EX‐FILING FEES

Calculation of Filing Fee Tables

Form S-3

(Form Type)

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

(Exact Name of Registrant as Specified in its Charter)

Table 1: Newly Registered and Carry Forward Securities

Security Type

Security Class Title

Fee Calculation or Carry Forward Rule

Amount Registered

Proposed Maximum Offering Price Per Unit

Maximum Aggregate Offering Price

Fee Rate

Amount of Registration Fee

Carry Forward Form Type

Carry Forward File Number

Carry Forward Initial Effective Date

Filing Fee Previously Paid in Connection with Unsold Securities to be Carried Forward

Newly Registered Securities

Fees to be Paid

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Fees Previously Paid

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

Carry Forward Securities

Carry Forward Securities

Other

Modified Guaranteed Annuity Contracts and Participating Interests Therein

415(a)(6)

N/A

N/A

$

55,046,930

N/A

N/A

Form S-1

333-229747

5/1/2019

$

9,586.15

Total Offering Amounts

$

55,046,930

$

0

Total Fees Previously Paid

$

0

Total Fee Offsets

$

0

Net Fee Due

$

0

Approximately $55,046,930 of the interests previously registered on the Registration Statement on Form S-1 (File No. 333-229747) initially filed on April 19, 2019 and declared effective on May 1, 2019 (the “Prior Registration Statement”) remain unsold and are hereby carried forward to this Registration Statement on Form S-3 in reliance on Rule 415(a)(6) under the Securities Act of 1933. Pursuant to Rule 415(a)(6), the offering of interests under the Prior Registration Statement will be deemed terminated as of the effective date of this Registration Statement.