AXA Equitable Holdings, Inc.

1290 Avenue of the Americas

New York, NY 10104

May 7, 2018

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-7010

Registration Statement on Form S-1

of AXA Equitable Holdings, Inc.

File No. 333-221521

Ladies and Gentlemen:

Pursuant to the provisions of Rule 461 under the Securities Act of 1933, as amended, AXA Equitable Holdings, Inc., a Delaware corporation (the “Company”), hereby respectfully requests that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 3:00 P.M. on May 9, 2018, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Debevoise & Plimpton LLP, by calling Peter J. Loughran at (212) 909-6375.

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Very truly yours,
AXA Equitable Holdings, Inc.
By:	/s/ Anders Malmström
	Name: Anders Malmström
	Title: Senior Executive Vice President and Chief Financial Officer

[Signature Page to Acceleration Request]