ALFRED AYENSU-GHARTEY

Vice President and

Associate General Counsel

(212) 314-2777

alfred.ayensu-ghartey@equitable.com

April 17, 2025

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Commissioners:

Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), Equitable Financial Life Insurance Company of America (the “Company”), and Variable Account AA (the “Registrant”), hereby respectfully request withdrawal, effective as of the date hereof or at the earliest practicable date hereafter, of the Company’s Registration Statement and any amendments thereto, on Form N-4 (File No. 333-266909), (the “Registration Statement”), as listed below:

The purpose of this Registration Statement was to register a new product offered by the Registrant. However, it was determined that this product will not be offered. In making this request, the Registrant and the Company confirm that no securities have been or will be distributed, issued, or sold pursuant to the Registration Statement. Accordingly, the Company hereby respectfully requests that the withdrawal of the Registration Statement be effective as of the date hereof or at the earliest practicable date hereafter.

Please note that this request for withdrawal is not meant to extend to the registration status of Variable Account AA, which is the funding vehicle for other variable annuity contracts.

Please contact the undersigned if there are any questions in connection with this matter.

EQUITABLE FINANCIAL LIFE INSURANCE COMPANY OF AMERICA

8501 IBM Drive, Suite 150, Charlotte, NC 28262-4333