss)	$	63	$	(20)
Adjustments to reconcile net income (loss) to net cash provided by (used in) operating activities:
Interest credited to policyholders’ account balances	23		19
Policy charges and fee income	(61)		(56)
Net derivative (gains) losses	(6)		8
Investment (gains) losses, net	5		1
Realized and unrealized (gains) losses on trading securities	2		—
Non-cash long-term incentive compensation expense	1		1
Amortization and depreciation	13		10
Remeasurement of liability for future policy benefits	(1)		(1)
Change in Market Risk Benefits	—		(5)
Changes in:
Reinsurance recoverable	(9)		1
Capitalization of deferred policy acquisition costs	(76)		(26)
Future policy benefits	9		9
Current and deferred income taxes (1)	(72)		(7)
Other, net	89		74
Net cash provided by (used in) operating activities	$	(20)	$	8
Cash flows from investing activities:
Proceeds from the sale/maturity/prepayment of:
Fixed maturities, available-for-sale	$	58	$	50
Short-term investments	—		(2)
Payment for the purchase/origination of:
Fixed maturities, available-for-sale	(963)		(119)
Trading account securities	(2)		—
Other	—		(1)
Cash settlements related to derivative instruments, net	(96)		(24)
Other, net	(6)		—
Net cash provided by (used in) investing activities	$	(1,009)	$	(96)
Cash flows from financing activities:
Policyholders’ account balances:
Deposits	$	1,202	$	187
Withdrawals	(13)		(20)
Transfer (to) from Separate Accounts	(15)		(59)
Change in collateralized pledged liabilities	96		(1)
Other, net	—		(1)
Net cash provided by (used in) financing activities	$	1,270	$	106
Change in cash and cash equivalents	241		18
Cash and cash equivalents, beginning of year	294		127
Cash and cash equivalents, end of year	$	535	$	145

_______________

(1)    For the period ended March 31, 2023 includes a release of $69 million deferred tax valuation allowance. Refer to Note 10 of these Consolidated Financial Statements.

Prior period amounts have been adjusted for the implementation of ASU 2018-12: Targeted Improvements to the Accounting for Long-Duration Contracts.

See Notes to Financial Statements (Unaudited).

8

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited)

1)    ORGANIZATION

Equitable America’s primary business is providing variable annuity, life insurance and employee benefit products to both individuals and businesses. The Company is an indirect, wholly-owned subsidiary of Holdings. Equitable America is a stock life insurance company organized under the laws of Arizona.

2)    SIGNIFICANT ACCOUNTING POLICIES

Basis of Presentation

The unaudited interim financial statements (the “financial statements”) have been prepared in conformity with accounting principles generally accepted in the United States of America (“U.S. GAAP” or “GAAP”) on a basis consistent with reporting interim financial information in accordance with instructions to the Form 10-Q and Article 10 of Regulation S-X of the Securities and Exchange Commission (“SEC”).

In the opinion of management, all adjustments necessary for a fair statement of the financial position and results of operations have been made. All such adjustments are of a normal, recurring nature. Interim results are not necessarily indicative of the results that may be expected for the full year. These financial statements should be read in conjunction with the Company’s financial statements included in the Company’s Annual Report on Form 10-K for the year ended December 31, 2022. Certain prior period amounts were adjusted to reflect the adoption of ASU 2018-12: Financial Services - Insurance (Topic 944).

The terms “first quarter 2023” and “first quarter 2022” refer to the three months ended March 31, 2023 and 2022, respectively. The terms “first three months of 2023” and “first three months of 2022” refer to the three months ended March 31, 2023 and 2022, respectively.

Certain prior year amounts have been reclassified to conform to the current year’s presentation.

Adoption of New Accounting Pronouncements

Description	Effect on the Financial Statement or Other Significant Matters
ASU 2018-12: Financial Services - Insurance (Topic 944)
This ASU provides targeted improvements to existing recognition, measurement, presentation, and disclosure requirements for long-duration contracts issued by an insurance entity. The ASU primarily impacts four key areas, including: 1. Measurement of the liability for future policy benefits for traditional and limited payment contracts. The ASU requires companies to review, and if necessary, update cash flow assumptions at least annually for non-participating traditional and limited-payment insurance contracts. The ASU also prescribes the discount rate to be used in measuring the liability for future policy benefits for traditional and limited payment long-duration contracts. 2. Measurement of Market Risk Benefits (“ MRBs”). MRBs, as defined under the ASU, will encompass certain GMxB features associated with variable annuity products and other general account annuities with other than nominal market risk. 3. Amortization of deferred acquisition costs. The ASU simplifies the amortization of deferred acquisition costs and other balances amortized in proportion to premiums, gross profits, or gross margins, requiring such balances to be amortized on a constant level basis over the expected term of the contracts. 4. Expanded footnote disclosures. The ASU requires additional disclosures including information about significant inputs, judgements, assumptions and methods used in measurement.	On January 1, 2023, the Company adopted the new accounting standard ASU 2018-12 using the modified retrospective approach, except for MRBs which will use the full retrospective approach. Refer to “Transition impact of ASU 2018-12, Financial Services- Insurance (Topic 944): Targeted Improvements to the Accounting for Long-Duration Contracts” section within this note for further details.

9

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

Transition impact of ASU 2018-12, Financial Services—Insurance (Topic 944): Targeted Improvements to the Accounting for Long-Duration Contracts

The Company has not retrospectively adjusted its financial statements for the year ended December 31, 2020 to reflect the adoption of ASU 2018-12, consistent with the Division of Corporation Finance’s Financial Reporting Manual Section 11410.1.

The Company adopted ASU 2018-12 for liability for future policy benefits (“LFPB”), additional insurance liabilities, DAC and balances amortized on a basis consistent with DAC on a modified retrospective basis. ASU 2018-12 was adopted for MRBs on a full retrospective basis.

The majority of the transition impacts come from removal of DAC and URL adjustments balances recorded in accumulated other comprehensive income (AOCI) impact, resulting in a favorable AOCI. There is limited impact from LFPB and MRB as of transition.

The following table presents the effect of transition adjustment to total equity resulting from the adoption of ASU 2018-12 as of January 1, 2021:

	Retained Earnings		Accumulated Other Comprehensive Income		Total
	(in millions)
Liability for future policy benefits (1)	$	—	$	—	$	—
Market risk benefits	2		(1)		1
DAC	—		110		110
Unearned revenue liability and sales inducement assets (1)	—		(37)		(37)
Total transition adjustment before taxes	2		72		74
Income taxes	(1)		(15)		(16)
Total transition adjustment (net of taxes)	$	1	$	57	$	58

_____________

(1)Unearned revenue liability included within liability for future policy benefits financial statement line item in the balance sheet. Sales inducement assets are included in other assets in the balance sheets.

The following table summarizes the balance of and changes in DAC on January 1, 2021 resulting from the adoption of ASU 2018-12:

	Variable Universal Life		Indexed Universal Life		Total
	(in millions)
Balance, December 31, 2020	$	230	$	247	$	477
Adjustment for reversal of balances recorded in Accumulated Other Comprehensive Income	70		40		110
Balance, January 1, 2021	$	300	$	287	$	587

The following table summarizes the balance of and changes in sales inducement assets and unearned revenue liability on January 1, 2021 resulting from the adoption of ASU 2018-12:

	Variable Universal Life		Indexed Universal Life		Total
	(in millions)
Balance, December 31, 2020	$	55	$	14	$	69
Adjustment for reversal of balances recorded in Accumulated Other Comprehensive Income	28		9		37
Balance, January 1, 2021	$	83	$	23	$	106

DAC

Acquisition costs that vary with and are primarily related to the acquisition of new and renewal insurance business, reflecting incremental direct costs of contract acquisition with independent third parties or employees that are essential

10

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

to the contract transaction, as well as the portion of employee compensation, including employee fringe benefits and other costs directly related to underwriting, policy issuance and processing, medical inspection, and contract selling for successfully negotiated contracts including commissions, underwriting, agency and policy issue expenses, are deferred.

Contracts are measured on a grouped basis utilizing cohorts consistent with those used in the calculation of future policy benefit reserves. DAC is amortized on a constant level basis for the grouped contracts over the expected term of the contract. For life insurance products, DAC is amortized in proportion to the face amount in force. For annuity products DAC is amortized in proportion to policy counts. The constant level basis used for amortization determines the current period amortization considering both the current period’s actual experience and future projections. The amortization pattern is revised quarterly on a prospective basis. Amortization of DAC is included in Amortization of DAC, part of total benefits and other deductions.

For some products, policyholders can elect to modify product benefits, features, rights or coverages that occur by the exchange of a contract for a new contract, or by amendment, endorsement, or rider to a contract, or by election or coverage within a contract. These transactions are known as internal replacements. If such modification substantially changes the contract, the associated DAC is written off immediately through income and any new acquisition costs associated with the replacement contract are deferred.

Amount due to and from Reinsurers

For each of its reinsurance agreements, the Company determines whether the agreement provides indemnification against loss or liability relating to insurance risk in accordance with applicable accounting standards. Cessions under reinsurance agreements do not discharge the Company’s obligations as the primary insurer. The Company reviews all contractual features, including those that may limit the amount of insurance risk to which the reinsurer is subject or features that delay the timely reimbursement of claims.

For reinsurance of existing in-force blocks of long-duration contracts that transfer significant insurance risk, the difference, if any, between the amounts paid (received), and the liabilities ceded (assumed) related to the underlying contracts is considered the net cost of reinsurance at the inception of the reinsurance agreement. Subsequent amounts paid (received) on the reinsurance of in-force blocks, as well as amounts paid (received) related to new business, are recorded as premiums ceded (assumed); and amounts due from reinsurers (amounts due to reinsurers) are established.

Assets and liabilities relating to reinsurance agreements with the same reinsurer may be recorded net on the balance sheet, if a right of offset exists within the reinsurance agreement. In the event that reinsurers do not meet their obligations to the Company under the terms of the reinsurance agreements, reinsurance recoverable balances could become uncollectible. In such instances, reinsurance recoverable balances are stated net of allowances for uncollectible reinsurance.

Premiums, policy charges and fee income, and policyholders’ benefits include amounts assumed under reinsurance agreements and are net of reinsurance ceded. Amounts received from reinsurers for policy administration are reported in other revenues.

For reinsurance contracts, reinsurance recoverable balances are generally calculated using methodologies and assumptions that are consistent with those used to calculate the direct liabilities.

Ceded reinsurance transactions are recognized and measured in a manner consistent with underlying reinsured contracts, including using consistent assumptions. Assumed and ceded reinsurance contract rights and obligations are accounted for on a basis consistent with our direct contract. The reinsurance cost or benefit for traditional life non-participating and limited-payment contracts is recognized in proportion to the gross premiums of the underlying direct cohorts. The locked-in single A discount rate used to calculate the reinsurance cost or benefit is established at inception of the reinsurance contract. Changes to the single A discount rate are reflected in comprehensive income at each reporting date.

If the Company determines that a reinsurance agreement does not expose the reinsurer to a reasonable possibility of a significant loss from insurance risk, the Company records the agreement using the deposit method of accounting. Deposits received are included in other liabilities and deposits made are included within other assets. As amounts are paid or received, consistent with the underlying contracts, the deposit assets or liabilities are adjusted. Interest on such deposits is recorded as other income or other operating costs and expenses, as appropriate.

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

Policyholders’ Account Balances

Policyholders’ account balances relate to contracts or contract features where the Company has no significant insurance risk. This liability represents the contract value that has accrued to the benefit of the policyholder as of the balance sheet date.

Future Policy Benefits and Other Policyholders’ Liabilities

For traditional life insurance policies, future policy benefit liabilities are estimated using a net level premium method on the basis of actuarial assumptions as to mortality, persistency and interest established at policy issue. Assumptions established at policy issue as to mortality and persistency are based on the Company’s experience that, together with interest and expense assumptions, includes a margin for adverse deviation. Benefit liabilities for traditional annuities during the accumulation period are equal to accumulated policyholders’ fund balances and, after annuitization, are equal to the present value of expected future payments. Interest rates used in establishing such liabilities range from 3.5% to 4.5% of life insurance liabilities and a rate of 0.3% for retained annuity liabilities.

For traditional life insurance policies and limited pay contracts, contracts are grouped into cohorts by contract type and issue year. The Company quarterly updates its estimate of cash flows using actual experience and current future cash flow assumptions, which is reflected in an updated net premium ratio used to calculate the liability. The ratio of actual and future expected claims to actual and future expected premiums determines the net premium ratio. The policy administration expense assumption is not updated after policy issuance. If actual expenses differ from the original expense assumptions, the differences are recognized in the period identified. The revised net premium ratio is used to determine the updated liability for future policy benefits as of the beginning of the reporting period, discounted at the original contract issuance rate. Changes in the liability due to current discount rates differing from original rates are included in other comprehensive income within the statement of comprehensive income.

For non-participating traditional life insurance policies (Term) and limited pay contracts (Payout, Pension), the discount rate assumption used is corporate A rated forward curve. We use a forward curve based upon a Bloomberg index. The liability is remeasured each quarter with the remeasurement change reported in other comprehensive income. The locked-in discount rate is generally based on expected investment returns at contract inception for contracts issued prior to January 1, 2021 and the upper medium grade fixed income corporate instrument yield (i.e., single A) at contract inception for contracts issued after January 1, 2021. The Company developed an LDTI discount rate methodology used to calculate the LFPB for its traditional insurance liabilities and constructed a discount rate curve that references upper-medium grade (low credit risk) fixed-income instrument yields (i.e. Single-A rated Corporate bond yields) which are meant to reflect the duration characteristics of the corresponding insurance liabilities. The methodology uses observable market data, where available, and uses various estimation techniques in line with fair value guidance (such as interpolation and extrapolation) where data is limited. Discount rates are updated quarterly.

For limited-payment products, gross premiums received in excess of net premiums are deferred at initial recognition as a deferred profit liability (“DPL”). DPL will be amortized in relation to the expected future benefit payments. As the calculation of the DPL is based on discounted cash flows, interest accrues on the unamortized DPL balance using the discount rate determined at contract issuance. The DPL is updated at the same time as the estimates for cash flows for the liability for future policy benefits. Any difference between the recalculated and beginning of period DPL is recognized in remeasurement gain or loss in the statement of income (loss), Remeasurement of Liability for Future Policy Benefits, part of total benefits and other deductions. On the balance sheet the DPL is recorded in the liability for future policy benefits.

Additional liabilities for contract or contract feature that provide for additional benefits in addition to the account balance but are not market risk benefits or embedded derivatives (“additional insurance liabilities”) are established by estimating the expected value of death or other insurance benefits in excess of the projected contract accumulation value and recognizing the excess over the estimated life based on expected assessments (i.e., benefit ratio). The liability equals the current benefit ratio multiplied by cumulative assessments recognized to date, plus interest, less cumulative excess payments to date. These reserves are recorded within future policy benefits and other policyholders’ liabilities. The determination of this estimated future policy benefits liability is based on models that involve numerous assumptions and subjective judgments, including those regarding expected market rates of return and volatility, contract surrender and withdrawal rates, and mortality experience. There can be no assurance that actual experience will be consistent with management’s estimates. Assumptions are reviewed annually and updated with the remeasurement gain or loss reflected in total benefit expense.

12

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

The Company recognizes an adjustment in other comprehensive income for the additional insurance liabilities for unrealized gains and losses not included when calculating the present value of expected assessments for the benefit ratios.

The Company conducts annual premium deficiency testing except for liability for future policy benefits for non-participating traditional and limited payment contracts. The Company reviews assumptions and determines whether the sum of existing liabilities and the present value of future gross premiums is sufficient to cover the present value of future benefits to be paid and settlement costs. Anticipated investment income is considered when performing premium deficiency for long duration contracts. The anticipated investment income is projected based on current investment portfolio returns grading to long term reinvestment rates over the projection periods, based on anticipated gross reinvestment spreads, defaults and investment expenses. Premium deficiency reserves are recorded in certain instances where the policyholder liability for a particular line of business may not be deficient in the aggregate to trigger loss recognition, but the pattern of earnings may be such that profits are expected to be recognized in earlier years followed by losses in later years. This pattern of profits followed by losses is exhibited in our VISL business and is generated by the cost structure of the product or secondary guarantees in the contract. The secondary guarantee ensures that, subject to specified conditions, the policy will not terminate and will continue to provide a death benefit even if there is insufficient policy value to cover the monthly deductions and charges. We accrue for these PFBL using a dynamic approach that changes over time as the projection of future losses change.

Liabilities for unpaid claims and claim adjustment expenses are established for the Company’s employee benefits products which include the following Group products: long-term and short-term disability, life insurance, vision, dental, critical Illness, and accident. Unpaid claim and claim adjustment expenses consist of (i) claim reserves for known claims that are unpaid as of the balance sheet date; (ii) Incurred But Not Reported reserves for claims where the insured event occurred but has not yet been reported to the Company or the insured has not yet satisfied elimination period to be eligible for the benefits; and (iii) claim adjustment expense reserves for settling the claim run-out. The Company determines Incurred But Not Reported reserves and reviews the claim reserves for the long-term disability claims provided by a reinsurer managing the claims on the Company’s behalf. The claim adjustment expense reserves are set based on the Company’s anticipated cost associated with claim administration expenses on the run-out of business.

For long-term disability (“LTD”) the claim reserves for the reported claims are calculated as the present value of the net monthly LTD benefits (Social Security and other offsets may be estimated if unknown) and the best estimate probabilities of the claimant remaining disabled for a given benefit payment which are based on a termination rates table adjusted for experience. Should the offsets be estimated, they are estimated using the claimant’s salary, duration of disability and the probability of the offset award.

The disability termination rates vary based on the insured’s age at disability, gender, elimination period, the duration of disability, social security status and the number of months remaining in the benefit period. The rates account for the probabilities of both recovery and death. The reserves vary with plan provisions such as monthly benefit, offsets, own occupation period, benefit duration, cost of living adjustment (“COLA”), and minimum and maximum benefits. The discount rate assumptions for these liabilities are set annually and are based on projected investment returns for the asset portfolios. The interest rate is locked in for each claimant based on the year of disability.

For long-term disability, critical illness, and group accident the incurred but not reported reserves are determined using the expected loss ratio method, where the expected loss ratio is applied to the premiums to determine ultimate liabilities. For dental and vision the incurred but not reported reserves are determined using completion factors, where these factors complete paid-to-date claims to the ultimate liability based on past experience. For short-term disability and group life the incurred but not reported reserves are determined using a combination of expected loss ratio and completion factor methods.

Market Risk Benefits

Market risk benefits (“MRBs”) are contracts or contract features that provide protection to the contract holder from other than nominal capital market risk and expose the Company to other than nominal capital market risk. Market risk benefits include contract features that provide minimum guarantees to policyholders and include GMIB, GMDB, and ROP DB benefits. MRBs are measured at fair value on a seriatim basis using an ascribed fee approach based upon policyholder behavior projections and risk neutral economic scenarios adjusted based on the facts and circumstances of the Company’s product features. The MRB Asset and MRB Liability will be equal to the average present value of benefits and risk margins less the average present value of ascribed fees. Ascribed fees will consist of the fee needed, under a stochastically generated set of risk-neutral scenarios, so that the mean present value of claims, including any

13

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

risk charge, is equal to the mean present value of the projected attributed fees which will be capped at average present value of total policyholder contractual fees. The attributed fee percentage is considered a fixed term of the MRB feature and is held static over the life of the contract. Changes in fair value are recognized as a remeasurement gain/loss in the Change in market risk benefits and purchased market risk benefits, part of total benefits and other deductions except for the portion of the change in the fair value due to change in the Company’s own credit risk, which is recognized in other than comprehensive income. Additionally, when an annuitization occurs (for annuitization benefits) or upon extinguishment of the account balance (for withdrawal benefits) the balance related to the MRB will be derecognized and the amount deducted (after derecognition of any related amount included in accumulated other comprehensive income) shall be used in the calculation of the liability for future policy benefits for the payout annuity. Upon derecognition, any related balance will be removed from AOCI.

The Company has issued and continues to offer certain variable annuity products with GMDB and/or contain a GMIB (collectively, the “GMxB features”) which, if elected by the policyholder after a stipulated waiting period from contract issuance, guarantees a minimum lifetime annuity based on predetermined annuity purchase rates that may be in excess of what the contract account value can purchase at then-current annuity purchase rates. This minimum lifetime annuity is based on predetermined annuity purchase rates applied to a GMIB base.

Features in ceded reinsurance contracts that meet the definition of MRBs are accounted for at fair value. The fees used to determine the fair value of the reinsured market risk benefit are those defined in the reinsurance contract. The expected periodic future premiums would represent cash outflows and the expected future benefits would represent cash inflows in the fair value calculation. On the ceded side, the Purchased MRB will be measured considering the counterparty credit risk of the reinsurer, while the direct contract liabilities will be measured considering the instrument-specific credit risk of the insurer. As a result of the difference in the treatment of the counterparty credit risk, the fair value of the direct and ceded contracts may be different even if the contractual fees and benefits are the same. Changes in instrument-specific credit risk of the Company is included in the fair value of its market risk benefit, whether in an asset or liability position, and whether related to an issued or purchased MRB, is recognized in OCI. The counterparty credit risk of the reinsurer is recorded in the statements of income (loss).

3)    INVESTMENTS

Fixed Maturities AFS

The components of fair value and amortized cost for fixed maturities classified as AFS on the balance sheets excludes accrued interest receivable because the Company elected to present accrued interest receivable within other assets. Accrued interest receivable on AFS fixed maturities as of March 31, 2023 and December 31, 2022 was $33 million and $23 million, respectively. There was no accrued interest written off for AFS fixed maturities for the three months ended March 31, 2023 and 2022.

The following tables provide information relating to the Company’s fixed maturities classified as AFS.

14

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

AFS Fixed Maturities by Classification

	Amortized Cost		Allowance for Credit Losses		Gross Unrealized Gains		Gross Unrealized Losses		Fair Value
	(in millions)
March 31, 2023:
Fixed Maturities:
Corporate (1)	$	3,272	$	—	$	13	$	298	$	2,987
U.S. Treasury, government and agency	14		—		—		—		14
States and political subdivisions	50		—		—		7		43
Foreign governments	31		—		—		—		31
Residential mortgage-backed	9		—		—		2		7
Asset-backed (2)	77		—		—		2		75
Commercial mortgage-backed	84		—		—		16		68
Total at March 31, 2023	$	3,537	$	—	$	13	$	325	$	3,225
December 31, 2022:
Fixed Maturities:
Corporate (1)	$	2,417	$	—	$	—	$	359	$	2,058
U.S. Treasury, government and agency	14		—		—		—		14
States and political subdivisions	43		—		—		9		34
Residential mortgage-backed	8		—		—		2		6
Asset-backed (2)	43		—		—		2		41
Commercial mortgage-backed	81		—		—		16		65
Total at December 31, 2022	$	2,606	$	—	$	—	$	388	$	2,218

______________

(1)Corporate fixed maturities include both public and private issues.

(2)Includes credit-tranched securities collateralized by sub-prime mortgages, credit risk transfer securities. and other asset types.

The contractual maturities of AFS fixed maturities as of March 31, 2023 are shown in the table below. Bonds not due at a single maturity date have been included in the table in the final year of maturity. Actual maturities may differ from contractual maturities because borrowers may have the right to call or prepay obligations with or without call or prepayment penalties.

Contractual Maturities of AFS Fixed Maturities

	Amortized Cost (Less Allowance for Credit Losses)		Fair Value
	(in millions)
March 31, 2023:
Contractual maturities:
Due in one year or less	$	85	$	85
Due in years two through five	742		726
Due in years six through ten	1,481		1,397
Due after ten years	1,059		867
Subtotal	3,367		3,075
Residential mortgage-backed	9		7
Asset-backed	77		75
Commercial mortgage-backed	84		68
Total at March 31, 2023	$	3,537	$	3,225

The following table shows proceeds from sales, gross gains (losses) from sales and allowance for credit losses for AFS fixed maturities.

15

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

Proceeds from Sales, Gross Gains (Losses) from Sales and Allowance for Credit and Intent to Sell Losses for AFS Fixed Maturities

	Three Months Ended March 31,
	2023		2022
	(in millions)
Proceeds from sales	$	50	$	23
Gross gains on sales	$	—	$	—
Gross losses on sales	$	(5)	$	1
Net (increase) decrease in Allowance for Credit and Intent to Sell losses	$	—	$	—

The following table sets forth the amount of credit loss impairments on AFS fixed maturities held by the Company at the dates indicated and the corresponding changes in such amounts.

AFS Fixed Maturities - Credit and Intent to Sell Loss Impairments

	Three Months Ended March 31,
	2023		2022
	(in millions)
Balance, beginning of period	$	—	$	2
Previously recognized impairments on securities that matured, paid, prepaid or sold	—		—
Recognized impairments on securities impaired to fair value this period (1)	—		—
Credit losses recognized this period on securities for which credit losses were not previously recognized	—
Additional credit losses this period on securities previously impaired	—		—
Increases due to passage of time on previously recorded credit losses	—		—
Accretion of previously recognized impairments due to increases in expected cash flows (for OTTI securities 2019 and prior)	—		—
Balance at March 31,	$	—	$	2

______________

(1)Represents circumstances where the Company determined in the current period that it intends to sell the security, or it is more likely than not that it will be required to sell the security before recovery of the security’s amortized cost.

The tables that follow below present a roll-forward of net unrealized investment gains (losses) recognized in AOCI.

Net Unrealized Gains (Losses) on AFS Fixed Maturities

	Net Unrealized Gains (Losses) on Investments		Policyholders’ Liabilities		Deferred Income Tax Asset (Liability)		AOCI Gain (Loss) Related to Net Unrealized Investment Gains (Losses)
	(in millions)
Balance, January 1, 2023	$	(388)	$	8	$	161	$	(219)
Net investment gains (losses) arising during the period	71		—		—		71
Reclassification adjustment:
Included in net income (loss)	5		—		—		5
Other (1)	—		—		—		—
Impact of net unrealized investment gains (losses)	—		(2)		(16)		(18)
Net unrealized investment gains (losses) excluding credit losses	(312)		6		145		(161)
Net unrealized investment gains (losses) with credit losses	—		—		—		—
Balance, March 31, 2023	$	(312)	$	6	$	145	$	(161)

16

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

	Net Unrealized Gains (Losses) on Investments		Policyholders’ Liabilities		Deferred Income Tax Asset (Liability)		AOCI Gain (Loss) Related to Net Unrealized Investment Gains (Losses)
	(in millions)
Balance, January 1, 2022	$	128	$	(3)	$	(26)	$	99
Net investment gains (losses) arising during the period	(222)		—		—		(222)
Reclassification adjustment:
Included in net income (loss)	1		—		—		1
Other	—		—		—		—
Impact of net unrealized investment gains (losses)	—		5		45		50
Net unrealized investment gains (losses) excluding credit losses	(93)		2		19		(72)
Net unrealized investment gains (losses) with credit losses	—		—		—		—
Balance, March 31, 2022	$	(93)	$	2	$	19	$	(72)

The following tables disclose the fair values and gross unrealized losses of the 853 issues as of March 31, 2023 and the 845 issues as of December 31, 2022 that are not deemed to have credit losses, aggregated by investment category and length of time that individual securities have been in a continuous unrealized loss position for the specified periods at the dates indicated:

AFS Fixed Maturities in an Unrealized Loss Position for Which No Allowance Is Recorded

	Less Than 12 Months				12 Months or Longer				Total
	Fair Value		Gross Unrealized Losses		Fair Value		Gross Unrealized Losses		Fair Value		Gross Unrealized Losses
	(in millions)
March 31, 2023:
Fixed Maturities:
Corporate	$	730	$	22	$	1,472	$	276	$	2,202	$	298
U.S. Treasury, government and agency	7		—		7		—		14		—
States and political subdivisions	6		—		28		7		34		7
Foreign governments	14		—		—		—		14		—
Residential mortgage-backed	—		—		6		2		6		2
Asset-backed	14		—		23		2		37		2
Commercial mortgage-backed	—		—		65		16		65		16
Redeemable preferred stock	—		—		—		—		—		—
Total at March 31, 2023	$	771	$	22	$	1,601	$	303	$	2,372	$	325
December 31, 2022:
Fixed Maturities:
Corporate	$	1,446	$	159	$	590	$	200	$	2,036	$	359
States and political subdivisions	19		4		13		5		32		9
Residential mortgage-backed	2		—		4		2		6		2
Asset-backed	35		1		6		1		41		2
Commercial mortgage-backed	5		1		60		15		65		16
Total at December 31, 2022	$	1,507	$	165	$	673	$	223	$	2,180	$	388

17

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

The Company’s investments in fixed maturities do not include concentrations of credit risk of any single issuer greater than 10% of the equity of the Company, other than securities of the U.S. government, U.S. government agencies, and certain securities guaranteed by the U.S. government. The Company maintains a diversified portfolio of corporate securities across industries and issuers and does not have exposure to any single issuer in excess of 1.3% of total corporate securities. The largest exposures to a single issuer of corporate securities held as of March 31, 2023 and December 31, 2022 were $39 million and $24 million, respectively, representing 10.3% and 10.3% of the equity of the Company.

Corporate high yield securities, consisting primarily of public high yield bonds, are classified as other than investment grade by the various rating agencies, i.e., a rating below Baa3/BBB- or the NAIC designation of 3 (medium investment grade), 4 or 5 (below investment grade) or 6 (in or near default). As of March 31, 2023 and December 31, 2022, respectively, approximately $7 million and $4 million, or 0.2% and 0.2%, of the $3.5 billion and $2.6 billion aggregate amortized cost of fixed maturities held by the Company were considered to be other than investment grade. These securities had no gross unrealized losses as of March 31, 2023 and December 31, 2022.

As of March 31, 2023 and December 31, 2022, respectively, the $303 million and $223 million of gross unrealized losses of twelve months or more were concentrated in corporate securities. In accordance with the policy described in Note 2 of the Notes to these Financial Statements, the Company concluded that an allowance for credit losses for these securities was not warranted at either March 31, 2023 or December 31, 2022. As of March 31, 2023 and December 31, 2022, the Company did not intend to sell the securities nor will it likely be required to dispose of the securities before the anticipated recovery of their remaining amortized cost basis.

Based on the Company’s evaluation both qualitatively and quantitatively of the drivers of the decline in fair value of fixed maturity securities as of March 31, 2023, the Company determined that the unrealized loss was primarily due to increases in interest rates and credit spreads.

Mortgage Loans on Real Estate

The Company held two commercial mortgage loans with a carrying value of $17 million and $17 million at March 31, 2023 and December 31, 2022. The loans were issued prior to 2017 for apartment complex properties located in the Mid-Atlantic region. The loans were current as of March 31, 2023 and December 31, 2022 with LTV ratios between 0%-50% and DSC ratios of 2.0x or greater.

Accrued interest receivable as of March 31, 2023 and December 31, 2022 was $0 million and no accrued interest was written off for the three months ended March 31, 2023 and 2022. The allowance for credit losses was $0 million as of March 31, 2023 and 2022, with a change of $0 million for the periods ended.

As of March 31, 2023 and 2022, the Company had no loans for which foreclosure was probable included within the individually assessed mortgage loans, and accordingly had no associated allowance for credit losses.

Equity Securities

The table below presents a breakdown of unrealized and realized gains and (losses) on equity securities during the three months ended March 31, 2023 and 2022.

Unrealized and Realized Gains (Losses) from Equity Securities

	Three Months Ended March 31,
	2023		2022
	(in millions)
Net investment gains (losses) recognized during the period on securities held at the end of the period	$	(1)	$	(2)
Net investment gains (losses) recognized on securities sold during the period	—		—
Unrealized and realized gains (losses) on equity securities	$	(1)	$	(2)

18

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

Trading Securities

As of March 31, 2023 and December 31, 2022, respectively, the fair value of the Company’s trading securities was $1 million and $1 million. As of March 31, 2023 and December 31, 2022, respectively, trading securities included the General Account’s investment in Separate Accounts had carrying values of $1 million and $1 million.

The table below shows a breakdown of net investment income (loss) from trading securities during the three months ended March 31, 2023 and 2022.

Net Investment Income (Loss) from Trading Securities

	Three Months Ended March 31,
	2023		2022
	(in millions)
Net investment gains (losses) recognized during the period on securities held at the end of the period	$	(2)	$	—
Net investment gains (losses) recognized on securities sold during the period	—		—
Unrealized and realized gains (losses) on trading securities	(2)		—
Interest and dividend income from trading securities	—		—
Net investment income (loss) from trading securities	$	(2)	$	—

4)    DERIVATIVES

The Company uses derivatives as part of its overall asset/liability risk management primarily to reduce exposures to equity market and interest rate risks. Derivative hedging strategies are designed to reduce these risks from an economic perspective and are all executed within the framework of a “Derivative Use Plan” approved by applicable states’ insurance law. The Company does not designate any derivatives as hedge accounting. Operation of these hedging programs is based on models involving numerous estimates and assumptions, including, among others, mortality, lapse, surrender and withdrawal rates, election rates, fund performance, market volatility and interest rates. A wide range of derivative contracts can be used in these hedging programs, including exchange traded equity and interest rate futures contracts as well as equity options. The derivative contracts are collectively managed in an effort to reduce the economic impact of unfavorable changes in guaranteed benefits’ exposures attributable to movements in capital markets.

Derivatives Utilized to Hedge Exposure to Variable Annuities with Guarantee Features

The Company has issued and continues to offer variable annuity products with GMxB features which are accounted for as market risk benefits. The risk associated with the GMDB feature is that under-performance of the financial markets could result in GMDB benefits, in the event of death, being higher than what accumulated policyholders’ account balances would support. The risk associated with the GMIB feature is that under-performance of the financial markets could result in the present value of GMIB, in the event of annuitization, being higher than what accumulated policyholders’ account balances would support, taking into account the relationship between current annuity purchase rates and the GMIB guaranteed annuity purchase rates. The risk associated with products that have a GMxB feature and are accounted for as market risk benefits is that under-performance of the financial markets could result in the GMxB features benefits being higher than what accumulated policyholders’ account balances would support.

For GMxB features, the Company retains certain risks including basis, credit spread and some volatility risk and risk associated with actual experience versus expected actuarial assumptions for mortality, lapse and surrender, withdrawal and policyholder election rates, among other things. The derivative contracts are managed to correlate with changes in the value of the GMxB features that result from financial markets movements.

Derivatives Utilized to Hedge Crediting Rate Exposure on SCS, MSO and IUL Products/Investment Options

The Company hedges crediting rates in the SCS, MSO in the variable life insurance products and IUL insurance products. These products permit the contract owner to participate in the performance of an index, ETF or commodity price movement up to a cap for a set period of time. They also contain a protection feature, in which the Company will

19

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

absorb, up to a certain percentage, the loss of value in an index, ETF or commodity price, which varies by product segment.

In order to support the returns associated with these features, the Company enters into derivative contracts whose payouts, in combination with fixed income investments, emulate those of the index, ETF or commodity price, subject to caps and buffers, thereby substantially reducing any exposure to market-related earnings volatility.

The tables below present quantitative disclosures about the Company’s derivative instruments, including those embedded in other contracts required to be accounted for as derivative instruments:

The following table presents the gross notional amount and estimated fair value of the Company’s derivatives:

Derivative Instruments by Category

	March 31, 2023						December 31, 2022
			Fair Value						Fair Value
	Notional Amount		Derivative Assets		Derivative Liabilities		Notional Amount		Derivative Assets		Derivative Liabilities
	(in millions)
Derivatives: (1)
Equity contracts:
Futures	$	944	$	—	$	—	$	394	$	—	$	—
Options	751		194		78		209		34		16
Interest rate contracts:
Futures	306		—		—		282		—		—
Other contracts:
Margin	—		62		—		—		29		—
Collateral	—		—		99		—		—		3
Total:	2,001		256		177		885		63		19
Embedded derivatives:
MSO, SCS and IUL indexed features (2)	—		—		288		—		—		87
Total embedded derivatives	—		—		288		—		—		87
Total derivative instruments	$	2,001	$	256	$	465	$	885	$	63	$	106

______________

(1)Reported in other invested assets in the balance sheets.

(2)Reported in policyholders’ account balances in the balance sheets.

The following table presents the effects of derivative instruments on the statements of income and comprehensive income (loss).

20

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

	Three Months Ended March 31,
	2023		2022
	Net Derivatives Gain (Losses)		Net Derivatives Gain (Losses)
	(in millions)
Derivatives:
Equity contracts:
Futures	$	16	$	(9)
Options	6		—
Interest rate contracts:
Futures	20		(12)
Total:	42		(21)
Embedded derivatives:
MSO, SCS and IUL indexed features	(36)		13
Total Embedded Derivatives	(36)		13
Total Derivatives instruments (1)	$	6	$	(8)

______________

(1)Reported in net derivative gains (losses) in the statements of income (loss).

Equity-Based and Treasury Futures Contracts Margin

All outstanding equity-based futures contracts as of March 31, 2023 and December 31, 2022 are exchange-traded and net settled daily in cash. As of March 31, 2023 and December 31, 2022, respectively, the Company had open exchange-traded futures positions on: (i) the S&P 500, Nasdaq, Russell 2000 and Emerging Market indices, having initial margin requirements of $52 million and $22 million and (ii) the 2-year, 5-year and 10-year U.S. Treasury Notes on U.S. Treasury bonds and ultra-long bonds, having initial margin requirements of $11 million and $10 million.

Collateral Arrangements

The Company generally has executed a CSA under the ISDA Master Agreement it maintains with each of its OTC derivative counterparties that requires both posting and accepting collateral either in the form of cash or high-quality securities, such as U.S. Treasury securities, U.S. government and government agency securities and investment grade corporate bonds. The Company nets the fair value of all derivative financial instruments with counterparties for which an ISDA Master Agreement and related CSA have been executed. As of March 31, 2023 and December 31, 2022, respectively, the Company held $99 million and $3 million in cash and securities collateral delivered by trade counterparties, representing the fair value of the related derivative agreements. The unrestricted cash collateral is reported in other invested assets. The Company posted collateral of $0 million and $0 million as of March 31, 2023 and December 31, 2022, respectively, in the normal operation of its collateral arrangements. The Company is exposed to losses in the event of non-performance by counterparties to financial derivative transactions with a positive fair value. The Company manages credit risk by: (i) entering into derivative transactions with highly rated major international financial institutions and other creditworthy counterparties governed by master netting agreements, as applicable; (ii) trading through central clearing and OTC parties; (iii) obtaining collateral, such as cash and securities, when appropriate; and (iv) setting limits on single party credit exposures which are subject to periodic management review.

Substantially all of the Company’s derivative agreements have zero thresholds which require daily full collateralization by the party in a liability position. In addition, certain of the Company’s derivative agreements contain credit-risk related contingent features; if the credit rating of one of the parties to the derivative agreement is to fall below a certain level, the party with positive fair value could request termination at the then fair value or demand immediate full collateralization from the party whose credit rating fell and is in a net liability position.

As of March 31, 2023 and December 31, 2022, there were no net liability derivative positions with counterparties with credit risk-related contingent features whose credit rating has fallen. All derivatives have been appropriately collateralized by the Company or the counterparty in accordance with the terms of the derivative agreements.

21

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

The following tables presents information about the Company’s offsetting of financial assets and liabilities and derivative instruments as of March 31, 2023 and December 31, 2022:

Offsetting of Financial Assets and Liabilities and Derivative Instruments

As of March 31, 2023

	Gross Amount Recognized		Gross Amount Offset in the Balance Sheets		Net Amount Presented in the Balance Sheets		Gross Amount not Offset in the Balance Sheets (1)		Net Amount
	(in millions)
Assets:
Derivative assets	$	256	$	177	$	79	$	—	$	79
Other financial assets	3		—		3		—		3
Other invested assets	$	259	$	177	$	82	$	—	$	82
Liabilities:
Derivative liabilities	$	177	$	177	$	—	$	—	$	—
Other financial liabilities	182		—		182		—		182
Other liabilities	$	359	$	177	$	182	$	—	$	182

______________

(1)Financial instruments sent (held).

As of December 31, 2022

	Gross Amount Recognized		Gross Amount Offset in the Balance Sheets		Net Amount Presented in the Balance Sheets		Gross Amount not Offset in the Balance Sheets (1)		Net Amount
	(in millions)
Assets:
Derivative assets	$	63	$	18	$	45	$	—	$	45
Other financial assets	2		—		2		—		2
Other invested assets	$	65	$	18	$	47	$	—	$	47
Liabilities:
Derivative liabilities	$	19	$	18	$	1	$	—	$	1
Other financial liabilities	72		—		72		—		72
Other liabilities	$	91	$	18	$	73	$	—	$	73

______________

(1)Financial instruments sent (held).

5)    DAC AND OTHER DEFERRED ASSETS/LIABILITIES

Changes in the DAC asset for the three months ended March 31, 2023 and 2022 were as follows:

	VUL (1)		IUL (2)		GMxB Core		Investment Edge		SCS		Total
	(in millions)
Balance, beginning of the period	$	410	$	296	$	40	$	1	$	13	$	760
Capitalization	17		3		9		5		42		76
Amortization	(6)		(4)		(1)		—		(1)		(12)
Balance, March 31, 2023	$	421	$	295	$	48	$	6	$	54	$	824

______________

(1)    “VUL” defined as Variable Universal Life.

(2)    “IUL” defined as Indexed Universal Life.

22

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

	VUL (1)		IUL (2)		GMxB Core		Investment Edge		SCS		Total
	(in millions)
Balance, beginning of the period	$	361	$	297	$	14	$	—	$	—	$	672
Capitalization	17		5		4		—		—		26
Amortization	(5)		(5)		—		—		—		(10)
Balance, March 31, 2022	$	373	$	297	$	18	$	—	$	—	$	688

______________

(1)    “VUL” defined as Variable Universal Life.

(2)    “IUL” defined as Indexed Universal Life.

Changes in the Sales Inducement Assets for the three months ended March 31, 2023 and 2022 were as follows:

	Three Months Ended March 31,
	2023		2022
	GMxB Core
	(in millions)
Balance, beginning of the period	$	1	$	—
Capitalization	—		—
Amortization	—		—
Balance, end of the period	$	1	$	—

Changes in the Unearned Revenue Liability for the three months ended March 31, 2023 and 2022 were as follows:

	Three Months Ended March 31,
	2023				2022
	VUL		IUL		VUL		IUL
	(in millions)
Balance, beginning of the period	$	159	$	157	$	118	$	94
Capitalization	13		17		12		18
Amortization	(2)		(3)		(2)		(2)
Balance, end of the period	$	170	$	171	$	128	$	110

The following table presents a reconciliation of DAC to the balance sheet.

	March 31, 2023		December 31, 2022
	(in millions)
VUL	$	421	$	410
IUL	295		296
GMxB Core	48		40
Investment Edge	6		1
SCS	54		13
Total	$	824	$	760

Annually, or as circumstances warrant, we will review the associated decrements assumptions. (i.e. mortality and lapse) based on our multi-year average of companies experience with actuarial judgements to reflect other observable industry trends. In addition to DAC, the Unearned Revenue Liability and Sales Inducement Asset (“SIA”) use similar techniques and quarterly update processes for balance amortization.

6)    FAIR VALUE DISCLOSURES

U.S. GAAP establishes a fair value hierarchy that requires an entity to maximize the use of observable inputs and minimize the use of unobservable inputs when measuring fair value, and identifies three levels of inputs that may be used to measure fair value:

23

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

Level 1    Unadjusted quoted prices for identical instruments in active markets. Level 1 fair values generally are supported by market transactions that occur with sufficient frequency and volume to provide pricing information on an ongoing basis.

Level 2    Observable inputs other than Level 1 prices, such as quoted prices for similar instruments, quoted prices in markets that are not active, and inputs to model-derived valuations that are directly observable or can be corroborated by observable market data.

Level 3    Unobservable inputs supported by little or no market activity and often requiring significant management judgment or estimation, such as an entity’s own assumptions about the cash flows or other significant components of value that market participants would use in pricing the asset or liability.

The Company uses unadjusted quoted market prices to measure fair value for those instruments that are actively traded in financial markets. In cases where quoted market prices are not available, fair values are measured using present value or other valuation techniques. The fair value determinations are made at a specific point in time, based on available market information and judgments about the financial instrument, including estimates of the timing and amount of expected future cash flows and the credit standing of counterparties. Such adjustments do not reflect any premium or discount that could result from offering for sale at one time the Company’s entire holdings of a particular financial instrument, nor do they consider the tax impact of the realization of unrealized gains or losses. In many cases, the fair value cannot be substantiated by direct comparison to independent markets, nor can the disclosed value be realized in immediate settlement of the instrument.

Management is responsible for the determination of the value of investments carried at fair value and the supporting methodologies and assumptions. Under the terms of various service agreements, the Company often utilizes independent valuation service providers to gather, analyze, and interpret market information and derive fair values based upon relevant methodologies and assumptions for individual securities. These independent valuation service providers typically obtain data about market transactions and other key valuation model inputs from multiple sources and, through the use of widely accepted valuation models, provide a single fair value measurement for individual securities for which a fair value has been requested. As further described below with respect to specific asset classes, these inputs include, but are not limited to, market prices for recent trades and transactions in comparable securities, benchmark yields, interest rate yield curves, credit spreads, quoted prices for similar securities, and other market-observable information, as applicable. Specific attributes of the security being valued also are considered, including its term, interest rate, credit rating, industry sector, and when applicable, collateral quality and other security- or issuer-specific information. When insufficient market observable information is available upon which to measure fair value, the Company either will request brokers knowledgeable about these securities to provide a non-binding quote or will employ internal valuation models. Fair values received from independent valuation service providers and brokers and those internally modeled or otherwise estimated are assessed for reasonableness.

Assets and Liabilities Measured at Fair Value on a Nonrecurring Basis

Fair value measurements are required on a non-recurring basis for certain assets only when an impairment or other events occur. As of March 31, 2023 and December 31, 2022, no assets or liabilities were required to be measured at fair value on a non-recurring basis.

Assets and Liabilities Measured at Fair Value on a Recurring Basis

Assets and liabilities measured at fair value on a recurring basis are summarized below.

24

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

Fair Value Measurements as of March 31, 2023

	Level 1		Level 2		Level 3		Total
	(in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate (1)	$	—	$	2,950	$	37	$	2,987
U.S. Treasury, government and agency	—		14		—		14
States and political subdivisions	—		43		—		43
Foreign governments	—		31		—		31
Residential mortgage-backed	—		7		—		7
Asset-backed (2)	—		75		—		75
Commercial mortgage-backed	—		68		—		68
Total fixed maturities, AFS	—		3,188		37		3,225
Other equity investments	—		18		—		18
Other invested assets:
Options	—		116		—		116
Total other invested assets	—		116		—		116
Cash equivalents	508		—		—		508
Purchased market risk benefits	—		—		11		11
Assets for market risk benefits	—		—		17		17
Separate Accounts assets (3)	3,858		7		—		3,865
Total Assets	$	4,366	$	3,329	$	65	$	7,760
Liabilities:
MSO and IUL indexed features’ liability	—		288		—		288
Liabilities for market risk benefits	—		—		14		14
Total Liabilities	$	—	$	288	$	14	$	302

______________

(1)Corporate fixed maturities includes both public and private issues.

(2)Includes credit-tranched securities collateralized by sub-prime mortgages, credit risk transfer securities and other asset types.

(3)Separate Accounts assets included in the fair value hierarchy exclude investments not fair valued including other assets of $2 million.

25

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

Fair Value Measurements as of December 31, 2022

	Level 1		Level 2		Level 3		Total
	(in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate (1)	$	—	$	2,040	$	18	$	2,058
U.S. Treasury, government and agency	—		14		—		14
States and political subdivisions	—		34		—		34
Residential mortgage-backed	—		6		—		6
Asset-backed (2)	—		41		—		41
Commercial mortgage-backed	—		65		—		65
Total fixed maturities, AFS	—		2,200		18		2,218
Other equity investments	—		19		—		19
Options	—		18		—		18
Total other invested assets	—		18		—		18
Cash equivalents	272		—		—		272
Purchased market risk benefits	—		—		13		13
Assets for market risk benefits	—		—		12		12
Separate Accounts assets	3,367		7		—		3,374
Total Assets	$	3,639	$	2,244	$	43	$	5,926
Liabilities:
MSO and IUL indexed features’ liability	—		87		—		87
Liabilities for market risk benefits	—		—		15		15
Total Liabilities	$	—	$	87	$	15	$	102

______________

(1)Corporate fixed maturities includes both public and private issues.

(2)Includes credit-tranched securities collateralized by sub-prime mortgages, credit risk transfer securities and other asset types.

Public Fixed Maturities

The fair values of the Company’s public fixed maturities are generally based on prices obtained from independent valuation service providers and for which the Company maintains a vendor hierarchy by asset type based on historical pricing experience and vendor expertise. Although each security generally is priced by multiple independent valuation service providers, the Company ultimately uses the price received from the independent valuation service provider highest in the vendor hierarchy based on the respective asset type, with limited exception. To validate reasonableness, prices also are internally reviewed by those with relevant expertise through comparison with directly observed recent market trades. Consistent with the fair value hierarchy, public fixed maturities validated in this manner generally are reflected within Level 2, as they are primarily based on observable pricing for similar assets and/or other market observable inputs.

Private Fixed Maturities

The fair values of the Company’s private fixed maturities are determined from prices obtained from independent valuation service providers. Prices not obtained from an independent valuation service provider are determined by using a discounted cash flow model or a market comparable company valuation technique. In certain cases, these models use observable inputs with a discount rate based upon the average of spread surveys collected from private market intermediaries who are active in both primary and secondary transactions, taking into account, among other factors, the credit quality and industry sector of the issuer and the reduced liquidity associated with private placements. Generally, these securities have been reflected within Level 2. For certain private fixed maturities, the discounted cash flow model or a market comparable company valuation technique may also incorporate unobservable inputs, which reflect the Company’s own assumptions about the inputs market participants would use in pricing the asset. To the extent management determines that such unobservable inputs are significant to the fair value measurement of a security, a Level 3 classification generally is made.

26

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

Freestanding Derivative Positions

The net fair value of the Company’s freestanding derivative positions as disclosed in Note 4 of the Notes to these Financial Statements are generally based on prices obtained either from independent valuation service providers or derived by applying market inputs from recognized vendors into industry standard pricing models. The majority of these derivative contracts are traded in the OTC derivative market and are classified in Level 2. The fair values of derivative assets and liabilities traded in the OTC market are determined using quantitative models that require use of the contractual terms of the derivative instruments and multiple market inputs, including interest rates, prices, and indices to generate continuous yield or pricing curves, including overnight index swap curves, and volatility factors, which then are applied to value the positions. The predominance of market inputs is actively quoted and can be validated through external sources or reliably interpolated if less observable.

Level Classifications of the Company’s Financial Instruments

Financial Instruments Classified as Level 1

Investments classified as Level 1 primarily include redeemable preferred stock, trading securities, cash equivalents and Separate Accounts assets. Fair value measurements classified as Level 1 include exchange-traded prices of fixed maturities, equity securities and derivative contracts, and net asset values for transacting subscriptions and redemptions of mutual fund shares held by Separate Accounts. Cash equivalents classified as Level 1 include money market accounts, overnight commercial paper and highly liquid debt instruments purchased with an original maturity of three months or less and are carried at cost as a proxy for fair value measurement due to their short-term nature.

Financial Instruments Classified as Level 2

Investments classified as Level 2 are measured at fair value on a recurring basis and primarily include U.S. government and agency securities and certain corporate debt securities, such as public and private fixed maturities. As market quotes generally are not readily available or accessible for these securities, their fair value measures are determined utilizing relevant information generated by market transactions involving comparable securities and often are based on model pricing techniques that effectively discount prospective cash flows to present value using appropriate sector-adjusted credit spreads commensurate with the security’s duration, also taking into consideration issuer-specific credit quality and liquidity.

Observable inputs generally used to measure the fair value of securities classified as Level 2 include benchmark yields, reported secondary trades, issuer spreads, benchmark securities and other reference data. Additional observable inputs are used when available, and as may be appropriate, for certain security types, such as prepayment, default, and collateral information for the purpose of measuring the fair value of mortgage- and asset-backed securities. The Company’s AAA-rated mortgage- and asset-backed securities are classified as Level 2 for which the observability of market inputs to their pricing models is supported by sufficient, albeit more recently contracted, market activity in these sectors.

Certain Company products, such as IUL and the MSO fund available in some life contracts offer investment options which permit the contract owner to participate in the performance of an index, ETF or commodity price. These investment options, which depending on the product and on the index selected can currently have one, three, five or six year terms, provide for participation in the performance of specified indices, ETF or commodity price movement up to a segment-specific declared maximum rate. Under certain conditions that vary by product, e.g., holding these segments for the full term, these segments also shield policyholders from some or all negative investment performance associated with these indices, ETF or commodity prices. These investment options have defined formulaic liability amounts, and the current values of the option component of these segment reserves are accounted for as Level 2 embedded derivatives. The fair values of these embedded derivatives are based on data obtained from independent valuation service providers.

Financial Instruments Classified as Level 3

The Company’s investments classified as Level 3 primarily include corporate debt securities, such as private fixed maturities and asset-backed securities. Determinations to classify fair value measures within Level 3 of the valuation hierarchy generally are based upon the significance of the unobservable factors to the overall fair value measurement. Included in the Level 3 classification are fixed maturities with indicative pricing obtained from brokers that otherwise could not be corroborated to market observable data.

27

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

The Company has certain variable annuity contracts with GMDB, GMIB, GIB and GWBL and other features in-force that guarantee one of the following:

•Return of Premium: the benefit is the greater of current account value or premiums paid (adjusted for withdrawals);

•Ratchet: the benefit is the greatest of current account value, premiums paid (adjusted for withdrawals), or the highest account value on any anniversary up to contractually specified ages (adjusted for withdrawals);

•Roll-Up: the benefit is the greater of current account value or premiums paid (adjusted for withdrawals) accumulated at contractually specified interest rates up to specified ages;

•Combo: the benefit is the greater of the ratchet benefit or the roll-up benefit, which may include either a five year or an annual reset; or

•Withdrawal: the withdrawal is guaranteed up to a maximum amount per year for life.

The Company also issues certain benefits on its variable annuity products that are accounted for as market risk benefits carried at fair value and are also considered Level 3 for fair value leveling.

The GMIBNLG feature allows the policyholder to receive guaranteed minimum lifetime annuity payments based on predetermined annuity purchase rates applied to the contract’s benefit base if and when the contract account value is depleted and the NLG feature is activated. The optional GMIB feature allows the policyholder to receive guaranteed minimum lifetime annuity payments based on predetermined annuity purchase rates.

The GMWB feature allows the policyholder to withdraw at minimum, over the life of the contract, an amount based on the contract’s benefit base. The GWBL feature allows the policyholder to withdraw, each year for the life of the contract, a specified annual percentage of an amount based on the contract’s benefit base. The GMAB feature increases the contract account value at the end of a specified period to a GMAB base. The GIB feature provides a lifetime annuity based on predetermined annuity purchase rates if and when the contract account value is depleted.

This lifetime annuity is based on predetermined annuity purchase rates applied to a GIB base. The GMDB feature guarantees that the benefit paid upon death will not be less than a guaranteed benefit base. If the contract’s account value is less than the benefit base at the time a death claim is paid, the amount payable will be equal to the benefit base.

Purchased MRB assets, which are accounted for as market risk benefits carried at fair value are also considered Level 3 for fair value leveling. The Purchased MRB asset fair value reflects the present value of reinsurance premiums, net of recoveries, adjusted for risk margins and nonperformance risk over a range of market consistent economic scenarios while the MRB asset and liability reflects the present value of expected future payments (benefits) less fees, adjusted for risk margins and nonperformance risk, attributable to the MRB liability over a range of market-consistent economic scenarios. 

The valuations of the Purchased MRB assets incorporate significant non-observable assumptions related to policyholder behavior, risk margins and projections of equity Separate Accounts funds. The credit risks of the counterparty and of the Company are considered in determining the fair values of its Purchased MRB asset after taking into account the effects of collateral arrangements. Incremental adjustment to the risk free curve for counterparty non-performance risk is made to the fair values of the Purchased MRB assets. Risk margins were applied to the non-capital markets inputs to the Purchased MRB valuations.

The Company also issues certain benefits on its variable annuity products that are accounted for as market risk benefits carried at fair value and are also considered Level 3. See Note 8 of the Notes to Financial Statements for further description of our market risk benefits fair value.

Transfers of Financial Instruments Between Levels 2 and 3

During the three months ended March 31, 2023, there were $10 million AFS fixed maturities transferred out of Level 3 and into Level 2 and no AFS fixed maturities transferred out of Level 2 and into Level 3. These transfers in the aggregate represent approximately 2.7% of total equity as of March 31, 2023.

During the three months ended March 31, 2022, there were no AFS fixed maturities transferred from Level 2 into Level 3 classification and no AFS fixed maturities transferred from Level 3 into Level 2.

28

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

The tables below present reconciliations for Level 3 assets and liabilities and changes in unrealized gains (losses) for the three months ended March 31, 2023 and 2022, respectively. Not included below are the changes in balances related to market risk benefits and purchased market risk level 3 assets and liabilities, which are included in Note 8 of the Notes to these Financial Statements.

Level 3 Instruments - Fair Value Measurements

	Corporate
	(in millions)
Balance, January 1, 2023	$	18
Realized and unrealized gains (losses), included in Net income (loss) as:
Investment gains (losses), reported in net investment income	—
Net derivative gains (losses) (1)	—
Total realized and unrealized gains (losses)	—
Other comprehensive income (loss)	—
Purchases	29
Sales	—
Transfers into Level 3 (1)	—
Transfers out of Level 3 (1)	(10)
Balance, March 31, 2023	$	37
Change in unrealized gains or losses for the period included in earnings for instruments held at the end of the reporting period	$	—
Change in unrealized gains or losses for the period included in other comprehensive income for instruments held at the end of the reporting period.	$	—
Balance, January 1, 2022	$	11
Realized and unrealized gains (losses), included in Net income (loss) as:
Investment gains (losses), reported in net investment income	—
Net derivative gains (losses) (1)	—
Total realized and unrealized gains (losses)	—
Other comprehensive income (loss)	(1)
Purchases	1
Sales	—
Transfers into Level 3 (1)	—
Transfers out of Level 3 (1)	—
Balance, March 31, 2022	$	11
Change in unrealized gains or losses for the period included in earnings for instruments held at the end of the reporting period	$	—
Change in unrealized gains or losses for the period included in other comprehensive income for instruments held at the end of the reporting period	$	(1)

____________

(1)Transfers into/out of the Level 3 classification are reflected at beginning-of-period fair values.

Quantitative and Qualitative Information about Level 3 Fair Value Measurements

The following tables disclose quantitative information about Level 3 fair value measurements by category for assets and liabilities as of March 31, 2023 and December 31, 2022, respectively.

29

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

Quantitative Information about Level 3 Fair Value Measurements as of March 31, 2023

	Fair Value		Valuation Technique	Significant Unobservable Input	Range	Weighted Average
	(in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate	$	7	Matrix pricing  model	Spread over Benchmark	20 bps - 245 bps	147 bps
Purchased MRB asset (1)	11		Discounted cash flow	Lapse rates Withdrawal rates Annuitization rates Non-performance risk (bps) Mortality: Ages 0-40 Ages 41-60 Ages 61-115	N/A	N/A
Direct MRB (1) (2) (3)	3		Discounted cash flow	Non-performance risk (bps) Lapse rates Withdrawal rates Annuitization rates Mortality: Ages 0-40 Ages 41-60 Ages 61-115	191 bps 0.35% - 35.42% 0.20% - 1.24% 0.04% - 100.00% 0.01% - 0.17% 0.06% - 0.52% 0.32% - 40.00%	191 bps 4.08% 1.10% 2.94% 0.96% (same for all ages) (same for all ages)

(1)Lapses and pro-rata withdrawal rates were developed as a function of the policy account value. Dollar for dollar withdrawal rates were developed as a function of the dollar for dollar threshold, the dollar for dollar limit. GMIB utilization rates were developed as a function of the GMIB benefit base.

(2)MRB assets are shown net of MRB liabilities. Net amount is made up of $17 million of MRB assets and $14 million of MRB liabilities.

(3)Includes Core products.

    Quantitative Information about Level 3 Fair Value Measurements as of December 31, 2022

	Fair Value		Valuation Technique	Significant Unobservable Input	Range	Weighted Average
	(in millions)
Assets:
Investments:
Fixed maturities, AFS:
Corporate	$	4	Matrix pricing model	Spread over benchmark	245 bps - 245 bps	245 bps
Purchased MRB asset (1) (2) (4)	13		Discounted cash flow	Lapse rates Withdrawal rates Annuitization Non-performance risk (bps) Mortality: Ages 0-40 Ages 41-60 Ages 61-115	N/A	N/A
Liabilities:
Direct MRB (1) (2) (3) (4)	3		Discounted cash flow	Non-performance risk Lapse rates Withdrawal rates Annuitization rates Mortality: Ages 0-40 Ages 41-60 Ages 61-115	157 bps 0.35% - 35.42% 0.20% - 1.24% 0.04% - 100.00% 0.01% - 0.17% 0.06% - 0.52% 0.32% - 40.00%	157 bps 4.35% 1.22% 3.27% 1.08% (same for all ages) (same for all ages)

(1)Mortality rates vary by age and demographic characteristic such as gender. Mortality rate assumptions are based on a combination of company and industry experience. A mortality improvement assumption is also applied. For any given contract, mortality rates vary throughout the period over which cash flows are projected for purposes of valuating the embedded derivatives.

30

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

(2)Lapses and pro-rata withdrawal rates were developed as a function of the policy account value. Dollar for dollar withdrawal rates were developed as a function of the dollar for dollar threshold, the dollar for dollar limit. GMIB utilization rates were developed as a function of the GMIB benefit base.

(3)MRB liabilities are shown net of MRB assets. Net amount is made up of $15 million of MRB liabilities and $12 million of MRB assets.

(4)Includes Core products.

Level 3 Financial Instruments for which Quantitative Inputs are Not Available

Certain Privately Placed Debt Securities with Limited Trading Activity

Excluded from the tables above as of March 31, 2023 and December 31, 2022, respectively, are approximately $30 million and $14 million of Level 3 fair value measurements of investments for which the underlying quantitative inputs are not developed by the Company and are not readily available. These investments primarily consist of certain privately placed debt securities with limited trading activity, and their fair values generally reflect unadjusted prices obtained from independent valuation service providers and indicative, non-binding quotes obtained from third-party broker-dealers recognized as market participants. Significant increases or decreases in the fair value amounts received from these pricing sources may result in the Company’s reporting significantly higher or lower fair value measurements for these Level 3 investments.

•The fair value of private placement securities is determined by application of a matrix pricing model or a market comparable company value technique. The significant unobservable input to the matrix pricing model valuation technique is the spread over the industry-specific benchmark yield curve. Generally, an increase or decrease in spreads would lead to directionally inverse movement in the fair value measurements of these securities. The significant unobservable input to the market comparable company valuation technique is the discount rate. Generally, a significant increase (decrease) in the discount rate would result in significantly lower (higher) fair value measurements of these securities.

Market Risk Benefits

Significant unobservable inputs with respect to the fair value measurement of the Purchased MRB assets and the MRB liabilities identified in the table above are developed using Company data. Future Policyholder behavior is an unobservable market assumption and as such all aspects of policy holder behavior are derived based on recent historical experience. These policyholder behaviors include lapses, pro-rata withdrawals, dollar for dollar withdrawals, GMIB utilization, deferred mortality and payout phase mortality. Many of these policyholder behaviors have dynamic adjustment factors based on the relative value of the rider as compared to the account value in different economic environments. This applies to all variable annuity related products; products with GMxB riders including but not limited to GMIB, GMDB and GWL.

Lapse rates are adjusted at the contract level based on a comparison of the value of the embedded GMxB rider and the current policyholder account value, which include other factors such as considering surrender charges. Generally, lapse rates are assumed to be lower in periods when a surrender charge applies. A dynamic lapse function reduces the base lapse rate when the guaranteed amount is greater than the account value as in-the-money contracts are less likely to lapse. For valuing Purchased MRB assets and MRB liabilities, lapse rates vary throughout the period over which cash flows are projected.

Carrying Value of Financial Instruments Not Otherwise Disclosed in Note 3 and Note 4 of Notes to Financial Statements

The carrying values and fair values as of March 31, 2023 and December 31, 2022 for financial instruments not otherwise disclosed in Note 3 and Note 4 of the Notes to these Financial Statements are presented in the table below.

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EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

Carrying Values and Fair Values for Financial Instruments Not Otherwise Disclosed

	Carrying Value		Fair Value
			Level 1		Level 2		Level 3		Total
	(in millions)
March 31, 2023:
Mortgage loans on real estate	$	17	$	—	$	—	$	15	$	15
Policy loans	$	250	$	—	$	—	$	259	$	259
Policyholders’ liabilities: Investment contracts	$	112	$	—	$	—	$	104	$	104
December 31, 2022:
Mortgage loans on real estate	$	17	$	—	$	—	$	15	$	15
Policy loans	$	244	$	—	$	—	$	248	$	248
Policyholders’ liabilities: Investment contracts	$	115	$	—	$	—	$	106	$	106

Mortgage Loans on Real Estate

Fair values for commercial mortgage loans on real estate are measured by discounting future contractual cash flows to be received on the mortgage loan using interest rates at which loans with similar characteristics and credit quality would be made. The discount rate is derived based on the appropriate U.S. Treasury rate with a like term to the remaining term of the loan to which a spread reflective of the risk premium associated with the specific loan is added. Fair values for mortgage loans anticipated to be foreclosed and problem mortgage loans are limited to the fair value of the underlying collateral, if lower.

Policy Loans

The fair value of policy loans is calculated by discounting expected cash flows based upon the U.S. Treasury yield curve and historical loan repayment patterns.

Policyholder Liabilities - Investment Contracts

The fair values for deferred annuities and certain annuities, which are included in policyholders’ account balances and liabilities for investment contracts are estimated using projected cash flows discounted at rates reflecting current market rates. Significant unobservable inputs reflected in the cash flows include lapse rates and withdrawal rates. Incremental adjustments may be made to the fair value to reflect non-performance risk. Certain other products such as the Company’s association plans contracts, supplementary contracts not involving life contingencies, Access Accounts and Escrow Shield Plus product reserves are held at book value.

Financial Instruments Exempt from Fair Value Disclosure or Otherwise Not Required to be Disclosed

Exempt from Fair Value Disclosure Requirements

Certain financial instruments are exempt from the requirements for fair value disclosure, such as insurance liabilities other than financial guarantees.

7)    LIABILITIES FOR FUTURE POLICYHOLDER BENEFITS

The following table provides the balance, changes in and the weighted average durations of the additional insurance liabilities for the three months ended March 31, 2023 and 2022.

32

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

	March 31, 2023		March 31, 2022
	Universal Life		Universal Life
	(Dollars in millions)
Balance, beginning of the period	$	58	$	57
Beginning balance before AOCI adjustments	66		55
Effect of changes in interest rate and cash flow assumptions and model changes	—		—
Effect of actual variances from expected experience	(1)		(1)
Adjusted beginning of period balance	65		54
Interest accrual	1		1
Net assessments collected	2		2
Benefit payments	—		—
Ending balance before shadow reserve adjustments	68		57
Effect of shadow reserve adjustment	(6)		(2)
Balance, end of the period	$	62	$	55
Net liability for additional liability	$	62	$	55
Effect of reserve adjustment recorded in AOCI	—		—
Net liability for additional liability, after reinsurance recoverable	$	62	$	55
			—
Weighted-average duration of additional liability - death benefit (years)	32.3		33.9

The following tables provides the revenue, interest and weighted average interest rates, related to the additional insurance liabilities for the three months ended and as of March 31, 2023 and 2022.

	Three Months Ended March 31,
	2023		2022		2023		2022
	Assessments				Interest Accretion
	(in million)
Revenue and Interest Accretion
Universal Life	$	5	$	4	$	—	$	1
Total	$	5	$	4	$	—	$	1

	March 31,
	2023		2022
Weighted Average Interest Rate
Universal Life	5.5	%	5.5	%
Interest accretion rate	5.5	%	5.5	%

The following table reconciles the net liability for future policy benefits and liability of death benefits to the liability for future policy benefits in the balance sheet as of March 31, 2023 and December 31, 2022.

	March 31, 2023		December 31, 2022
	(in millions)
Reconciliation
Universal Life - additional liability for death benefits	$	62	$	58
Other (1)	230		220
Future policyholder benefits total	292		278
Other policyholder liabilities	415		391
Total	$	707	$	669

______________

(1)Primarily reflects Future policy benefits related to Protective Life and Employee Benefits.

33

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

8)    MARKET RISK BENEFITS

The following table presents the balances and changes to the balances for the market risk benefits for the GMxB benefits on deferred variable annuities for the three months ended and as of March 31, 2023 and 2022.

	March 31, 2023		March 31, 2022
	GMxB Core		GMxB Core
	(Dollars in millions)
Balance, beginning of the period (“BOP”)	$	(9)	$	—
Balance BOP before changes in the instrument specific credit risk	(8)		1
Model changes and effect of changes in cash flow assumptions	—		—
Actual market movement effect	(5)		4
Interest accrual	—		—
Attributed fees accrued (1)	1		—
Benefit payments	—		—
Actual policyholder behavior different from expected behavior	2		1
Changes in future economic assumptions	2		(7)
Issuances	—		(1)
Balance EOP before changes in the instrument-specific credit risk	(8)		(2)
Changes in the instrument-specific credit risk (2)	(6)		(5)
Balance, end of the period (“EOP”)	$	(14)	$	(7)
Weighted-average age of policyholders (years)	61.3		59.5
Net amount at risk	$	9	$	2

(1) Attributed fees accrued represents the portion of the fees needed to fund future GMxB claims.

(2) Changes are recorded in OCI.

(3) Purchased MRB is the impact of non-affiliated reinsurance.

The following table reconciles market risk benefits by the amounts in an asset position and amounts in a liability position to the market risk amounts in the balance sheet as of March 31, 2023 and December 31, 2022.

	March 31, 2023										December 31, 2022
	Direct Asset		Direct Liability		Net Direct MRB		Purchased MRB		Total		Direct Asset		Direct Liability		Net Direct MRB		Purchased MRB		Total
	(in millions)
GMxB Core	(17)		3		(14)		—		(14)		(12)		3		(9)		—		(9)
Other (1)	—		11		11		(11)		—		—		12		12		(13)		(1)
Total	$	(17)	$	14	$	(3)	$	(11)	$	(14)	$	(12)	$	15	$	3	$	(13)	$	(10)

______________

(1)    Other primarily reflects Protective Life not reflected within the MRB roll-forward table.

34

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

9)    POLICYHOLDER ACCOUNT BALANCES    

The following table summarizes the balances and changes in policyholders’ account balances three months ended and as of March 31, 2023 and 2022:

	Indexed Universal Life		Variable Universal Life		GMxB Core		Investment Edge		SCS (2)		Reinsured (1)
March 31, 2023	(Dollars in millions)
Balance, beginning of the period	$	1,962	$	655	$	27	$	7	242		$	819
Issuances	—		—		—		—		—		—
Premiums received	58		5		29		—		—		6
Policy charges	(44)		(9)		(2)		—		—		(9)
Surrenders and withdrawals	(7)		—		—		—		(1)		(23)
Benefit payments	(3)		(2)		—		—		—		(2)
Net transfers from (to) separate account	—		11		(26)		77		1,031		—
Interest credited (3)	30		9		—		1		24		8
Other	—		—		—		—		—		1
Balance, end of the period	$	1,996	$	669	$	28	$	85	$	1,296	$	800
Weighted-average crediting rate	2.23%		3.52%		1.00%		1.00%		1.00%		4.12%
Net amount at risk (4)	$	18,004	$	30,589	$	9	$	—	$	—	$	4,011
Cash surrender value	$	1,505	$	535	$	32	$	81	$	1,208	$	799

______________

(1)Reinsured primarily reflects Protective Life reinsured business.

(2)SCS sales are recorded in a Separate Account holding account until they are swept into the General Account. This sweep is recorded as Net Transfers from (to) separate account.

(3)SCS includes amounts related to the change in embedded derivative.

(4)For life insurance products the net amount at risk is death benefit less account value for the policyholder. For variable annuity products the net amount risk is the maximum GMxB NAR for the policyholder.

	Indexed Universal Life			Variable Universal Life			GMxB Core			Investment Edge			SCS (2)			Reinsured (1)
March 31, 2022	(Dollars in millions)
Balance, beginning of period	$	1,973		$	614		$	13		$	—		$	—		$	867
Issuances	—			—			—			—			—			—
Premiums received	66			4			4			—			—			8
Policy charges	(44)			(2)			(1)			—			—			(8)
Surrenders and withdrawals	(6)			—			—			—			—			(22)
Benefit payments	(3)			(1)			—			—			—			(1)
Net transfers from (to) separate account	—			9			—			—			—			2
Interest credited (3)	2			5			—			—			—			9
Other	—			—			—			—			—			—
Balance, end of the period	$	1,988		$	629		$	16		$	—					$	855
Weighted-average crediting rate	2.19		%	3.53		%	1.00		%	—		%	—		%	4.31		%
Net amount at risk (4)	$	18,296		$	27,994		$	2		$	—		$	—		$	4,279
Cash surrender value	$	1,452		$	511		$	18		$	—		$	—		$	855

______________

(1)Reinsured primarily reflects Protective Life reinsured business.

(2)SCS sales are recorded in a Separate Account holding account until they are swept into the General Account. This sweep is recorded as Net Transfers from (to) separate account.

(3)SCS includes amounts related to the change in embedded derivative.

35

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

(4)For life insurance products the net amount at risk is death benefit less account value for the policyholder. For variable annuity products the net amount risk is the maximum GMxB NAR for the policyholder.

The following table reconciles the policyholders account balances to the policyholders’ account balance liability in the balance sheet as of March 31, 2023 and December 31, 2022.

	March 31, 2023		December 31, 2022
	(in millions)
Policyholders’ account balance reconciliation
IUL	$	1,996	$	1,962
VUL	669		655
GMxB Core	28		27
Investment Edge	85		7
SCS	1,296		242
Reinsured	800		819
Other	36		39
Total	$	4,910	$	3,751

The following table presents the account values by range of guaranteed minimum crediting rates and the related range of the difference in basis points, between rates being credited policyholders and the respective guaranteed minimums as of March 31, 2023 and December 31, 2022.

March 31, 2023
Product (1)	Range of Guaranteed Minimum Crediting Rate	At Guaranteed Minimum		1 Basis Point - 50 Basis Points Above		51 Basis Points - 150 Basis Points Above		Greater Than 150 Basis Points Above		Total
		(in millions)
Indexed Universal Life	0.00% - 1.50%	$	—	$	—	$	—	$	—	$	—
	1.51% - 2.50%	1,166		611		172		—		1,949
	Greater than 2.50%	—		—		—		—		—
	Total	$	1,166	$	611	$	172	$	—	$	1,949
Variable Universal Life	0.00% - 1.50%	$	15	$	36	$	5	$	—	$	56
	1.51% - 2.50%	59		27		—		—		86
	Greater than 2.50%	462		—		2		—		464
	Total	$	536	$	63	$	7	$	—	$	606
Investment Edge	0.00% - 1.50%	$	84	$	—	$	—	$	—	$	84
	1.51% - 2.50%									—
	Greater than 2.50%									—
	Total	$	84	$	—	$	—	$	—	$	84
GMxB Core	0.00% - 1.50%	$	35	$	—	$	—	$	—	$	35
	1.51% - 2.50%	—		—		—		—		—
	Greater than 2.50%	—		—		—		—		—
	Total	$	35	$	—	$	—	$	—	$	35

36

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

December 31, 2022
Product	Range of Guaranteed Minimum Crediting Rate	At Guaranteed Minimum		1 Basis Point-50 Basis Points Above		51 Basis Points-150 Basis Points Above		Greater Than 150 Basis Points Above		Total
		(in millions)
Indexed Universal Life	0.00% - 1.50%	$	—	$	—	$	—	$	—	$	—
	1.51% - 2.50%	1,202		666		73		—		1,941
	Greater than 2.50%	—		—		—		—		—
	Total	$	1,202	$	666	$	73	$	—	$	1,941
Variable Universal Life	0.00% - 1.50%	$	18	$	30	$	2	$	—	$	50
	1.51% - 2.50%	73		12		—		—		85
	Greater than 2.50%	460		—		2		—		462
	Total	$	551	$	42	$	4	$	—	$	597
Investment Edge	0.00% - 1.50%	$	7	$	—	$	—	$	—	$	7
	1.51% - 2.50%	—		—		—		—		—
	Greater than 2.50%	—		—		—		—		—
	Total	$	7	$	—	$	—	$	—	$	7
GMxB Core	0.00% - 1.50%	$	32	$	—	$	—	$	—	$	32
	1.51% - 2.50%	—		—		—		—		—
	Greater than 0.025	—		—		—		—		—
	Total	$	32	$	—	$	—	$	—	$	32

Separate Account - Summary

The following table presents the balances of and changes in separate account liabilities three months ended and as of March 31, 2023 and 2022.

	VUL		GMxB Core		Investment Edge		Reinsured (1)
March 31, 2023	(in millions)
Balance, beginning of the period	$	1,653	$	756	$	26	$	913
Premiums and deposits	96		139		138		5
Policy charges	(32)		(2)		—		(8)
Surrenders and withdrawals	(10)		(5)		—		(14)
Benefit payments	(2)		(2)		—		(4)
Investment performance (2)	98		38		1		74
Net transfers from (to) general account	(11)		26		(77)		—
Balance, end of the period	$	1,792	$	950	$	88	$	966
Cash surrender value	$	1,468	$	874	$	84	N/A

_______________

(1) Reinsured primarily reflects Protective Life reinsured ceded business.

(2) Investment performance is reflected net of M&E fees.

37

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

	VUL		GMxB Core		Investment Edge		Reinsured (1)
March 31, 2022	(in millions)
Balance, beginning of the period	$	1,832	$	315	$	—	$	1,244
Premiums and deposits	92		109		—		6
Policy charges	(34)		—		—		(9)
Surrenders and withdrawals	(8)		(2)		—		(14)
Benefit payments	(1)		—		—		(5)
Net transfers from (to) general account	(109)		—		—		(2)
Investment Performance (2)	(12)		(21)		—		(92)
Balance, end of the period	$	1,760	$	401	$	—	$	1,128
Cash surrender value	$	1,452	$	370	$	—	N/A

______________

(1) Reinsured primarily reflects Protective Life reinsured ceded business.

(2) Investment performance is reflected net of M&E fees.

The following table reconciles the separate account liabilities to the separate account liability balance in the balance sheet as of March 31, 2023 and December 31, 2022.

	March 31, 2023		December 31, 2022
	(in millions)
Separate Account Reconciliation
VUL	$	1,792	$	1,653
GMxB Core	950		756
Investment Edge	88		26
Reinsured	966		913
Other	71		26
Total	$	3,867	$	3,374

The following table presents the aggregate fair value of separate account assets by major asset category as of March 31, 2023 and December 31, 2022.

	March 31, 2023
	Life Insurance & Employee Benefits Products		Individual Variable Annuity Products		Employer - Sponsored Products		Other		Total
	(in millions)
Asset Type
Mutual Funds	$	2,268	$	1,586	$	—	$	13	$	3,867
Total	$	2,268	$	1,586	$	—	$	13	$	3,867

38

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

	December 31, 2022
	Life Insurance & Employee Benefits Products		Individual Variable Annuity Products		Employer - Sponsored Products		Other		Total
	(in millions)
Asset Type
Mutual Funds	$	2,096	$	1,265	$	—	$	13	$	3,374
Total	$	2,096	$	1,265	$	—	$	13	$	3,374

10)    INCOME TAXES

Income tax expense for the three months ended March 31, 2023 and 2022 was computed using an estimated annual effective tax rate (“ETR”), with discrete items recognized in the period in which they occur. The estimated ETR is revised, as necessary, at the end of successive interim reporting periods.

During the fourth quarter of 2022, the Company established a valuation allowance of $85 million against its deferred tax assets related to unrealized capital losses in the available for sale securities portfolio. For the three-months ended March 31, 2023, the Company recorded a decrease to the valuation allowance of $16 million due to a decrease in the portfolio’s unrealized capital loss. This adjustment was allocated to other comprehensive income.

As of each reporting date, management considers new evidence, both positive and negative, that could affect its view of the future realization of deferred tax assets. The Company has reassessed its ability to increase its available future liquidity by increasing borrowing capacity and amending certain counterparty agreements. As a result of these actions, the Company now has the ability and intent to hold the underlying securities in its available for sale portfolio to recovery. Based on all available evidence, as of March 31, 2023, the Company concluded the deferred tax assets related to unrealized tax capital losses are more-likely-than-not to be realized and that a valuation allowance is not necessary. The remaining release of the valuation allowance of $69 million was recorded in net income.

The Company uses the aggregate portfolio approach related to the stranded or disproportionate income tax effects in accumulated other comprehensive income related to available for sale securities. Under this approach, the disproportionate tax effect remains intact as long as the investment portfolio remains.

11)    RELATED PARTY TRANSACTIONS

The Company did not enter into any new significant transactions with related parties during the first quarter 2023.

12)    EQUITY

AOCI represents cumulative gains (losses) on items that are not reflected in net income (loss). The balances as of March 31, 2023 and December 31, 2022 is as follows:

	March 31, 2023		December 31, 2022
	(in millions)
Unrealized gains (losses) on investments	$	(309)	$	(383)
Market risk benefits - instrument-specific credit risk component	7		1
Accumulated other comprehensive income (loss)	$	(302)	$	(382)

The components of OCI, net of taxes for the three months ended March 31, 2023 and 2022, follow:

39

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

	Three Months Ended March 31,
	2023		2022
	(in millions)
Change in net unrealized gains (losses) on investments:
Net unrealized gains (losses) arising during the period	$	72	$	(176)
(Gains) losses reclassified into net income (loss) during the period (1)	4		1
Net unrealized gains (losses) on investments	76		(175)
Adjustments for policyholders’ liabilities, DAC, insurance liability loss recognition and other	(1)		4
Change in unrealized gains (losses), net of adjustments (net of deferred income tax expense (benefit) of $16 and $(45).	75		(171)
Change in LFPB discount rate and MRB credit risk
Changes in instrument-specific credit risk - market risk benefits (net of deferred income tax expense (benefit) of $1 and $1.	5		5
Changes in current discount rate - liability for future policy benefits (net of deferred income tax expense (benefit) of $0 and $0.	—		—
Other comprehensive income (loss)	$	80	$	(166)

____________

(1)See “Reclassification adjustment” in Note 3 of the Notes to these Financial Statements. Reclassification amounts presented net of income tax expense (benefit) of $1 million and $0 million for the three months ended March 31, 2023 and 2022, respectively.

Investment gains and losses reclassified from AOCI to net income (loss) primarily consist of realized gains (losses) on sales and credit losses of AFS securities and are included in total investment gains (losses), net on the statements of income (loss). Amounts presented in the table above are net of tax.

13)    COMMITMENTS AND CONTINGENT LIABILITIES

Litigation

Litigation, regulatory and other loss contingencies arise in the ordinary course of the Company’s activities. The Company is a defendant in litigation matters arising from the conduct of its business. In some of these matters, claimants seek to recover very large or indeterminate amounts, including compensatory, punitive, treble and exemplary damages. Modern pleading practice permits considerable variation in the assertion of monetary damages and other relief. Claimants are not always required to specify the monetary damages they seek, or they may be required only to state an amount sufficient to meet a court’s jurisdictional requirements. Moreover, some jurisdictions allow claimants to allege monetary damages that far exceed any reasonably possible verdict. The variability in pleading requirements and past experience demonstrates that the monetary and other relief that may be requested in a lawsuit or claim often bears little relevance to the merits or potential value of a claim.

The outcome of a litigation or regulatory matter is difficult to predict, and the amount or range of potential losses associated with these or other loss contingencies requires significant management judgment. It is not possible to predict the ultimate outcome or to provide reasonably possible losses or ranges of losses for all pending regulatory matters, litigation and other loss contingencies. While it is possible that an adverse outcome in certain cases could have a material adverse effect upon the Company’s financial position, based on information currently known, management believes that neither the outcome of pending litigation and regulatory matters, nor potential liabilities associated with other loss contingencies, are likely to have such an effect. However, given the large and indeterminate amounts sought in certain litigation and the inherent unpredictability of all such matters, it is possible that an adverse outcome in certain of the Company’s litigation or regulatory matters, or liabilities arising from other loss contingencies, could, from time to time, have a material adverse effect upon the Company’s results of operations or cash flows in a particular quarterly or annual period.

For some matters, the Company is able to estimate a range of loss. For such matters in which a loss is probable, an accrual has been made. For matters where the Company believes a loss is reasonably possible, but not probable, no accrual is required. For matters for which an accrual has been made, but there remains a reasonably possible range of loss in excess of the amounts accrued or for matters where no accrual is required, the Company develops an estimate of the unaccrued amounts of the reasonably possible range of losses. As of March 31, 2023, the Company estimates the aggregate range of reasonably possible losses, in excess of any amounts accrued for these matters as of such date, to be up to approximately $5 million.

40

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

For other matters, the Company is currently not able to estimate the reasonably possible loss or range of loss. The Company is often unable to estimate the possible loss or range of loss until developments in such matters have provided sufficient information to support an assessment of the range of possible loss, such as quantification of a damage demand from plaintiffs, discovery from plaintiffs and other parties, investigation of factual allegations, rulings by a court on motions or appeals, analysis by experts and the progress of settlement discussions. On a quarterly and annual basis, the Company reviews relevant information with respect to litigation and regulatory contingencies and updates the Company’s accruals, disclosures and reasonably possible losses or ranges of loss based on such reviews.

Guarantees and Other Commitments

The Company has no outstanding commitments under existing mortgage loans or mortgage loan commitment agreements at March 31, 2023.

14)    UNPAID CLAIM AND CLAIM EXPENSES

The liability for unpaid claims and claim expenses as of March 31, 2023 and 2022 is as follows:

Liability for Unpaid Claims and Claim Expenses

	2023		2022
	(in millions)
Gross Balance at January 1,	$	110	$	78
Less Reinsurance	36		23
Net Balance at January 1,	74		55
Incurred Claims (net) Related to:
Current Period	67		40
Prior Period	(16)		(1)
Total Incurred	51		39
Paid Claims (net) Related to:
Current Period	23		15
Prior Period	26		20
Total Paid	49		35
Net Balance at March 31,	76		59
Add Reinsurance	38		25
Gross Balance at March 31,	$	114	$	84

15)    REVISION OF PREVIOUSLY ISSUED FINANCIAL STATEMENTS

During the quarter ended September 30, 2022, the Company identified errors primarily related to the calculation of the deferred cost of reinsurance amortization. Specifically, the deferred cost of reinsurance as reflected on the balance sheet was overstated and operating expenses (deferred cost amortization) was understated commencing in the quarter ended December 31, 2019 with a cumulative impact of $14 million pre-tax. In accordance with SAB No. 108, management evaluated the impact of this error and concluded that previously issued financial statements were not materially misstated; however, the cumulative impact would be material to the quarter ended September 30, 2022 and annual period ending December 31, 2022 and accordingly, determined to revise previously reported financial statements for years ended December 31, 2021, 2020 and 2019 and for the three-month periods ended March 31, 2022 and 2021 and June 30, 2022 and 2021 and for the six-months periods ended June 30, 2022 and June 2021. As a result of the determination to revise previously issued financial statements for the amortization matter discussed above, management also has corrected other previously identified but uncorrected errors and errors recorded in incorrect periods including, (a) balance sheet gross up errors resulting from incorrectly calculating reserves relating to business which has been 100% ceded to reinsurers resulting in corrections to Future policy benefits and other policyholders’ liabilities and Amounts due from reinsurers; (b) the classification of a preferred stock investment of $25 million from

41

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

available for sale debt securities to equity securities and present previously recorded unrealized losses as net investment income (loss) rather than as a component of other comprehensive income in the amount of $2 million; and, (c) other immaterial errors.

The following tables present line items for prior period impacted financial statements that have been affected by the errors discussed above as well as the impact of the adoption of ASU 2018-12:

	Three Months Ended March 31, 2022
	As Previously Reported		ASU 2018-12 Impact		As Adjusted		Impact of Revisions		As Revised
	(in millions)
Statements of Income (Loss):
Other operating costs and expenses	$	21	$	1	$	22	$	1	$	23
Total benefits and deductions	161		(15)		146		1		147
Income (loss) from continuing operations, before income taxes	(22)		(3)		(25)		(1)		(26)
Net income (loss) from continuing operations	(19)		—		(19)		(1)		(20)
Net income (loss)	$	(19)	$	—	$	(19)	$	(1)	$	(20)

	Three Months Ended March 31, 2022
	As Previously Reported		ASU 2018-12 Impact		As Adjusted		Impact of Revisions		As Revised
	(in millions)
Statements of Comprehensive Income (Loss):
Net income (loss)	$	(19)	$	—	$	(19)	$	(1)	$	(20)
Comprehensive income (loss)	$	(169)	$	(16)	$	(185)	$	(1)	$	(186)

	Three Months Ended March 31, 2022
Statements of Equity:	As Previously Reported			ASU 2018-12 Impact			As Adjusted			Impact of Revision			As Revised
	(in millions)
Additional paid-in capital, beginning of year	$	679		$	—		$	679		$	1		$	680
Additional paid-in capital, end of period	680		—	—		—	680		—	1		—	681
Accumulated Deficit, beginning of year	(60)			(64)			(124)			(10)			(134)
Net income (loss)	(19)			—			(19)			(1)			(20)
Accumulated Deficit, end of period	(79)		—	(64)		—	(143)			(11)			(154)
Total equity, end of period	$	540		$	(68)		$	472		$	(10)		$	462

42

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

Notes to Financial Statements (Unaudited), Continued

	Three Months March 31, 2022
	As Reported		ASU 2018-12 Impact		As Adjusted		Impact of Revision		As Revised
	(in millions)
Statement of Cash Flows:
Cash flow from operating activities:
Net income (loss)	$	(19)	$	—	$	(19)	$	(1)	$	(20)
Future policy benefits	(4)		—		(4)		13		9
Reinsurance recoverable	14		—		14		(13)		1
Other, net	73		—		73		1		74

16)    SUBSEQUENT EVENTS

Funding Agreement-Backed Commercial Paper Program

In May 2023, Equitable America established a funding agreement-backed commercial paper program (the “FABCP Program”), pursuant to which a special purpose limited liability company (the “SPLLC”) may issue commercial paper and deposit the proceeds with Equitable America pursuant to a funding agreement issued by Equitable America to the SPLLC. The current maximum aggregate principal amount permitted to be outstanding at any one time under the FABCP Program is $1.0 billion.

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Item 2.    Management’s Discussion and Analysis of Financial Condition and Results of Operations

Management’s discussion and analysis of financial condition and results of operations is presented pursuant to General Instruction (H)(2)(a) of Form 10-Q. The management’s narrative that follows should be read in conjunction with the financial statements and the related Notes to Financial Statements included elsewhere herein, with the information provided under “Note Regarding Forward-looking Statements and Information” included elsewhere herein and Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”) in Part II, Item 7 and “Risk Factors” in Part I, Item 1A included in Equitable America’s Annual Report on Form 10-K for the year ended December 31, 2022 (“2022 Form 10-K”). The management’s narrative that follows represents a discussion and analysis of Equitable America’s financial condition and results of operations and not the financial condition and results of operations of Equitable Holdings, Inc. (“Holdings”).

Executive Summary

Overview

We are an indirect, wholly-owned subsidiary of Holdings. Our primary business is to provide life insurance, annuity, and employee benefit products to individuals and small and medium-sized businesses. We are licensed to sell our products in 49 states (not including New York), the District of Columbia and Puerto Rico.

Long - Duration Targeted Improvements (“LDTI”) Adoption

Effective January 1, 2023, the Company adopted ASU 2018-12 and elected a transition date of January 1, 2021, thereby permitting the Company to implement the standard only for the last two fiscal years rather than the customary last three fiscal years.

The Company adopted ASU 2018-12 for liability for future policy benefits, additional insurance liabilities, DAC and balances amortized on a basis consistent with DAC on a modified retrospective basis. ASU 2018-12 was adopted for MRBs on a full retrospective basis. See Note 2 of the Notes to the Financial Statements for further information on the adoption of LDTI.

Macroeconomic and Industry Trends

Our business and results of operations are significantly affected by economic conditions and consumer confidence, conditions in the global capital markets and the interest rate environment.

Financial and Economic Environment

A wide variety of factors continue to impact financial and economic conditions. These factors include, among others, increased volatility in the capital markets, equity market declines, rising interest rates, inflationary pressures fueling concerns of a potential recession, plateauing or decreasing economic growth, high fuel and energy costs, changes in fiscal or monetary policy and geopolitical tensions. Market volatility, particularly during March 2023, was driven by instability in the banking sector following continued interest rate increases by the U.S. Federal Reserve in 2022 and 2023, as a run on some mid-size U.S. banks resulted in regulatory intervention, including the guarantee of all deposits by the FDIC. The ongoing military conflict between the Ukraine and Russia and the sanctions and other measures imposed in response to this conflict also continue to contribute to geopolitical tensions and market volatility.

Stressed conditions, volatility and disruptions in the capital markets, particular markets, or financial asset classes can have an adverse effect on us, in part because we have a large investment portfolio. In addition, our insurance liabilities and derivatives are sensitive to changing market factors, including equity market performance and interest rates. During the third quarter 2022, equity markets continued their decline, while interest rates continued to rise, and are anticipated to continue to rise throughout the year based on statements of members of the Board of Governors of the Federal Reserve System. An increase in market volatility could continue to affect our business, including through effects on the yields we earn on invested assets, changes in required reserves and capital and fluctuations in the value of our AUM and AV, from which we derive our fee income. These effects could be exacerbated by uncertainty about future fiscal policy, changes in tax policy, the scope of potential deregulation and levels of global trade.

The potential for increased volatility, coupled with prevailing interest rates remaining below historical averages despite recent increases could pressure sales and reduce demand for our products as consumers consider purchasing alternative products to meet their objectives. In addition, this environment could make it difficult to consistently develop products that are attractive to customers. Financial performance can be adversely affected by market volatility and equity market declines as fees driven by AV and AUM fluctuate, hedging costs increase and revenues decline due to reduced sales and increased outflows

44

We monitor the behavior of our customers and other factors, including mortality rates, morbidity rates, annuitization rates and lapse and surrender rates, which change in response to changes in capital market conditions, to ensure that our products and solutions remain attractive and profitable. For additional information on our sensitivity to interest rates and capital market prices, see “Quantitative and Qualitative Disclosures About Market Risk.”

Regulatory Developments

We are regulated primarily by the Arizona Department of Insurance and Financial Institutions, with some policies and products also subject to federal regulation. On an ongoing basis, regulators refine capital requirements and introduce new reserving standards. Regulations recently adopted or currently under review can potentially impact our statutory reserve and capital requirements.

The NAIC is evaluating the appropriate accounting treatment of an insurer’s negative interest maintenance reserve (“IMR”) balance, since a rising interest rate environment may cause an insurer’s IMR balance to become negative as a result of bond sales executed at a capital loss. If this occurs, current statutory accounting guidance requires the non-admittance of negative IMR, which can impact an insurer’s surplus and financial strength reflected in its financial statements and result in lower reported surplus and RBC ratios. The NAIC has exposed new statutory accounting guidance that would permit an insurer with an RBC greater than 300% to admit negative IMR up to 5% of its general account capital and surplus, subject to certain restrictions and reporting obligations. Comments on the proposal are due in June 2023. The NAIC is focused on identifying an interim solution for year-end 023 statutory reporting, although it also intends to develop a long-term solution even if interest rates change. The Company currently has $11 million of negative IMR and would be able to admit such negative IMR subject to the restrictions required by the NAIC.

The NAIC is also evaluating the risks associated with insurers’ investments in certain categories of structured securities, including CLOs. In March 2023, the NAIC adopted an amendment to the Purposes and Procedures Manual to give the NAIC’s Structured Securities Group, housed within the SVO, responsibility for modeling CLO securities and evaluating tranche level losses across all debt and equity tranches under a series of calibrated and weighted collateral stress scenarios in order to assign NAIC designations. Under the amended Purposes and Procedures Manual, which will become effective no earlier than year-end 2024 financial reporting, CLO investments will no longer be broadly exempt from filing with the SVO based on ratings from Credit Rating Providers. The NAIC’s goal is to ensure that the weighted average RBC factor for owning all tranches of a CLO more closely aligns with what would be required for directly owning all of the underlying loan collateral, in order to avoid RBC arbitrage. The NAIC is collaborating with interested parties to develop and refine the process for modeling CLO investments.

The NAIC has also proposed an interim change to their RBC requirement for equity tranches of all securitizations, including CLOs. If adopted, this would increase the capital charge for these equity tranches from 30% to 45%. This proposal remains subject to comment from regulators, insurance companies, and other interested parties and thus may still be revised or delayed. An interim charge will likely have to be approved by June 30 for it to be effective for year-end 2023 statutory filings. The interim charge is intended to remain in effect until the NAIC finalizes and adopts its modeling framework for CLOs which is not expected to be completed until at least year-end 2024.

In March 2023, the Securities and Exchange Commission (SEC) reopened the comment period for the Investment Management Cybersecurity Release proposing new rules under the Investment Advisers Act of 1940 and the Investment Company Act of 1940 that would require registered investment advisers and investment companies to adopt and implement written cybersecurity policies and procedures reasonably designed to: (1) address cybersecurity risk management, (2) disclose information about cybersecurity risks and incidents, (3) report information confidentially to the SEC about certain cybersecurity incidents, and (4) maintain related records.

In addition, in March 2023, the SEC proposed rule amendments that would require brokers and dealers, investment companies, and investment advisers registered with the SEC to adopt written policies and procedures for incident response programs to address unauthorized access to or use of customer information, including procedures for providing timely notification to individuals affected by an incident involving sensitive customer information with details about the incident and information designed to help affected individuals respond appropriately. The proposal also would broaden the scope of information covered by amending requirements for safeguarding customer records and information, and for properly disposing of consumer report information, as well as impose requirements to maintain written records documenting compliance with the proposed amended rules. Finally, the proposed amendments would conform annual privacy notice delivery provisions to the terms of an exception provided by a statutory amendment to the Gramm-Leach-Bliley Act.

45

Finally, in March 2023, the SEC proposed a new rule and form and amendments to existing recordkeeping rules to require broker-dealers, clearing agencies, major security-based swap participants, the Municipal Securities Rulemaking Board, national securities associations, national securities exchanges, security-based swap data repositories, security-based swap dealers, and transfer agents to address cybersecurity risks through: (1) policies and procedures, (2) immediate notification to the SEC of the occurrence of a significant cybersecurity incident, (3) as applicable, reporting detailed information to the SEC about a significant cybersecurity incident, and (4) public disclosures with respect to cybersecurity risks and significant cybersecurity incidents.

The public comment period for this proposed rule will end in May 2023. We cannot predict what form the final new or amended rules may take, or what affect such developments in the law may have on our business or compliance costs. For additional information on the regulatory developments, see “Business—Regulation” and “Risk Factors—Legal and Regulatory Risks” in the 2022 Form 10-K.

Revenues

Our revenues come from three principal sources:

•fee income derived from our products

•premiums from our traditional life insurance, annuity, and employee benefits products; and

•investment income from our General Account investment portfolio.

Our fee income varies directly in relation to the amount of the underlying AV or benefit base of our life insurance and annuity products which are influenced by changes in economic conditions, primarily equity market returns, as well as net flows. Our premium income is driven by the growth in new policies written and covered lives, and the persistency of our in-force policies, which are influenced by a combination of factors, including our efforts to attract and retain customers and market conditions that influence demand for our products. Our investment income is driven by the yield on our General Account investment portfolio and is impacted by the prevailing level of interest rates as we reinvest cash associated with maturing investments and net flows to the portfolio.

Benefits and Other Deductions

Our primary expenses are:

•policyholders’ benefits and interest credited to policyholders’ account balances;

•sales commissions and compensation paid to intermediaries and advisors that distribute our products and services; and

•compensation and benefits provided to Equitable Financial’s employees and other operating expenses.

Policyholders’ benefits are driven primarily by mortality, morbidity, customer withdrawals and benefits which change in response to changes in capital market conditions. In addition, some of our policyholders’ benefits are directly tied to the AV and benefit base of our variable annuity products. Interest credited to policyholders varies in relation to the amount of the underlying AV or benefit base. Sales commissions and compensation paid to intermediaries and advisors vary in relation to premium and fee income generated from these sources, whereas compensation and benefits to Equitable Financial’s employees are more constant and impacted by market wages and decline with increases in efficiency. Our ability to manage these expenses across various economic cycles and products is critical to the profitability of our company.

Significant Factors Impacting Our Results

The following significant factors have impacted, and may in the future impact, our financial condition, results of operations or cash flows.

Impact of Hedging on Results

We have offered and continue to offer variable annuity and life insurance products. The future claims exposure on these features is sensitive to movements in the equity markets and interest rates. Accordingly, we have implemented hedging programs designed to mitigate the economic exposure to us from these features due to equity market and interest rate movements. Changes in the values of the derivatives associated with these programs due to equity market and interest rate movements are recognized in the periods in which they occur while corresponding changes in offsetting liabilities not measured at fair value, are recognized over time. This results in net income volatility.

46

Effect of Assumption Updates on Operating Results

Our actuaries oversee the valuation of the product liabilities and assets and review the underlying inputs and assumptions. We comprehensively review the actuarial assumptions underlying these valuations and update assumptions during the third quarter of each year. Assumptions are based on a combination of Company experience, industry experience, management actions and expert judgment and reflect our best estimate as of the date of the applicable financial statements. Changes in assumptions can result in a significant change to the carrying value of product liabilities and assets and, consequently, the impact could be material to earnings in the period of the change.

Most of the variable annuity products, variable universal life insurance and universal life insurance products we offer maintain policyholder deposits that are reported as liabilities and classified within either Separate Accounts liabilities or policyholder account balances. Our products and riders also impact liabilities for future policyholder benefits and unearned revenues and assets for DAC and DSI. The valuation of these assets and liabilities (other than deposits) is based on differing accounting methods depending on the product, each of which requires numerous assumptions and considerable judgment. The accounting guidance applied in the valuation of these assets and liabilities includes, but is not limited to, the following: (i) universal life insurance and variable life insurance secondary guarantees for which benefit liabilities are determined by estimating the expected value of death benefits payable when the account balance is projected to be zero and recognizing those benefits ratably over the accumulation period based on total expected assessments; (ii) certain product guarantees for which benefit liabilities are accrued over the life of the contract in proportion to actual and future expected policy assessments; and (iii) certain product guarantees reported as embedded derivatives at fair value.

For further details of our accounting policies and related judgments pertaining to assumption updates, see Note 2 of the Notes to the Financial Statements.

Results of Operations

The following table summarizes our statements of income (loss) for the three months ended March 31, 2023 and 2022:

47

Statement of Income (Loss)

	Three Months Ended March 31,
	2023		2022
	(in millions)
REVENUES
Policy charges and fee income	$	61	$	56
Premiums	69		49
Net derivative gains (losses)	6		(8)
Net investment income (loss)	29		20
Investment gains (losses), net	(5)		(1)
Investment management and service fees	5		5
Other income	6		—
Total revenues	171		121
BENEFITS AND OTHER DEDUCTIONS
Policyholders’ benefits	79		74
Remeasurement of liability for future policy benefits	(1)		(1)
Change in market risk benefits and purchased market risk benefits	—		(5)
Interest credited to policyholders’ account balances	23		19
Compensation and benefits	13		11
Commissions	31		16
Amortization of deferred policy acquisition costs	12		10
Other operating costs and expenses	23		23
Total benefits and other deductions	180		147
Income (loss) from continuing operations, before income taxes	(9)		(26)
Income tax (expense) benefit	72		6
Net income (loss)	$	63	$	(20)

The following discussion compares the results for the three months ended March 31, 2023 to the three months ended March 31, 2022.

Three Months Ended March 31, 2023 Compared to the Three Months Ended March 31, 2022

Net Income (Loss) Attributable to Equitable America

Net income attributable to Equitable America increased $83 million, to net income of $63 million for the three months ended March 31, 2023 from a net loss of $20 million for the three months ended March 31, 2022, primarily driven by the following notable items:

Favorable items included:

•Fee-type revenue increased by $31 million mainly due to business growth, primarily driven by an increase in employee benefit premiums.

•Net derivative gains (losses) increased $14 million mainly due to market appreciation during the first quarter of 2023 compared to market depreciation during the first quarter 2022.

•Net investment income increased by $9 million mainly due to higher SCS asset balances partially offset by lower income from seed capital investments.

•Income tax benefit increased $66 million primarily driven by a decrease to the valuation allowance of $69 million.

These were partially offset by the following unfavorable items:

•Commissions increased by $15 million mainly due to increased sales related to business growth.

48

•Policyholders’ benefits increased by $5 million mainly due to growth of the employee benefits business.

•Change in market risk benefits and purchased market risk benefits increased by $5 million mainly due to a decrease in interest rates during first quarter 2023 compared to an increase during first quarter 2022, partially offset by equity market depreciation during first quarter 2022.

•Net investment gains (losses) decreased by $4 million primarily due to realized losses on sales of AFS fixed maturities.

•Interest credited to policyholders’ account balances increased by $4 million mainly due to general business growth.

Summary of Critical Accounting Estimates

The preparation of financial statements in conformity with U.S. GAAP requires management to adopt accounting policies and make estimates and assumptions that affect amounts reported in our financial statements included elsewhere herein. For a discussion of our significant accounting policies, see Note 2 of the Notes to the Financial Statements. The most critical estimates include those used in determining:

•market risk benefits and purchased market risk benefits;

•accounting for reinsurance;

•estimated fair values of investments in the absence of quoted market values and investment impairments;

•estimated fair values of freestanding derivatives and the recognition and estimated fair value of embedded derivatives requiring bifurcation;

•measurement of income taxes and the valuation of deferred tax assets; and

•liabilities for litigation and regulatory matters.

In applying our accounting policies, we make subjective and complex judgments that frequently require estimates about matters that are inherently uncertain. Many of these policies, estimates and related judgments are common in the insurance and financial services industries while others are specific to our business and operations. Actual results could differ from these estimates.

Market Risk Benefits

Market risk benefits include contract features that provide minimum guarantees to policyholders and include GMIB, GMDB, GMWB, GMAB, and ROP DB benefits. MRBs are measured at estimated fair value with changes reported in the Change in market risk benefits and purchased market risk benefits, except for the portion of the fair value change related to the Company’s own credit risk, which is recognized in OCI.

MRBs are measured at fair value on a seriatim basis using an Ascribed Fee approach based upon policyholder behavior projections and risk neutral economic scenarios adjusted based on the facts and circumstances of the Company’s product features. Market conditions including, but not limited to, changes in interest rates, equity indices, market volatility and variations in actuarial assumptions, including policyholder behavior, mortality and risk margins related to non-capital market inputs, as well as changes in our nonperformance risk adjustment may result in significant fluctuations in the estimated fair value of the MRBs that could materially affect net income.

Risk margins are established to capture the non-capital market risks of the instrument which represent the additional compensation a market participant would require to assume the risks related to the uncertainties in certain actuarial assumptions. The establishment of risk margins requires the use of significant management judgment, including assumptions of the amount needed to cover the guarantees.

We ceded the risk associated with certain of the variable annuity products with GMxB features described in the preceding paragraphs. The value of the MRBs on the ceded risk is determined using a methodology consistent with that described previously for the guarantees directly written by us with the exception of the input for nonperformance risk that reflects the credit of the reinsurer.

Nonperformance Risk Adjustment

49

The valuation of our MRBs includes an adjustment for the risk that we fail to satisfy our obligations, which we refer to as our nonperformance risk. The nonperformance risk adjustment, which is captured as a spread over the risk-free rate in determining the discount rate to discount the cash flows of the liability, is determined by taking into consideration publicly available information relating to spreads on corporate bonds in the secondary market comparable to Holdings’ financial strength rating.

The table below illustrates the impact that a range of reasonably likely variances in credit spreads would have on our balance sheet, excluding the effect of income tax, related to the GMxB Core MRBs measured at estimated fair value. Even when credit spreads do not change, the impact of the nonperformance risk adjustment on fair value will change when the cash flows within the fair value measurement change. The table only reflects the impact of changes in credit spreads on our financial statements included elsewhere herein and not these other potential changes. In determining the ranges, we have considered current market conditions, as well as the market level of spreads that can reasonably be anticipated over the near term. The ranges do not reflect extreme market conditions such as those experienced during the 2008–2009 financial crisis as we do not consider those to be reasonably likely events in the near future.

NPR Sensitivity

December 31, 2022

	Increase/(Decrease) In MRB
	(in millions)
Increase in NPR by 50bps	$	(8)
Decrease in NPR by 50bps	$	9

Sensitivity of MRBs to Changes in Interest Rates

The following table demonstrates the sensitivity of the MRBs to changes in long-term interest rates by quantifying the adjustments that would be required, assuming an increase and decrease in long-term interest rates of 50bps. This information considers only the direct effect of changes in the interest rates on MRB balances, net of reinsurance.

Interest Rate Sensitivity

December 31, 2022

	Increase/(Decrease) In MRB
	(in millions)
Increase in interest rates by 50bps	$	(7)
Decrease in interest rates by 50bps	$	8

Sensitivity of MRBs to Changes in Equity Returns

The following table demonstrates the sensitivity of the MRBs to changes in equity returns.

Equity Returns Sensitivity

December 31, 2022

	Increase/(Decrease) In MRB
	(in millions)
Increase in equity returns by 10%	$	(6)
Decrease in equity returns by 10%	$	7

Sensitivity of MRBs to Changes in GMIB Lapses

Lapse rates are adjusted at the contract level based on a comparison of the value of the embedded GMIB rider and the current policyholder account value, which include other factors such as considering surrender charges. Generally, lapse rates are assumed to be lower in periods when a surrender charge applies. A dynamic lapse function reduces the base lapse rate when the guaranteed amount is greater than the account value as in-the-money contracts are less likely to lapse.

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GMIB Lapse floor Sensitivity

December 31, 2022

	Increase/(Decrease) In MRB
	(in millions)
GMIB Lapse floor of 1%	$	6

Item 3.     Quantitative and Qualitative Disclosures About Market Risk

There have been no material changes to the quantitative and qualitative disclosures about market risk described in the Annual Report on Form 10-K for the year ended December 31, 2022 in "Quantitative and Qualitative Disclosures About Market Risk".

Item 4.     Controls and Procedures

Management, with the participation of the Chief Executive Officer and Chief Financial Officer, has evaluated the effectiveness of the design and operation of the Company’s disclosure controls and procedures, as defined in Rule 13a-15(e) of the Exchange Act. Based on such evaluation, the Chief Executive Officer and Chief Financial Officer have concluded that, as of March 31, 2023, the Company’s disclosure controls and procedures were effective.

During the first quarter 2023, we adopted the new accounting standard ASU 2018-12, Financial Services – Insurance (Topic 944): Targeted Improvements to the Accounting for Long-Duration Contracts. We have modified our existing controls infrastructure, primarily through enhanced automation in our actuarial processes. There are no other changes in our internal control over financial reporting (as defined in Rule 13a-15(f) and Rule 15d-15(f) under the Exchange Act) that occurred during the quarter ended March 31, 2023, that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.

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Part II     OTHER INFORMATION

Item 1.     Legal Proceedings

For information regarding certain legal proceedings pending against us, see Note 13 of the Notes to the Financial Statements (unaudited) in this Form 10-Q. Also see “Risk Factors—Legal and Regulatory Risks—Legal and regulatory actions” included in our Annual Report on Form 10-K for the year ended December 31, 2022.

Item 1A. Risk Factors

You should carefully consider the risks described in the “Risk Factors” section included in our Annual Report on Form 10-K for the year ended December 31, 2022. Risks to which we are subject also include, but are not limited to, the factors mentioned under “Note Regarding Forward-Looking Statements and Information” above and the risks of our businesses described elsewhere in this Quarterly Report on Form 10-Q.

Item 2.    Unregistered Sales of Equity Securities and Use of Proceeds

Not applicable.

Item 3.     Defaults Upon Senior Securities

Not applicable.

Item 4.    Mine Safety Disclosures

Not applicable.

Item 5.     Other Information

None.

Item 6.     Exhibits    

INDEX TO EXHIBITS

Number		Description
31.1	#	Section 302 Certification made by the registrant’s Chief Executive Officer
31.2	#	Section 302 Certification made by the registrant’s Chief Financial Officer
32.1	#	Section 906 Certification made by the registrant’s Chief Executive Officer
32.2	#	Section 906 Certification made by the registrant’s Chief Financial Officer
101.INS		XBRL Instance Document - the instance document does not appear in the Interactive Data File because its XBRL tags are embedded within the Inline XBRL document.
101.SCH		Inline XBRL Taxonomy Extension Schema Document
101.CAL		Inline XBRL Taxonomy Extension Calculation Linkbase Document
101.LAB		Inline XBRL Taxonomy Extension Label Linkbase Document
101.PRE		Inline XBRL Taxonomy Extension Presentation Linkbase Document
101.DEF		Inline XBRL Taxonomy Extension Definition Linkbase Document
104		Cover Page Interactive Data File (formatted in Inline XBRL and contained in Exhibits 101).

______________

#    Filed herewith.

52

GLOSSARY

Selected Financial Terms

Account Value (“AV”)	Generally equals the aggregate policy account value of our retirement and protection products. General Account AV refers to account balances in investment options that are backed by the General Account while Separate Accounts AV refers to Separate Accounts investment assets.
Alternative investments	Investments in real estate and real estate joint ventures and other limited partnerships.
Annualized Premium	100% of first year recurring premiums (up to target) and 10% of excess first year premiums or first year premiums from single premium products.
Assets under management (“AUM”)	Investment assets that are managed by one of our subsidiaries and includes: (i) assets managed by AB, (ii) the assets in our GAIA portfolio and (iii) the Separate Account assets of our retirement and protection businesses. Total AUM reflects exclusions between segments to avoid double counting.
Combined RBC Ratio	Calculated as the overall aggregate RBC ratio for the Company’s insurance subsidiaries including capital held for its life insurance and variable annuity liabilities and non-variable annuity insurance liabilities.
Conditional tail expectation (“CTE”)	Calculated as the average amount of total assets required to satisfy obligations over the life of the contract or policy in the worst x% of scenarios. Represented as CTE (100 less x). Example: CTE95 represents the worst five percent of scenarios.
Deferred policy acquisition cost (“DAC”)	Represents the incremental costs related directly to the successful acquisition of new and certain renewal insurance policies and annuity contracts and which have been deferred on the balance sheet as an asset.
Deferred sales inducements (“DSI”)	Represent amounts that are credited to a policyholder’s account balance that are higher than the expected crediting rates on similar contracts without such an inducement and that are an incentive to purchase a contract and also meet the accounting criteria to be deferred as an asset that is amortized over the life of the contract.
Dividends Received Deduction (“DRD”)	A tax deduction under U.S. federal income tax law received by a corporation on the dividends it receives from other corporations in which it has an ownership stake.
Fee-Type Revenue	Revenue from fees and related items, including policy charges and fee income, premiums, investment management and service fees, and other income.
Gross Premiums	First year premium and deposits and Renewal premium and deposits.

Invested assets	Includes fixed maturity securities, equity securities, mortgage loans, policy loans, alternative investments and short-term investments.
P&C	Property and casualty.
Premium and deposits	Amounts a policyholder agrees to pay for an insurance policy or annuity contract that may be paid in one or a series of payments as defined by the terms of the policy or contract.
Protection Solutions Reserves	Equals the aggregate value of Policyholders’ account balances and Future policy benefits for policies in our Protection Solutions segment.
Reinsurance	Insurance policies purchased by insurers to limit the total loss they would experience from an insurance claim.
Renewal premium and deposits	Premiums and deposits after the first twelve months of the policy or contract.
Risk-based capital (“RBC”)	Rules to determine insurance company statutory capital requirements. It is based on rules published by the National Association of Insurance Commissioners (“NAIC”).
Total adjusted capital (“TAC”)	Primarily consists of capital and surplus, and the asset valuation reserve.

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Value of business acquired (“VOBA”)	Present value of estimated future gross profits from in-force policies of acquired businesses.
Product Terms
401(k)	A tax-deferred retirement savings plan sponsored by an employer. 401(k) refers to the section of the Internal Revenue Code of 1986, as amended (the “Code”) pursuant to which these plans are established.
403(b)	A tax-deferred retirement savings plan available to certain employees of public schools and certain tax-exempt organizations. 403(b) refers to the section of the Code pursuant to which these plans are established.
457(b)	A deferred compensation plan that is available to governmental and certain non-governmental employers. 457(b) refers to the section of the Code pursuant to which these plans are established.
Accumulation phase	The phase of a variable annuity contract during which assets accumulate based on the policyholder’s lump sum or periodic deposits and reinvested interest, capital gains and dividends that are generally tax-deferred.
Affluent	Refers to individuals with $250,000 to $999,999 of investable assets.
Annuitant	The person who receives annuity payments or the person whose life expectancy determines the amount of variable annuity payments upon annuitization of an annuity to be paid for life.
Annuitization	The process of converting an annuity investment into a series of periodic income payments, generally for life.

Benefit base	A notional amount (not actual cash value) used to calculate the owner’s guaranteed benefits within an annuity contract. The death benefit and living benefit within the same contract may not have the same benefit base.
Cash surrender value	The amount an insurance company pays (minus any surrender charge) to the policyholder when the contract or policy is voluntarily terminated prematurely.
Deferred annuity	An annuity purchased with premiums paid either over a period of years or as a lump sum, for which savings accumulate prior to annuitization or surrender, and upon annuitization, such savings are exchanged for either a future lump sum or periodic payments for a specified length of time or for a lifetime.
Dollar-for-dollar withdrawal	A method of calculating the reduction of a variable annuity benefit base after a withdrawal in which the benefit is reduced by one dollar for every dollar withdrawn.
Fixed annuity	An annuity that guarantees a set annual rate of return with interest at rates we determine, subject to specified minimums. Credited interest rates are guaranteed not to change for certain limited periods of time.
Fixed Rate GMxB	Guarantees on our individual variable annuity products that are based on a rate that is fixed at issue.
Floating Rate GMxB	Guarantees on our individual variable annuity products that are based on a rate that varies with a specified index rate, subject to a cap and floor.
Future policy benefits	Future policy benefits for the annuities business are comprised mainly of liabilities for life-contingent income annuities, and liabilities for the variable annuity guaranteed minimum benefits accounted for as insurance. Future policy benefits for the life business are comprised mainly of liabilities for traditional life and certain liabilities for universal and variable life insurance contracts (other than the Policyholders’ account balance).
General Account Investment Portfolio	The invested assets held in the General Account.
General Account	The assets held in the general accounts of our insurance companies as well as assets held in our separate accounts on which we bear the investment risk.

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GMxB	A general reference to all forms of variable annuity guaranteed benefits, including guaranteed minimum living benefits, or GMLBs (such as GMIBs, GMWBs and GMABs), and guaranteed minimum death benefits, or GMDBs (inclusive of return of premium death benefit guarantees).
Guaranteed income benefit (“GIB”)	An optional benefit which provides the policyholder with a guaranteed lifetime annuity based on predetermined annuity purchase rates applied to a GIB benefit base, with annuitization automatically triggered if and when the contract AV falls to zero.

Guaranteed minimum accumulation benefits (“GMAB”)	An optional benefit (available for an additional cost) which entitles an annuitant to a minimum payment, typically in lump-sum, after a set period of time, typically referred to as the accumulation period. The minimum payment is based on the benefit base, which could be greater than the underlying AV.
Guaranteed minimum death benefits (“GMDB”)	An optional benefit (available for an additional cost) that guarantees an annuitant’s beneficiaries are entitled to a minimum payment based on the benefit base, which could be greater than the underlying AV, upon the death of the annuitant.
Guaranteed minimum income benefits (“GMIB”)	An optional benefit (available for an additional cost) where an annuitant is entitled to annuitize the policy and receive a minimum payment stream based on the benefit base, which could be greater than the underlying AV.
Guaranteed minimum living benefits (“GMLB”)	A reference to all forms of guaranteed minimum living benefits, including GMIBs, GMWBs and GMABs (does not include GMDBs).
Guaranteed minimum withdrawal benefits (“GMWB”)	An optional benefit (available for an additional cost) where an annuitant is entitled to withdraw a maximum amount of their benefit base each year, for which cumulative payments to the annuitant could be greater than the underlying AV.
Guaranteed Universal Life (“GUL”)	A universal life insurance offering with a lifetime no lapse guarantee rider, otherwise known as a guaranteed UL policy. With a GUL policy, the premiums are guaranteed to last the life of the policy.
Guaranteed withdrawal benefit for life (“GWBL”)	An optional benefit (available for an additional cost) where an annuitant is entitled to withdraw a maximum amount of their benefit base each year, for the duration of the policyholder’s life, regardless of account performance.
High net worth	Refers to individuals with $1,000,000 or more of investable assets.
Index-linked annuities	An annuity that provides for asset accumulation and asset distribution needs with an ability to share in the upside from certain financial markets such as equity indices, or an interest rate benchmark. With an index-linked annuity, the policyholder’s AV can grow or decline due to various external financial market indices performance.
Investment Edge (“IE”)	A traditional variable deferred annuity without enhanced guaranteed benefits.
Indexed Universal Life (“IUL”)	A permanent life insurance offering built on a universal life insurance framework that uses an equity-linked approach for generating policy investment returns.
Living benefits	Optional benefits (available at an additional cost) that guarantee that the policyholder will get back at least his original investment when the money is withdrawn.
Mortality and expense risk fee (“M&E fee”)	A fee charged by insurance companies to compensate for the risk they take by issuing life insurance and variable annuity contracts.

Net flows Net change in customer account balances in a period including, but not limited to, gross premiums, surrenders, withdrawals and benefits. It excludes investment performance, interest credited to customer accounts and policy charges.

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Policyholder account balances	Annuities. Policyholder account balances are held for fixed deferred annuities, the fixed account portion of variable annuities and non-life contingent income annuities. Interest is credited to the policyholder’s account at interest rates we determine which are influenced by current market rates, subject to specified minimums. Life Insurance Policies. Policyholder account balances are held for retained asset accounts, universal life policies and the fixed account of universal variable life insurance policies. Interest is credited to the policyholder’s account at interest rates we determine which are influenced by current market rates, subject to specified minimums.
Return of premium (“ROP”) death benefit	This death benefit pays the greater of the account value at the time of a claim following the owner’s death or the total contributions to the contract (subject to adjustment for withdrawals). The charge for this benefit is usually included in the M&E fee that is deducted daily from the net assets in each variable investment option. We also refer to this death benefit as the Return of Principal death benefit.
Rider	An optional feature or benefit that a policyholder can purchase at an additional cost.
Roll-up rate	The guaranteed percentage that the benefit base increases by each year.
Separate Account	Refers to the separate account investment assets of our insurance subsidiaries excluding the assets held in those separate accounts on which we bear the investment risk.
Surrender charge	A fee paid by a contract owner for the early withdrawal of an amount that exceeds a specific percentage or for cancellation of the contract within a specified amount of time after purchase.

Surrender rate	Represents annualized surrenders and withdrawals as a percentage of average AV.
Universal life (“UL”) products	Life insurance products that provide a death benefit in return for payment of specified annual policy charges that are generally related to specific costs, which may change over time. To the extent that the policyholder chooses to pay more than the charges required in any given year to keep the policy in-force, the excess premium will be placed into the AV of the policy and credited with a stated interest rate on a monthly basis.
Variable annuity	A type of annuity that offers guaranteed periodic payments for a defined period of time or for life and gives purchasers the ability to invest in various markets though the underlying investment options, which may result in potentially higher, but variable, returns.
Variable Universal Life (“VUL”)	Universal life products where the excess amount paid over policy charges can be directed by the policyholder into a variety of Separate Account investment options. In the Separate Account investment options, the policyholder bears the entire risk and returns of the investment results.
Whole Life (“WL”)	A life insurance policy that is guaranteed to remain in-force for the policyholder’s lifetime, provided the required premiums are paid.

ACRONYMS

•“AB” or “AllianceBernstein” means AB Holding and ABLP.

•“AB Holding” means AllianceBernstein Holding L.P., a Delaware limited partnership.

•“AB Holding Units” means units representing assignments of beneficial ownership of limited partnership interests in AB Holding.

•“ABLP” means AllianceBernstein L.P., a Delaware limited partnership and the operating partnership for the AB business.

•“AFS” means available-for-sale

•“AGL” means AXA Global Life

•“AOCI” means accumulated other comprehensive income

•“ASC” means Accounting Standards Codification

•“ASU” means Accounting Standards Update

•“AVR” means asset valuation reserve

•“AXA” means AXA S.A., a société anonyme organized under the laws of France, and formerly our controlling stockholder.

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•“AXA Financial” means AXA Financial, Inc., a Delaware corporation and a former wholly-owned direct subsidiary of Holdings. On October 1, 2018, AXA Financial merged with and into Holdings, with Holdings assuming the obligations of AXA Financial.

•“AXA RSUs” means AXA restricted stock units

•“BPs” means basis points

•“CARES Act” means Coronavirus Aid, Relief, and Economic Security Act

•“CDS” means credit default swaps

•“CDSC” means contingent deferred sales commissions

•“CEA” means Commodity Exchange Act

•“CECL” means current expected credit losses

•“CFTC” means U.S. Commodity Futures Trading Commission

•“COLI” means corporate owned life insurance

•“Company” means Equitable Financial Life Insurance Company of America (“Equitable America”), a direct wholly-owned subsidiary of Holdings.

•“CS Life” means Corporate Solutions Life Reinsurance Company, a Delaware corporation and a wholly-owned direct subsidiary of Holdings.

•“CS Life RE” means CS Life RE Company, an Arizona corporation and a wholly-owned indirect subsidiary of Holdings.

•“CSA” means credit support annex

•“CTE” means conditional tail expectation

•“DAC” means deferred policy acquisition costs

•“DCO” means designated clearing organization

•“DI” means disability income

•“Dodd-Frank Act” means Dodd-Frank Wall Street Reform and Consumer Protection Act

•“DOL” means U.S. Department of Labor

•“DSC” means debt service coverage

•“DSI” means deferred sales inducement

•“EAFE” means European, Australasia, and Far East

•“EFS” means Equitable Financial Services, LLC, a Delaware corporation and a wholly-owned direct subsidiary of Holdings.

•“EIM” means Equitable Investment Management Group, LLC, a Delaware limited liability company and a wholly-owned indirect subsidiary of Holdings.

•“Equitable Advisors” means Equitable Advisors, LLC, a Delaware limited liability company, our retail broker/dealer for our retirement and protection businesses and a wholly-owned indirect subsidiary of Holdings.

•“Equitable America” means Equitable Financial Life Insurance Company of America (f/k/a MONY Life Insurance Company of America), an Arizona corporation and a wholly-owned indirect subsidiary of Holdings.

•“Equitable Distributors” means Equitable Distributors, LLC, a Delaware limited liability company, our wholesale broker/dealer for our retirement and protection businesses and a wholly-owned indirect subsidiary of Holdings.

•“Equitable Financial QP” means Equitable Retirement Plan

•“Equitable Financial” means Equitable Financial Life Insurance Company, a New York corporation, a life insurance company and a wholly-owned subsidiary of EFS.

•“Equitable Network” means Equitable Network, LLC, a Delaware limited liability company and wholly-owned indirect subsidiary of Holdings and its subsidiary, Equitable Network of Puerto Rico, Inc.

•“EQ Premier VIP Trust” means EQ Premier VIP Trust, a series trust that is a Delaware statutory trust and is registered under the Investment Company Act of 1940, as amended (the “Investment Company Act”), as an open-end management investment company.

•“EQAT” means EQ Advisors Trust, a series trust that is a Delaware statutory trust and is registered under the Investment Company Act as an open-end management investment company.

•“EQ AZ Life Re” means EQ AZ Life Re Company, an Arizona corporation and a wholly-owned indirect subsidiary of Holdings.

•“ERISA” means Employee Retirement Income Security Act of 1974

•“ETF” means exchange traded funds

•“Exchange Act” means Securities Exchange Act of 1934, as amended

•“FASB” means Financial Accounting Standards Board

•“FDIC” means Federal Deposit Insurance Corporation

•“FHLB” means Federal Home Loan Bank

•“FINRA” means Financial Industry Regulatory Authority, Inc.

•“FIO” means Federal Insurance Office

•“FSOC” means Financial Stability Oversight Council

•The “General Partner” means AllianceBernstein Corporation, a Delaware corporation and the general partner of AB Holding and ABLP.

•“GIO” means guaranteed interest option

•“Holdings” means Equitable Holdings, Inc.

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•“Investment Advisers Act” means Investment Advisers Act of 1940, as amended

•“IPO” means initial public offering

•“IRS” means Internal Revenue Service

•“ISDA Master Agreement” means International Swaps and Derivatives Association Master Agreement

•“IUS” means Investments Under Surveillance

•“K-12 education market” means individuals in the kindergarten, primary and secondary education market

•“LGD” means loss given default

•“LIBOR” means London Interbank Offered Rate

•“LTV” means loan-to-value

•“Manual” means Accounting Practices and Procedures Manual as established by the NAIC

•“MD&A” means Management’s Discussion and Analysis of Financial Condition and Results of Operations

•“MRBs” means market risk benefits

•“MSO” means Market Stabilizer Option

•“NAIC” means National Association of Insurance Commissioners

•“NAR” means net amount at risk

•“NAV” means net asset value

•“NFA” means National Futures Association

•“NLG” means no-lapse guarantee

•“NYDFS” means New York State Department of Financial Services

•“OCI” means other comprehensive income

•“OTC” means over-the-counter

•“PD” means probability of default

•“Performance Share Plan” means AXA International Performance Shares Plan

•“PFBL” means profits followed by losses

•“R&P” means retirement and protection

•“RBG” means the Retirement Benefits Group, a specialized division of Equitable Advisors

•“REIT” means real estate investment trusts

•“RoU” means right of use

•“RSUs” means restricted stock units

•“RTM” means reversion to the mean

•“SAP” means statutory accounting principles

•“SCB LLC” means Sanford C. Bernstein & Co., LLC, a registered investment adviser and broker-dealer.

•“SCS” means Structured Capital Strategies

•“SEC” means U.S. Securities and Exchange Commission

•“SIO” means structured investment option

•“SPE” means special purpose entity

•“Stock Option Plan” means AXA Stock Option Plan for AXA Financial Employees and Associates

•“TCJA” or “Tax Reform Act” means the Tax Cuts and Jobs Act, enacted on December 22, 2017

•“TDRs” means troubled debt restructurings

•“TIPS” means treasury inflation-protected securities

•“U.S. GAAP” means accounting principles generally accepted in the United States of America

•“ULSG” means universal life products with secondary guarantee

•“URR” means unearned revenue reserve

•“VIAC” means Venerable Insurance and Annuity Company

•“VIE” means variable interest entity

•“VISL” means variable interest-sensitive life

•“VOE” means voting interest entity

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SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, Equitable Financial Life Insurance Company of America has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Date: May 12, 2023	/s/ Robin M. Raju
	Name: Robin M. Raju
	Title: Chief Financial Officer              (Principal Financial Officer)
Date: May 12, 2023	/s/ William Eckert
	Name: William Eckert
	Title: Chief Accounting Officer              (Principal Accounting Officer)

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