Equitable Financial Life Insurance Co. of America (RILA)
09/16/2025 | Press release | Distributed by Public on 09/16/2025 10:15
Post-Effective Amendment to Registration Statement by Investment Company (Form 485APOS)
Filed with the Securities and Exchange Commission on September 16, 2025.
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM N-4
(File No. 333-265026; 811-23609)
REGISTRATION STATEMENT
UNDER
| THE SECURITIES ACT OF 1933 | ☒ | |||
| Post-Effective Amendment No. 9 | ☒ |
AND/OR
REGISTRATION STATEMENT
UNDER
| THE INVESTMENT COMPANY ACT OF 1940 | ☒ | |||
| Amendment No. 89 | ☒ | |||
| (Check appropriate box or boxes) |
EQUITABLE AMERICA VARIABLE ACCOUNT NO. 70A
(Exact Name of Registered Separate Account)
(File No. 333-283590)
REGISTRATION STATEMENT
UNDER
| THE SECURITIES ACT OF 1933 | ☒ | |||
| Post-Effective Amendment No. 3 | ☒ |
EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA
(Name of Insurance Company)
8501 IBM Drive, Suite 150, Charlotte, NC 28262-4333
(Address of Insurance Company's Principal Executive Offices)
Insurance Company's Telephone Number, including Area Code: (212) 554-1234
Alfred Ayensu-Ghartey
Vice President and Associate General Counsel
Equitable Financial Life Insurance Company of America
8501 IBM Drive, Suite 150, Charlotte, NC 28262-4333
(Name and Address of Agent for Service)
APPROXIMATE DATE OF PROPOSED PUBLIC OFFERING: Continuous
It is proposed that this filing will become effective: (check appropriate box)
| ☐ |
immediately upon filing pursuant to paragraph (b) |
| ☐ |
on pursuant to paragraph (b) |
| ☒ |
60 days after filing pursuant to paragraph (a)(l) |
| ☐ |
on pursuant to paragraph (a)(l) of rule 485 under the Securities Act of 1933 ("Securities Act"). |
If appropriate, check the following box:
| ☐ |
this post-effective amendment designates a new effective date for a previously filed post-effective amendment. |
Check each box that appropriately characterizes the Registrant:
| ☐ |
New Registrant (as applicable, a Registered Separate Account or Insurance Company that has not filed a Securities Act registration statement or amendment thereto within 3 years preceding this filing) |
| ☐ |
Emerging Growth Company (as defined by Rule 12b-2 under the Securities Exchange Act of 1934 ("Exchange Act")) |
| ☐ |
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 7(a)(2)(B) of Securities Act |
| ☒ |
Insurance Company relying on Rule 12h-7 under the Exchange Act |
| ☐ |
Smaller reporting company (as defined by Rule 12b-2 under the Exchange Act) |
This Post-Effective Amendment No. 3 ("PEA") to the Form N-4 Registration Statement (File No. 333-283590) and Post-Effective Amendment No. 9 to Form N-4 Registration Statement (File No. 333-265026) ("Registration Statement") of Equitable Financial Life Insurance Company of America ("Equitable America") and its Equitable America Variable Account No. 70A is being filed for the purpose of including in the Registration Statement the additions/modifications reflected in the Supplement and Part C. This Post-Effective Amendment No. 3 for Registration Statement (File No. 333-283590) and Post-Effective Amendment No. 9 for Registration Statement (File No. 333-265026) incorporates by reference the information contained in Parts A and B of Post-Effective Amendment No. 1 (File No. 333-283590) and Post-Effective Amendment No. 7 (File No. 333-265026), filed on April 23, 2025.
Equitable Financial Life Insurance Company of America
Equitable Financial Life Insurance Company
Supplement dated September 16, 2025 to the Structured Capital Strategies PLUS® 21 prospectus dated May 1, 2025
This Supplement modifies certain information in the above-referenced prospectus (the "Prospectus"). You should read this Supplement in conjunction with your Prospectus and retain it for future reference. This Supplement incorporates the Prospectus by reference. Unless otherwise indicated, all other information included in your Prospectus remains unchanged. The terms we use in this Supplement have the same meaning as in your Prospectus. We will send you another copy of any prospectus or supplement without charge upon request. Please contact the customer service center at 877-899-3743.
The following hereby replaces the second paragraph in "Purchasing the contract - Your right to cancel within a certain number of days":
Generally, your refund will equal your contributions under the contract. However, some states require we refund your account value under the contract on the day we receive written notification of your decision to cancel the contract and will reflect any investment gain or loss in the investment options (less the daily charges we deduct) through the date we receive your contract. This includes the Segment Interim Value for amounts allocated to existing Segments. The Segment Interim Value calculation may reduce the amount of account value paid upon contract cancellation. For more information, see "Adjustments with respect to early distributions from Segments" in "Charges, Expenses, and Adjustments" in this prospectus. In addition, in some states, the amount of your refund (either the full amount of your contributions or the account value), and the length of your "free look" period, depend on whether you purchased the contract as a replacement. Please refer to the Appendix "State contract availability and/or variations of certain features and benefits", as well as your contract or supplemental materials or contact us for more information. For any IRA contract returned to us within seven days after you receive it, we are required to refund the full amount of your contribution. When required by applicable law to return the full amount of your contribution and the refunded amount includes account value in the EQ/Money Market variable investment option, we will return the greater of your contribution or your contract's cash value.
The following hereby replaces the corresponding section in "Charges, Expenses, and Adjustments - Charges under the contracts - Withdrawal charge (Series B contracts only) - Disability, terminal illness, or confinement to nursing home":
| (i) |
An owner (or older joint owner, if applicable) has qualified to receive Social Security disability benefits as certified by the Social Security Administration (this waiver only applies for contracts issued in New York, Oregon, and South Carolina, as well as all contracts issued using an application signed before September 22, 2025); or |
The following hereby supplements the information in the Appendix "State contract availability and/or variations of certain features and benefits":
The state variations listed in the Prospectus dated May 1, 2025 are applicable for all contracts issued using an application signed before September 22, 2025 and for contracts issued in California and New York.
| State | Features and benefits | Availability or variation | ||
|
South Carolina |
See "Your right to cancel within a certain number of days" in "Purchasing the contract" | If this is a replacement Contract: This Contract may be returned to us for any reason within 30 days after you receive it by mailing or delivering the Contract to either, us at the Processing Office, or to the agent through whom it was purchased. We will promptly refund any Contribution received on your behalf, plus or minus any investment gain or loss from the date of Contribution to the date of cancellation. | ||
| Catalog No. 800250 | ||
| SCS PLUS 21/New Biz | #56550 |
PART C
OTHER INFORMATION
ITEM 27. EXHIBITS
| (a) |
Board of Directors Resolutions. |
Secretary's Certificate dated November 10, 2020, certifying the Resolution of the Board of Directors of Equitable Financial Life Insurance Company of America authorizing establishment of Equitable America Variable Account No. 70A, incorporated herein by reference to Registration Statement (File No. 333-248907) filed on December 16, 2020.
| (b) |
Custodian Agreements. Not applicable. |
| (c) |
Underwriting Contracts |
| 1. |
Wholesale Distribution Agreement dated April 1, 2005, by and between MONY Life Insurance Company of America and MONY Securities Corporation and AXA Distributors, LLC, is incorporated herein by reference to the registration statement on Form S-3 (File No. 333-177419) filed on October 20, 2011. |
| (a) |
Form of the First Amendment dated as of October 1, 2013, to the Whole Distribution Agreement dated as of April 1, 2005, between MONY Life Insurance Company of America and AXA Distributors, LLC, incorporated herein by reference to the Registration Statement on Form S-1 (File No. 333-195491) filed on April 19, 2016. |
| (b) |
Second Amendment dated as of August 1, 2015, to the Wholesale Distributor Agreement dated as of April 1, 2005 between MONY Life Insurance Company of America and AXA Distributors, LLC, incorporated herein by reference to the Registration Statement on Form S-1 (File No. 333-195491) filed on April 19, 2016. |
| 2. |
Broker-Dealer and General Agent Sales Agreement between Equitable Distributors, LLC and Broker-Dealer and General Agent, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265027), filed on January 30, 2024. |
| 3. |
Wholesale Broker-Dealer Supervisory and Sale Agreement between the Broker-Dealer and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265027), filed on January 30, 2024. |
| 4. |
General Agent Sales Agreement dated June 6, 2005, by and between MONY Life Insurance Company of America and AXA Network, LLC. incorporated herein by reference to the registration statement on Form S-1 (File No. 333-180068) filed on March 13, 2012. |
| (a) |
First Amendment dated as of August 1, 2006, to General Agent Sales Agreement by and between MONY Life Insurance Company of America and AXA Network incorporated herein by reference to the registration statement on Form N-6 (File No. 333-134304) filed on March 1, 2012. |
| (b) |
Second Amendment dated as of April 1, 2008, to General Agent Sales Agreement dated as of April 1, 2008, by and between MONY Life Insurance Company of America and AXA Network, LLC incorporated herein by reference to the Registration Statement on Form S-1 (File No. 333-180068) filed on March 13, 2012. |
| (c) |
Form of THIRD AMENDMENT to General Agent Sales Agreement dated as of October 1, 2013, by and between MONY LIFE INSURANCE COMPANY OF AMERlCA and AXA NETWORK, LLC, incorporated herein by reference to the Registration Statement on Form S-1 (File No. 333-195491) filed on April 21, 2015. |
| (d) |
Fourth Amendment to General Agent Sales Agreement, dated as of October 1, 2014, by and between MONY LIFE INSURANCE COMPANY OF AMERICA ("MONY America") and AXA NETWORK, LLC and the additional affiliated entities of AXA Network, LLC, incorporated herein by reference to the Registration Statement on Form S-3 (File No. 333-236437) filed on March 14, 2022. |
| (e) |
Fifth Amendment to General Agent Sales Agreement, dated as of June 1, 2015, by and between MONY LIFE INSURANCE COMPANY OF AMERICA ("MONY America") and AXA NETWORK, LLC and the additional affiliated entities of AXA Network, LLC, incorporated herein by reference to Registration Statement on Form N-6 (File No. 333-207014) filed on December 23, 2015. |
| (f) |
Sixth Amendment to General Agent Sales Agreement, dated as of August 1, 2015, by and between MONY Life Insurance Company of America ("MONY America"), an Arizona life insurance company, and AXA NETWORK, LLC, a Delaware limited liability company ("General Agent"), incorporated herein by reference to the Registration Statement on Form N-6 (File No. 333-191149) filed on April 19, 2019. |
| (g) |
Seventh Amendment to the General Agent Sales Agreement, dated as of April 1, 2016, is by and between MONY Life Insurance Company of America ("MONY America"), an Arizona life insurance company, and AXA Network, LLC, a Delaware limited liability company ("General Agent"), incorporated herein by reference to the Registration Statement on Form N-6 (File No. 333-191149) filed on April 19, 2019. |
| (h) |
Eighth Amendment to General Agent Sales Agreement, dated as of November 1, 2019, by and between MONY Life Insurance Company of America and AXA Network, LLC, incorporated herein by reference to Registration Statement on Form N-6 (File No. 333-191149) filed on April 21, 2021. |
| (i) |
Ninth Amendment to General Agent Sales Agreement, dated as of October 1, 2020, by and between Equitable Financial Life Insurance Company of America and Equitable Network, LLC, incorporated herein by reference to Registration Statement on Form N-6 (File No. 333-191149) filed on April 21, 2021. |
| (j) |
Tenth Amendment to General Agent Sales Agreement dated as of September 1, 2021, by and between Equitable Financial Life Insurance Company of America and Equitable Network, LLC, incorporated herewith by reference to Registration Statement on Form N-4 (File No. 333-248907) filed on April 22, 2022. |
| (k) |
Eleventh Amendment to General Agent Sales Agreement dated as of November 1, 2021, by and between Equitable Financial Life Insurance Company of America and Equitable Network, LLC, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-248907) filed on April 22, 2022. |
| (l) |
Twelfth Amendment to General Agent Sales Agreement dated November 1, 2023, by and between Equitable Financial Life Insurance Company of America and Equitable Network, LLC, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265026) filed on April 22, 2024. |
| 5. |
Broker-Dealer Distribution and Servicing Agreement, dated June 6, 2005, made by and between MONY Life Insurance Company of America and AXA Advisors, LLC, incorporated herein by reference to post-effective amendment no. 1 to the registration statement on Form S-1 (File No. 333-180068) filed on March 13, 2012. |
| 6. |
Broker General Agent Agreement between Broker General Agent and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265027), filed on January 30, 2024. |
| (a) |
Amendment to Brokerage General Agent Sales Agreement between Brokerage General Agency and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265027), filed on January 30, 2024. |
| (d) |
Contracts. |
| 1. |
Form of Contract, 2021SCSBASE-A, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 2. |
Form of Contract, 2021SCSBASE-B, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 3. |
Form of Data Pages, 2021DPADV-SCS-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 4. |
Form of Data Pages, 2021DPB-SCS-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 5. |
Form of Data Pages, 2021DPC-SCS-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 6. |
Form of Endorsement, 2021CCOBR-SCS-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 7. |
Form of Endorsement, 2021INHIRA-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 8. |
Form of Endorsement, 2021INHNQ-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 9. |
Form of Endorsement, 2021INHROTH-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 10. |
Form of Endorsement, 2021IRA-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 11. |
Form of Endorsement, 2021NQ-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 12. |
Form of Endorsement, 2021NQROPDB-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 13. |
Form of Endorsement, 2021QPDB-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 14. |
Form of Endorsement, 2021QPDC-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 15. |
Form of Endorsement, 2021ROTH-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 16. |
Form of Endorsement, 2021SEP-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 17. |
Form of Rider, 2021SCS-AL-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 18. |
Form of Rider, 2021SCS-DD-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 19. |
Form of Rider, 2021SCS-EU-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 20' |
Form of Rider, 2021SCS-ROPDB-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 21. |
Form of Rider, 2021SCS-ST-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 22. |
Form of Rider, 2021SCS-SU-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 23. |
Form of TGAP-2021TGAP1-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 24. |
Form of TGAP-2021TGAP2-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 25. |
Form of TGAP-2021TGAP3-IR-Z, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 26. |
Form of Rider. 2022SCS-DSU-Z, incorporated herein by reference to Registration Statement on Form S-3 (File No. 333-265027) filed on December 13, 2022. |
| 27. |
Form of Rider. 2022SCS-LL-Z, incorporated herein by reference to Registration Statement on Form S-3 (File No. 333-265027) filed on December 13, 2022. |
| 28. |
Form of Certificate of Assumption, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-272919) filed on September 15, 2023. |
| 29. |
Form of Annual Lock Segment Option Rider 2023SCS-AL-Z, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265026) filed on April 22, 2024. |
| 30. |
Form of Endorsement Applicable to the Segment Interim Value 2023-SIV-Z, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265026) filed on April 22, 2024. |
| 31. |
Form of Endorsement Applicable to Advisory Fee Payment(s) 2023-AFP-Z, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265026) filed on April 22, 2024. |
| 32. |
Form of Contract, ICC25SCSBASE1-Z, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265026) filed on August 27, 2025. |
| 33. |
Form of Contract, ICC25SCSBASE2-Z, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265026) filed on August 27, 2025. |
| (e) |
Applications. |
| 1. |
Form of Application 2022 App SCSPL, incorporated herein by reference to the Registration Statement on Form N-4 (File No. 333-265026) filed on May 18, 2022. |
| 2. |
Form of Application, ICC25 App SCSPL21, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265026) filed on August 27, 2025. |
| (f) |
Insurance Company's Certificate of Incorporation and By-Laws. |
| 1. |
Articles of Restatement of the Articles of Incorporation of Equitable Financial Life Insurance Company of America (as Amended December 13, 2019) incorporated herein by reference to registration statement on Form S-1 (File No. 333-236437) filed on February 14, 2020. |
| 2. |
Amended and Restated By-Laws of Equitable Financial Life Insurance Company of America (as Amended September 23, 2020) incorporated herein by reference to registration statement on Form N-6 (File No. 333-191149) filed on April 21, 2021. |
| (g) |
Reinsurance Contracts. Not applicable. |
| (1) |
Reinsurance Agreement between Equitable Financial Life Insurance and Equitable Financial Life Insurance Company of America executed January 1, 2024, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265026) filed on April 22, 2024. |
| (h) |
Participation Agreements. |
| 1. |
AMENDED AND RESTATED PARTICIPATION AGREEMENT, made and entered into as of the 23rd day of May 2012 by and among MONY LIFE INSURANCE COMPANY OF AMERICA, an Arizona insurance company ("MONY"), on its own behalf and on behalf of the separate accounts set forth on Schedule B hereto as may be amended from time to time (each an "Account"), EQ ADVISORS TRUST, a business trust organized under the laws of the State of Delaware ("Trust") and AXA DISTRIBUTORS, LLC, a Delaware limited liability company (the "Distributor"), incorporated herein by reference to EQ Advisors Trust Registration Statement on Form N-1/A (File No. 333-17217) filed on January 10, 2014. |
| (a) |
Amendment No. 1, dated as of June 4, 2013 ("Amendment No. 1"), to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended ("Agreement"), by and among EQ Advisors Trust ("Trust"), MONY Life Insurance Company of America and AXA Distributors, LLC (collectively, the "Parties"), incorporated herein by reference to EQ Advisors Trust Registration Statement on Form N-1/A (File No. 333-17217) filed on January 10, 2014. |
| (b) |
Amendment No. 2, dated as of October 21, 2013 ("Amendment No. 2"), to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended ("Agreement"), by and among EQ Advisors Trust ("Trust"), MONY Life Insurance Company of America and AXA Distributors, LLC (collectively, the "Parties"), incorporated herein by reference to EQ Advisors Trust Registration Statement on Form N-1/A (File No. 333-17217) filed on January 10, 2014. |
| (c) |
Amendment No. 3, dated as of November 1, 2013 ("Amendment No. 3"), to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended ("Agreement"), by and among EQ Advisors Trust ("Trust"), MONY Life Insurance Company of America and AXA Distributors, LLC (collectively, the "Parties") "), incorporated herein by reference to EQ Advisors Trust Registration Statement on Form N-1/A (File No. 333-17217) filed on April 11, 2014. |
| (d) |
Amendment No. 4, dated as of April 4, 2014 ("Amendment No. 4"), to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended ("Agreement"), by and among EQ Advisors Trust ("Trust"), MONY Life Insurance Company of America and AXA Distributors, LLC (collectively, the "Parties") incorporated herein by reference to EQ Advisors Trust Registration Statement on Form N-1/A (File No. 333-17217) filed on April 30, 2014. |
| (e) |
Amendment No. 5, dated as of June 1, 2014 ("Amendment No. 5"), to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended ("Agreement"), by and among EQ Advisors Trust ("Trust"), MONY Life Insurance Company of America and AXA Distributors, LLC (collectively, the "Parties") incorporated herein by reference to EQ Advisors Trust Registration Statement on Form N-1/A (File No. 333-17217) filed on April 30, 2014. |
| (f) |
Amendment No. 6, dated as of July 16, 2014 ("Amendment No. 6"), to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended ("Agreement"), by and among EQ Advisors Trust ("Trust"), MONY Life Insurance Company of America and AXA Distributors, LLC (collectively, the "Parties"), incorporated herein by reference to EQ Advisors Trust Registration Statement on Form N-1/A (File No. 333-17217) filed on February 5, 2015. |
| (g) |
Amendment No. 7, dated as of April 30, 2015 ("Amendment No. 7"), to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended ("Agreement"), by and among EQ Advisors Trust ("Trust"), MONY Life Insurance Company of America and AXA Distributors, LLC (collectively, the "Parties"), incorporated herein by reference to EQ Advisors Trust Registration Statement on Form N-1/A (File No. 333-17217) filed on April 17, 2015. |
| (h) |
Amendment No. 8, dated as of December 21, 2015 ("Amendment No. 8"), to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended ("Agreement"), by and among EQ Advisors Trust ("Trust"), MONY Life Insurance Company of America and AXA Distributors, LLC (collectively, the "Parties") incorporated herein by reference to EQ Advisors Trust Registration Statement on Form 485 (a) (File No. 333-17217) filed on February 11, 2016. |
| (i) |
Amendment No. 9, dated as of December 9, 2016 ("Amendment No. 9"), to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended ("Agreement"), by and among EQ Advisors Trust ("Trust"), MONY Life Insurance Company of America and AXA Distributors, LLC (collectively, the "Parties") incorporated herein by reference to EQ Advisors Trust Registration Statement on Form 485 (a) (File No. 333-17217) filed on January 31, 2017. |
| (j) |
Amendment No. 10 dated as of May 1, 2017, to the Amended and Restated Participation Agreement among EQ Advisors Trust, MONY Life Insurance Company of America and AXA Distributors, LLC, dated May 23, 2012, incorporated herein by reference to Registration Statement on Form N-1A (File No. 333-17217) filed April 28, 2017. |
| (k) |
Amendment No. 11 dated as of November 1, 2017, to the Amended and Restated Participation Agreement among EQ Advisors Trust, MONY Life Insurance Company of America and AXA Distributors, LLC, dated May 23, 2012, incorporated herein by reference to Registration Statement on Form N-1A (File No. 333-17217) filed October 27, 2017. |
| (l) |
Amendment No. 12 dated as of July 12, 2018, to the Amended and Restated Participation Agreement among the EQ Advisor Trust, MONY Life Insurance Company of America and AXA Distributors, LLC, dated May 23, 2012, incorporated herein by reference to Registration Statement on Form N-1A (File No. 333-17217) filed on July 31, 2018. |
| (m) |
Amendment No. 13 dated as of December 6, 2018, to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, MONY Life Insurance Company of America and AXA Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-1A (File No. 333-17217), filed on April 26, 2019. |
| (n) |
Amendment No. 14 dated as of July 16, 2020, to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, Equitable Financial Life Insurance Company of America, Equitable Investment Management Group, LLC and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-14 (File No. 333-254202) filed on March 12, 2021. |
| (o) |
Amendment No. 15 dated as of February 1, 2021, to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, Equitable Financial Life Insurance Company of America, Equitable Investment Management Group, LLC and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-14 (File No. 333-254202) filed on March 12, 2021. |
| (p) |
Amendment No. 16 dated as of February 26, 2021, to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, Equitable Financial Life Insurance Company of America, Equitable Investment Management Group, LLC and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-1A (File No. 333-17217) filed on April 29, 2021. |
| (q) |
Amendment No. 17 dated July 22, 2021, to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, Equitable Financial Life Insurance Company of America, Equitable Investment Management Group, LLC and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-1A (File No. 333-17217) filed on September 24, 2021. |
| (r) |
Amendment No. 18 dated January 13, 2022 to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, Equitable Financial Life Insurance Company of America, Equitable Investment Management Group, LLC and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-1A (File No. 333-17217) filed on April 28, 2022. |
| (s) |
Amendment No. 19 dated August 19, 2022, to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, Equitable Financial Life Insurance Company of America, Equitable Investment Management Group, LLC and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-1A (File No. 333-17217) filed on April 26, 2023. |
| (t) |
Amendment No. 20 dated November 17, 2022, to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, Equitable Financial Life Insurance Company of America, Equitable Investment Management Group, LLC and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-1A (File No. 333-17217) filed on April 26, 2023. |
| (u) |
Amendment No. 21 dated March 16, 2023, to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, Equitable Financial Life Insurance Company of America, Equitable Investment Management Group, LLC and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-1A (File No. 333-17217) filed on March 29, 2023. |
| (v) |
Amendment No. 22 dated July 31, 2023, to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, Equitable Financial Life Insurance Company of America, Equitable Investment Management Group, LLC and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-248907) filed on February 7, 2024. |
| (w) |
Amendment No. 23 dated October 20, 2023, to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, Equitable Financial Life Insurance Company of America, Equitable Investment Management Group, LLC and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-248907) filed on February 7, 2024. |
| (x) |
Amendment No. 24 dated November 12, 2023, to the Amended and Restated Participation Agreement, dated as of May 23, 2012, as amended by and among EQ Advisors Trust, Equitable Financial Life Insurance Company of America, Equitable Investment Management Group, LLC and Equitable Distributors, LLC, incorporated herein by reference to Registration Statement on Form N-1A (File No. 333-17217) filed on April 26, 2024. |
(i) Administrative Contracts.
| 1. |
Amended and Restated Services Agreement between MONY Life Insurance Company of America and AXA Equitable Life Insurance Company dated as of February 1, 2005 incorporated herein by reference to Exhibit 10.2 to the registration statement (File No. 333-65423) on Form 10-K filed on March 31, 2005. |
(j) Other Material Contracts. Not applicable.
(k) Legal Opinion.
| 1. |
Opinion and consent of Counsel, filed herewith. |
(l) Other Opinions.
| 1. |
Consent of Independent Registered Public Accounting Firm, filed herewith. |
(m) Omitted Financial Statements. Not applicable.
(n) Initial Capital Agreements. Not applicable.
(o) Form of Initial Summary Prospectus, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265026) filed on April 23, 2025.
(p) Power of Attorney, Filed herewith.
(q) Letter Regarding Change in Certifying Accountant. Not Applicable.
(r) Historical Current Limits on Index Gains for SCS PLUS 21 B Shares, SCS PLUS 21 Select (C Shares), SCS PLUS ADV Shares, incorporated herein by reference to Registration Statement on Form N-4 (File No. 333-265026) filed on April 23, 2025.
ITEM 28. DIRECTORS AND OFFICERS OF THE INSURANCE COMPANY
| * |
The business address for all officers and directors of the Insurance Company is 8501 IBM Drive, Suite 150, Charlotte, NC 28262-4333. |
| NAME AND PRINCIPAL | POSITIONS AND OFFICES WITH | |
|
BUSINESS ADDRESS |
THE INSURANCE COMPANY |
|
| DIRECTORS | ||
| Douglas A. Dachille | Director | |
|
Legacy Liability Solutions, LLC |
||
|
161 N. Clark Street |
||
|
Chicago, IL 60602 |
||
| Francis Hondal | Director | |
| 10050 W. Suburban Drive | ||
| Pinecrest, FL 33156 | ||
|
Arlene Isaacs-Lowe 1830 South Ocean Drive, #1411 Hallandale, FL 33009 |
Director | |
| Daniel G. Kaye | Director | |
| 767 Quail Run | ||
| Inverness, IL 60067 | ||
| Joan Lamm-Tennant | Director | |
| 135 Ridge Common | ||
| Fairfield, CT 06824 | ||
|
Craig MacKay England & Company 1133 Avenue of the Americas Suite 2719 New York, NY 10036 |
Director | |
| Bertram L. Scott | Director | |
| 3601 Hampton Manor Drive | ||
| Charlotte, NC 28226 | ||
| George Stansfield | Director | |
| AXA | ||
| 25, Avenue Matignon | ||
| 75008 Paris, France | ||
| Charles G.T. Stonehill | Director | |
| Founding Partner | ||
| Green & Blue Advisors | ||
| 525 Park Avenue, 8D | ||
| New York, New York 10065 | ||
| OFFICER-DIRECTOR | ||
| *Mark Pearson | Director and Chief Executive Officer | |
| OTHER OFFICERS | ||
| *Nicholas B. Lane | President | |
| *José Ramón González | Chief Legal Officer and Secretary | |
| *Jeffrey J. Hurd | Chief Operating Officer | |
| *Robin M. Raju | Chief Financial Officer | |
| *Michael B. Healy | Chief Information Officer | |
| *Nicholas Huth | Chief Compliance Officer | |
| *William Eckert | Chief Accounting Officer | |
| *Darryl Gibbs | Chief Diversity Officer | |
| *David W. Karr | Signatory Officer | |
| *Erik Bass | Chief Strategy Officer | |
| *Mary Jean Bonadonna | Signatory Officer | |
| *Nicholas Chan | Deputy Treasurer | |
| *Eric Colby | Signatory Officer | |
| *Glen Gardner | Chief Investment Officer | |
| *Kenneth Kozlowski | Signatory Officer | |
| *Carol Macaluso | Signatory Officer | |
| *James Mellin | Signatory Officer | |
| *Hillary Menard | Signatory Officer | |
| *Kurt Meyer | Deputy General Counsel and Signatory Officer | |
| *Maryanne (Masha) Mousserie | Signatory Officer | |
| *Prabha ("Mary") Ng | Chief Information Security Officer | |
| *Antonio Di Caro | Signatory Officer | |
| *Shelby Hollister-Share | Signatory Officer | |
| *Manuel Prendes | Signatory Officer | |
| *Stephen Scanlon | Signatory Officer | |
| *Samuel Schwartz | Signatory Officer | |
| *Stephanie Shields | Signatory Officer | |
| *Joseph M. Spagnuolo | Signatory Officer | |
| *Qi Ning ("Peter") Tian | Treasurer | |
| *Gina Tyler | Chief Communications Officer | |
| *Constance Weaver | Chief Marketing Officer | |
| *Xu ("Vincent") Xuan | Chief Actuary | |
| *Yun ("Julia") Zhang | Chief Risk Officer | |
ITEM 29. PERSONS CONTROLLED BY OR UNDER COMMON CONTROL WITH THE INSURANCE COMPANY OR REGISTERED SEPARATE ACCOUNT.
Equitable America Variable Account No. 70A (the "Variable Account") is a variable account of Equitable Financial Life Insurance Company of America. Equitable Financial Life Insurance Company of America, an Arizona stock life insurance company, is an indirect wholly owned subsidiary of Equitable Holdings, Inc. (the "Holding Company").
Set forth below is the subsidiary chart for the Holding Company:
Equitable Holdings, Inc.-Subsidiary Organization Chart Q2-2025 is filed herewith.
ITEM 30. INDEMNIFICATION.
The By-Laws of Equitable Financial Life Insurance Company of America (the "Corporation") provide, in Article VI as follows:
SECTION 1. NATURE OF INDEMNITY. The Corporation shall indemnify any person who was or is a party or is threatened to be made a party to any threatened, pending or completed action, suit or proceeding, whether civil, criminal, administrative, or investigative, by reason of the fact that he or she is or was or has agreed to become a director or officer of the Corporation, or is or was serving or has agreed to serve at the request of the Corporation as a director or officer of another corporation, partnership, joint venture, trust or other enterprise, or by reason of any action alleged to have been taken or omitted in such capacity, and shall indemnify any person who was or is a party or is threatened to be made a party to such an action, suit or proceeding by reason of the fact that he or she is or was or has agreed to become an employee or agent of the Corporation, or is or was serving or has agreed to serve at the request of the Corporation as an employee or agent of another corporation, partnership, joint venture, trust or other enterprise, against expenses (including attorneys' fees), judgments, fines and amounts paid in settlement actually and reasonably incurred by him or her or on his or her behalf in connection with such action, suit or proceeding and any appeal therefrom, if he or she acted in good faith and in a manner he or she reasonably believed to be in or not opposed to the best interests of the Corporation, and, with respect to any criminal action or proceeding had no reasonable cause to believe his or her conduct was unlawful; except that in the case of an action or suit by or in the right of the Corporation to procure a judgment in its favor (1) such indemnification shall be limited to expenses (including attorneys' fees) actually and reasonably incurred by such person in the defense or settlement of such action or suit, and (2) no indemnification shall be made in respect of any claim, issue or matter as to which such person shall have been adjudged to be liable to the Corporation unless and only to the extent that the court in which such action or suit was brought or other court of competent jurisdiction shall determine upon application that, despite the adjudication of liability but in view of all the circumstances of the case, such person is fairly and reasonably entitled to indemnity.
The termination of any action, suit or proceeding by judgment, order, settlement, conviction or upon a plea of no contest or its equivalent, shall not, of itself, create a presumption that the person did not act in good faith and in a manner which he or she reasonably believed to be in or not opposed to the best interests of the Corporation, and, with respect to any criminal action or proceeding, had reasonable cause to believe that his or her conduct was unlawful.
SECTION 6. SURVIVAL; PRESERVATION OF OTHER RIGHTS. The foregoing indemnification provisions shall be deemed to be a contract between the Corporation and each director, officer, employee and agent who serves in any such capacity at any time while these provisions as well as the relevant provisions of Title 10, Arizona Revised Statutes are in effect and any repeal or modification thereof shall not affect any right or obligation then existing with respect to any state of facts then or previously existing or any action, suit or proceeding previously or thereafter brought or threatened based in whole or in part upon any such state of facts. Such a "contract right" may not be modified retroactively without the consent of such director, officer, employee or agent.
The indemnification provided by this Article shall not be deemed exclusive of any other right to which those indemnified may be entitled under any by-law, agreement, vote of stockholders or disinterested directors or otherwise, both as to action in his or her official capacity and as to action in another capacity while holding such office, and shall continue as to a person who has ceased to be a director, officer, employee or agent and shall inure to the benefit of the heirs, executors and administrators of such a person.
SECTION 7. INSURANCE. The Corporation may purchase and maintain insurance on behalf of any person who is or was a director or officer of the Corporation, or is or was serving at the request of the Corporation as a director, officer, employee or agent of another corporation, partnership, joint venture, trust or other enterprise against any liability asserted against such person and incurred by such person in any such capacity or arising out of his or her status as such, whether or not the Corporation would have the power to indemnify such person against such liability under the provisions of this By-Law.
The directors and officers of the Corporation are insured under policies issued by X.L. Insurance Company, Arch Insurance Company, Endurance Specialty Insurance Company, U.S. Specialty Insurance, ACE, Chubb Insurance Company, AXIS Insurance Company, Zurich Insurance Company, AWAC (Allied World Assurance Company Ltd.), Aspen Bermuda XS, CNA, AIG, Nationwide, Berkley, Berkshire, SOMPO, Chubb, Markel, Ascot, Bowhead, and Westfield. The annual limit on such policies is $300 million, and the policies insure the officers and directors against certain liabilities arising out of their conduct in such capacities.
Insofar as indemnification for liability arising under the Securities Act of 1933 may be permitted to directors, officers and controlling persons of the Registrant pursuant to the foregoing provisions, or otherwise, the Registrant has been advised that in the opinion of the Securities and Exchange Commission such indemnification is against public policy as expressed in the Act and is, therefore, unenforceable. In the event that a claim for indemnification for such liabilities (other than the payment by the Registrant of expense incurred or paid by a director, officer, or controlling person of the Registrant in the successful defense of any action, suit or proceeding) is asserted by such director, officer or controlling person in connection with the securities being registered, the Registrant will (unless in the opinion of its counsel the matter has been settled by controlling precedent) submit to a court of appropriate jurisdiction the question whether such indemnification by it is against public policy as expressed in the Act and will be governed by the final adjudication of such issue.
ITEM 31. PRINCIPAL UNDERWRITERS
| (a)(1) |
Equitable Advisors, LLC and Equitable Distributors, LLC are the principal underwriters for: |
| (i) |
Separate Account No. 49, Separate Account No. 70, Separate Account A, Separate Account FP, Separate Account I and Separate Account No. 45 of Equitable Financial |
| (ii) |
Separate Account No. 49B of Equitable Colorado |
| (iii) |
EQ Advisors Trust |
| (iv) |
Variable Account AA, Equitable America Variable Account A, Equitable America Variable Account K, Equitable America Variable Account L, and Equitable America Variable Account No. 70A. |
| (a)(2) |
Equitable Advisors is the principal underwriter of Equitable Financial's Separate Account No. 301. |
| (b) |
Set forth below is certain information regarding the directors and principal officers of Equitable Advisors, LLC and Equitable Distributors, LLC: |
EQUITABLE ADVISORS, LLC
|
NAME AND PRINCIPAL BUSINESS ADDRESS |
POSITIONS AND OFFICES WITH UNDERWRITER |
|
| *David Karr | Director, Chairman of the Board and Chief Executive Officer | |
| *Nicholas B. Lane | Director | |
| *Frank Massa | Director and President | |
| *Yun ("Julia") Zhang | Director | |
| *Ralph E. Browning, II | Chief Privacy Officer | |
| *Mary Jean Bonadonna | Chief Risk Officer | |
| *Patricia Boylan | Broker Dealer Chief Compliance Officer | |
| *Nia Dalley | Vice President and Chief Conflicts Officer | |
| *Brett Esselburn | Vice President, Investment Sales and Financial Planning | |
| *Gina Jones | Vice President and Financial Crime Officer | |
| *Tracy Zimmerer | Vice President and Principal Operations Officer | |
| *Sean Donovan | Assistant Vice President | |
| *Alan Gradzki | Assistant Vice President | |
| *Janie Smith | Assistant Vice President | |
| *James Mellin | Chief Sales Officer | |
| *Candace Scappator | Assistant Vice President, Controller and | |
| Principal Financial Officer | ||
| *Prabha ("Mary") Ng | Chief Information Security Officer | |
| *Alfred Ayensu-Ghartey | Vice President | |
| *Joshua Katz | Vice President | |
| *Dustin Long | Vice President | |
| *Christopher LaRussa | Investment Advisor Chief Compliance Officer | |
| *Christian Cannon | Vice President and General Counsel | |
| *Paul Scott Peterson | Vice President, Assistant Treasurer and Signatory Officer | |
| *Samuel Schwartz | Vice President | |
| *Dennis Sullivan | Vice President | |
| *Peter Tian | Senior Vice President, Treasurer and Signatory Officer | |
| *Constance (Connie) Weaver | Vice President | |
| *Michael Brudoley | Secretary | |
| *Christine Medy | Assistant Secretary | |
| *Francesca Divone | Assistant Secretary | |
| EQUITABLE DISTRIBUTORS, LLC | ||
|
NAME AND PRINCIPAL BUSINESS ADDRESS |
POSITIONS AND OFFICES WITH UNDERWRITER |
|
| *Nicholas B. Lane | Director, Chairman of the Board, President and | |
| Chief Executive Officer | ||
| *Jim Kais | Director and Head of Group Retirement | |
| *Jason Brown | Deputy Chief Compliance Officer | |
| *Ursula Carty | Head of Commercial Line Marketing | |
| *Amy Feintuch | Head of Independent Relationships - Financial Protection | |
| *Steve Junge | National Sales Manager - 1290 Funds | |
| *James O'Connor | Head of Business Development and Key Accounts Group Retirement | |
| *David Kahal | Signatory Officer | |
| *Fred Makonnen | Signatory Officer | |
| *Arielle D' Auguste | Signatory Officer and General Counsel | |
| *Alfred D'Urso | Signatory Officer and Chief Compliance Officer | |
| *Candace Scappator | Signatory Officer, Chief Financial Officer, Principal Financial | |
| Officer and Principal Operations Officer | ||
| *Gina Jones | Signatory Officer and Financial Crime Officer | |
| *Yun ("Julia") Zhang | Signatory Officer and Chief Risk Officer | |
| *Francesca Divone | Secretary | |
| *Stephen Scanlon | Director, Head of Individual Retirement and Signatory Officer | |
| *Prabha ("Mary") Ng | Signatory Officer and Chief Information Security Officer | |
| *Michael Brudoley | Assistant Secretary | |
| *Christine Medy | Assistant Secretary | |
* Principal Business Address:
1345 Avenue of the Americas
NY, NY 10105
(c)
|
Name of Principal Underwriter |
Net Underwriting Discounts |
Compensation on Redemption |
Brokerage Commission |
Other Compensation |
||||||||||||
|
Equitable Advisors, LLC |
N/A | $ | 0 | $ | 0 | $ | 0 | |||||||||
|
Equitable Distributors, LLC |
N/A | $ | 0 | $ | 0 | $ | 0 | |||||||||
ITEM 31A INFORMATION ABOUT CONTRACTS WITH INDEX-LINKED OPTIONS AND FIXED OPTIONS SUBJECT TO A CONTRACT ADJUSTMENT.
| (a) |
For any Contract with Index-Linked Options and/or Fixed Options subject to a Contract Adjustment offered through this registration statement, provide the information required by the following table as of December 31 of the prior calendar year. |
|
Name of the Contract |
Number of Contracts Outstanding |
Total value attributable to the Index-Linked Option and/or Fixed Option subject to a Contract Adjustment |
Number of Contracts sold during the prior calendar year |
Gross premiums received during the prior calendar year |
Amount of Contract value redeemed during the prior calendar year |
Combination Contract (Yes/No) |
||||||||||||||||
|
Structured Capital Strategies PLUS® 21 |
87,944 | 17,800,645,373 | 46,870 | 18,457,908,191 | 483,623,535 | Yes | ||||||||||||||||
| (b) |
See Exhibit (27)(r) Historical Current Limits on Index Gains. |
ITEM 32. LOCATION OF ACCOUNTS AND RECORDS.
This information is omitted as it is provided in Registered Separate Account's most recent report on Form N-CEN.
ITEM 33. MANAGEMENT SERVICES.
Not applicable.
ITEM 34. FEE REPRESENTATION.
| (a) |
The Insurance Company represents that, with respect to the Variable Options, the fees and charges deducted under the Contracts described in this Registration Statement, in the aggregate, are reasonable in relation to the services rendered, the expenses expected to be incurred, and the risks assumed by the Insurance Company under the respective Contracts. |
The Registered Separate Account hereby represents that it is relying on the November 28, 1988 no action letter (Ref. No. IP-6-88) relating to variable annuity contracts offered as funding vehicles for retirement plans meeting the requirements of Section 403(b) of the Internal Revenue Code. Registered Separate Account further represents that it will comply with the provisions of paragraphs (1)-(4) of that letter.
| (b) |
The Insurance Company undertakes to file, with respect to Index-Linked Options, during any period in which offers or sales are being made, a post-effective amendment to the registration statement to include any prospectus required by section 10(a)(3) of the Securities Act and that, for the purpose of determining any liability under the Securities Act, each such post-effective amendment shall be deemed to be a new registration statement relating to the securities offered therein, and the offering of such securities at that time shall be deemed to be the initial bona fide offering thereof. |
SIGNATURES
Pursuant to the requirements of the Securities Act of 1933 and the Investment Company Act of 1940, the Registrant has duly caused this registration statement to be signed on its behalf by the undersigned, duly authorized, in the City of New York, and State of New York on this 16th day of September, 2025.
| Equitable America Variable Account No. 70A | ||
| (Registered Separate Account) | ||
| Equitable Financial Life Insurance Company of America | ||
| (Insurance Company) | ||
| By |
/s/ Alfred Ayensu-Ghartey |
|
| Alfred Ayensu-Ghartey | ||
| Vice President and Associate General Counsel | ||
SIGNATURES
Pursuant to the requirements of the Securities Act of 1933, this Registration Statement has been signed by the following persons in the capacities and on the date indicated:
| PRINCIPAL EXECUTIVE OFFICER: | ||
| *Mark Pearson | Chief Executive Officer and Director | |
| PRINCIPAL FINANCIAL OFFICER: | ||
| *Robin Raju | Chief Financial Officer | |
| PRINCIPAL ACCOUNTING OFFICER: | ||
| *William Eckert | Chief Accounting Officer | |
| *DIRECTORS: | ||
|
Douglas A. Dachille Francis Hondal Arlene Isaacs-Lowe Daniel G. Kaye |
Joan Lamm-Tennant Craig MacKay Mark Pearson |
Bertram Scott George Stansfield Charles G. T. Stonehill |
| *By: |
/s/ Alfred Ayensu-Ghartey |
|
| Alfred Ayensu-Ghartey | ||
| Attorney-in-Fact | ||
| September 16, 2025 |
Equitable Financial Life Insurance Co. of America (RILA) published this content on September 16, 2025, and is solely responsible for the information contained herein. Distributed via SEC EDGAR on September 16, 2025 at 16:15 UTC. If you believe the information included in the content is inaccurate or outdated and requires editing or removal, please contact us at [email protected]