Morgan Stanley & Co. LLC

1585 Broadway

New York, New York 10036

J.P. Morgan Securities LLC

383 Madison Avenue

New York, New York 10179

Barclays Capital Inc.

745 Seventh Avenue

New York, New York 10019

Citigroup Global Markets Inc.

388 Greenwich Street

New York, New York 10013

May 7, 2018

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Dorrie Yale

Re: AXA Equitable Holdings, Inc. (the “Company”)

Registration Statement on Form S-1 (File No. 333-221521)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness at 3:00 pm New York City time on May 9, 2018, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus. The undersigned advise that the underwriters have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Pages Follow]

Very truly yours,
MORGAN STANLEY & CO. LLC
By:	/s/ Michael Occi
Name:	Michael Occi
Title:	Executive Director
J.P. MORGAN SECURITIES LLC
By:	/s/ Alaoui Zenere
Name:	Alaoui Zenere
Title:	Vice President
BARCLAYS CAPITAL INC.
By:	/s/ Victoria Hale
Name:	Victoria Hale
Title:	Vice President
CITIGROUP GLOBAL MARKETS INC.
By:	/s/ Aaron Lissner
Name:	Aaron Lissner
Title:	Director

[AEH—Signature Page to Underwriter Acceleration Request]