Form 485APOS Equitable America Variab
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E-mailFiled with the Securities and Exchange Commission on September 25, 2025.
REGISTRATION NO. 333-248907
REGISTRATION NO. 811-23609
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM N-4
| REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 |
☒ | |||
| POST-EFFECTIVE AMENDMENT NO. 15 | ☒ | |||
| and/or | ||||
| REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 |
☒ | |||
| AMENDMENT NO. 90 | ||||
EQUITABLE AMERICA VARIABLE ACCOUNT NO. 70A
(EXACT NAME OF REGISTERED SEPARATE ACCOUNT)
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 (date) 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. 15 (“PEA”) to the Form N-4 Registration Statement No. 333-248907 (“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 Supplements and Part C. This Post-Effective Amendment No. 15 incorporates by reference the information contained in Parts A and B of Post-Effective Amendment No. 14, filed on April 23, 2025.
Equitable Financial Life Insurance Company of America
Equitable Financial Life Insurance Company
Rate Sheet Supplement dated , 2025 to the current prospectus for:
| Retirement Cornerstone® Series 19 |
This Rate Sheet Supplement (this “Supplement”) updates certain information in the prospectus dated May 1, 2025 you received and in any supplements to the prospectus (collectively, the “Prospectus”). You should read this Supplement in conjunction with the Prospectus and retain it for future reference. Unless otherwise indicated, all other information included in the Prospectus remains unchanged. The terms and section headings we use in this Supplement have the same meaning as in the Prospectus. We will send you another copy of any prospectus or supplement without charge upon request. Please contact the customer service group referenced in the Prospectus.
Under the Guaranteed minimum income benefit, we will apply an initial Annual Roll-up rate and an initial Deferral Roll-up rate during the first seven years of your contract, beginning on the date your contract is issued. For more information, see “Annual Roll-up rate” and “Deferral Roll-up rate” in the “Benefits available under the contract” section of the Prospectus. The effective date of the following rates is , 2025 (the “Rate effective date”) until superseded as described below.
| Initial Annual Roll-up rate: 7.0% — See the “Important note for owners age 49 or younger” below. | ||
Initial Deferral Roll-up rate: 7.0% — See the “Important note for owners age 49 or younger” below.
Guaranteed Roll-up floor: 7.0%
Funding Age for GMIB: 50
If the contract is jointly owned, the GMIB can only be elected and funded if both owners are ages 50 through 80 (ages 50-70 for Series CP®).
Important note for owners age 49 or younger: Funding of the Guaranteed minimum income benefit and any guaranteed minimum death benefit you elect if you also have the Guaranteed minimum income benefit is only permitted starting at age 50. If you are between the ages of 43 and 49 at the time your contract is issued, the initial Roll-up rates specified in this Supplement will only apply after you attain age 50 for the amount of time then remaining in your first seven contract years. If you are age 42 or younger at the time your contract is issued, the initial Roll-up rates will never apply to your contract, as illustrated in the following chart:
| Age at time of contract purchase |
Contract years for which the initial Roll-up rates will apply(1) | |
| 50 or older | Full first 7 contract years | |
| 49 | Portion of 1st contract year plus contract years 2-7 | |
| 48 | Portion of 2nd contract year plus contract years 3-7 | |
| 47 | Portion of 3rd contract year plus contract years 4-7 | |
| 46 | Portion of 4th contract year plus contract years 5-7 | |
| 45 | Portion of 5th contract year plus contract years 6-7 | |
| 44 | Portion of 6th contract year plus contract year 7 | |
| 43 | Portion of contract year 7 | |
| 42 or younger | Never |
| (1) | For contract owners age 49 or younger at time of contract purchase, your birthday will determine the size of the portion of the contract year during which the Initial Roll-up rates apply. For example, if you signed your contract at age 46 on March 1 and your birthdate is April 1, the Initial Roll-up rates will apply for eleven months of your fourth contract year, starting on April 1 of that year. |
| IM-03-19 ( /25) | Cat. #159939 ( /25) | |
| RC 19/NB | #888453 |
GMIB Annuity Purchase Factors are applied to determine your periodic Lifetime GMIB payments under the GMIB. The GMIB annuity purchase factors are:
| GMIB Exercise Age |
Single Life (%) |
Joint Life (%)(1) |
GMIB Exercise Age |
Single Life (%) |
Joint Life (%)(1) |
|||||||||||||||||
| 60 | (2) | 2.790 | 2.232 | 78 | 4.090 | 3.272 | ||||||||||||||||
| 61 | 2.840 | 2.272 | 79 | 4.200 | 3.360 | |||||||||||||||||
| 62 | 2.890 | 2.312 | 80 | 4.315 | 3.452 | |||||||||||||||||
| 63 | 2.940 | 2.352 | 81 | 4.440 | 3.552 | |||||||||||||||||
| 64 | 3.000 | 2.400 | 82 | 4.570 | 3.656 | |||||||||||||||||
| 65 | 3.050 | 2.440 | 83 | 4.705 | 3.764 | |||||||||||||||||
| 66 | 3.110 | 2.488 | 84 | 4.845 | 3.876 | |||||||||||||||||
| 67 | 3.175 | 2.540 | 85 | 5.000 | 4.000 | |||||||||||||||||
| 68 | 3.235 | 2.588 | 86 | (3) | 5.155 | 4.124 | ||||||||||||||||
| 69 | 3.305 | 2.644 | 87 | (3) | 5.320 | 4.256 | ||||||||||||||||
| 70 | 3.375 | 2.700 | 88 | (3) | 5.490 | 4.392 | ||||||||||||||||
| 71 | 3.450 | 2.760 | 89 | (3) | 5.675 | 4.540 | ||||||||||||||||
| 72 | 3.530 | 2.824 | 90 | (3) | 5.860 | 4.688 | ||||||||||||||||
| 73 | 3.610 | 2.888 | 91 | (3) | 6.055 | 4.844 | ||||||||||||||||
| 74 | 3.700 | 2.960 | 92 | (3) | 6.260 | 5.008 | ||||||||||||||||
| 75 | 3.790 | 3.032 | 93 | (3) | 6.475 | 5.180 | ||||||||||||||||
| 76 | 3.885 | 3.108 | 94 | (3) | 6.695 | 5.356 | ||||||||||||||||
| 77 | 3.985 | 3.188 | 95 | (3) | 6.925 | 5.540 | ||||||||||||||||
| (1) | Based on age of younger joint owner. |
| (2) | Exercise of the GMIB is not permitted prior to age 60, except under the circumstances described in “Exercise of the GMIB in the event of a GMIB fee increase” in the “Charges and expenses” section. |
| (3) | If a surviving spouse is age 86 or older as of the Owner’s date of death and exercise the GMIB within one year of the Owner’s death, the joint life annuity payout option will apply. |
GMIB Annuity Purchase Factor Floor:
Single Life: 0.0% for GMIB Exercise Ages 60 - 65 and 3.11% for GMIB Exercise Ages 66 - 95
Joint Life(1): 0.0% for GMIB Exercise Ages 60 - 65 and 2.49% for GMIB Exercise Ages 66 - 95
| (1) | Based on age of younger joint owner. |
Lifetime GMIB payments are calculated by applying your GMIB benefit base (less any applicable withdrawal charge remaining) to the greater of (1) the guaranteed GMIB annuity purchase factors specified above, or (2) the GMIB annuity purchase factor floor specified above.
GMIB current Charge (as a percentage of the GMIB benefit base): 1.40%
GMDB current Charges (as a percentage of the benefit base) and issue ages:
| Guaranteed Minimum Death Benefit |
Current Charge and Issue Ages | |
| RMD Wealth Guard death benefit | Age Band on Contract Date 20-64 — 0.60% Age Band on Contract Date 65-73 — 1.25% | |
| Highest Anniversary Value death benefit | 0.35% 0-75 |
The rates, funding age, GMIB annuity purchase factors, and charges in this Supplement can be superseded. The rate effective date of a subsequent Rate Sheet Supplement will be at least 10 days after it is filed.
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If you sign your application on or after the above rate effective date and we issue you a contract based on that application during the Rate lock-in period (generally 75 days after the application is signed) and then (1) a subsequent Rate Sheet Supplement with one or more terms more favorable than the current Rate Sheet Supplement becomes effective and remains effective through your contract issue date, and (2) none of the terms on the subsequent Rate Sheet Supplement are less favorable than the current Rate Sheet Supplement, then we will change your terms to match all of the terms on the subsequent rate sheet supplement.
If we issue you a contract based on that application after the Rate lock-in period ends, the initial Annual Roll-up or Deferral rate, guaranteed Roll-up floor, GMIB funding age, GMIB annuity purchase factors, GMIB annuity purchase factor floor rate and age, and/or charge(s) applicable to your contract will be those in effect on the date your contract is issued based on the Rate Sheet Supplement then in effect. The terms in that supplement could be less favorable than those in this supplement.
See “Rate lock-in period” in the “Benefits available under the contract” section of the Prospectus. The Rate lock-in period may vary in some states. See Appendix “State contract availability and/or variations of certain features and benefits” in the Prospectus.
For information about the GMIB and GMDB rider fees, the GMIB funding age, initial Annual Roll-up rate, initial Deferral Roll-up rate, GMIB annuity purchase factors, GMIB annuity purchase factor floor rate and age, and guaranteed Roll-up floor applicable to you, please contact the customer service group toll-free at 1-800-789-7771. You can also visit www.equitable.com to view the current rates. Historical initial Annual Roll-up rates, initial Deferral Roll-up rates, guaranteed Roll-up floors, GMIB funding ages, GMIB annuity purchase factors, GMIB annuity purchase factor floor rate and age, and current historical GMIB and GMDB rider fees for contracts isssued before the date of this supplement may be found in Appendix “Historical Rate Sheet Supplement Information” to the Prospectus, as well as on the U.S. Securities and Exchange Commission’s website (www.sec.gov) by searching for File Nos. 333-248907 (Series 19 EFLOA) or 333-229766 (Series 19 EFLIC).
3
Equitable Financial Life Insurance Company
Equitable Financial Life Insurance Company of America
Supplement dated _________________, 2025 to the current prospectus for:
| Retirement Cornerstone® Series 19 |
This Supplement updates certain information in the most recent prospectus for variable annuity contracts and in any supplements to the prospectus (the “Prospectus”). This Supplement incorporates the Prospectus by reference unless otherwise indicated, and all other information included in your Prospectus remains unchanged. You should read this Supplement in conjunction with the Prospectus and retain it for future reference. The terms we use in this Supplement have the same meaning as in the Prospectus. We will send you another copy of any prospectus or supplement without charge upon request. Please contact the customer service group referenced in the Prospectus.
The purpose of this Supplement is to provide you with information regarding changes to your variable annuity. As is applicable to your contract, please note the following:
(1) New floor on annuitization purchase factors
The following hereby replaces the corresponding section in “Benefits available under the contract — Living Benefits — Guaranteed minimum income benefit — Exercise of GMIB”:
Lifetime GMIB payments. For contracts issued with applications signed before , lifetime GMIB payments are calculated by applying your GMIB benefit base (less any applicable withdrawal charge remaining) to the guaranteed GMIB annuity purchase factors specified in the Rate Sheet Supplement. For contracts issued with applications signed on or after , lifetime GMIB payments will now be calculated by applying your GMIB benefit base (less any applicable withdrawal charge remaining) to the greater of (1) the guaranteed GMIB annuity purchase factors specified in the Rate Sheet Supplement, or (2) the GMIB purchase factor floor specified in the Rate Sheet Supplement.
| RC 19/NB | Catalog # ( /25) | |
| #931401 |
PART C
OTHER INFORMATION
| ITEM 27. | EXHIBITS |
| (a) | Board of Directors Resolutions. |
| (b) | Custodian Agreements. Not applicable. |
| (c) | Underwriting Contracts. |
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| (d) | Contracts. |
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| (e) | Applications. |
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C-1
| (f) | Insurance Company’s Certificate of Incorporation and By-Laws. |
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| (g) | Reinsurance Contracts. |
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| (h) | Participation Agreements. |
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C-3
| (i) | Administrative Contracts. Not applicable. |
| (1) |
| (j) | Other Material Contracts. Not applicable. |
| (k) | Legal Opinion. |
| (1) |
| (l) | Other Opinions. |
| (1) | Consent of Independent Registered Public Accounting Firm, to be filed by amendment. |
| (m) | Omitted Financial Statements. Not applicable. |
| (n) | Initial Capital Agreements. Not applicable. |
| (o) |
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| (q) | Letter Regarding Change in Certifying Accountant. Not Applicable. |
| (r) | Historical Current Limits on Index Gains. Not Applicable. |
C-4
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 BUSINESS ADDRESS |
POSITIONS AND OFFICES WITH THE INSURANCE COMPANY | |
| DIRECTORS |
||
| Douglas A. Dachille |
Director | |
| Legacy Liability Solutions, LLC |
||
| 161 N. Clark Street |
||
| Chicago, IL 60602 |
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| Francis Hondal |
Director | |
| 10050 W. Suburban Drive |
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| Pinecrest, FL 33156 |
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| Arlene Isaacs-Lowe |
Director | |
| 1830 South Ocean Drive, #1411 |
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| Hallandale, FL 33009 |
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| Daniel G. Kaye |
Director | |
| 767 Quail Run |
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| Inverness, IL 60067 |
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| Joan Lamm-Tennant |
Director | |
| 135 Ridge Common |
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| Fairfield, CT 06824 |
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| Craig MacKay |
Director | |
| England & Company |
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| 1133 Avenue of the Americas |
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| Suite 2719 |
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| New York, NY 10036 |
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| Bertram L. Scott |
Director | |
| 3601 Hampton Manor Drive |
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| Charlotte, NC 28226 |
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| George Stansfield |
Director | |
| AXA |
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| 25, Avenue Matignon |
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| 75008 Paris, France |
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| Charles G.T. Stonehill |
Director | |
| Founding Partner |
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| Green & Blue Advisors |
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| 525 Park Avenue, 8D |
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| New York, New York 10065 |
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| OFFICER-DIRECTOR |
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| *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 | |
C-5
| *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 Meyers |
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 | |
C-6
| *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 | |
C-7
| 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:
C-8
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.
C-9
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.
C-10
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 | |
C-11
| *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 | |
C-12
| *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 | |
C-13
| *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. |
Not Applicable.
C-14
| 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 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) | Not Applicable. |
C-15
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 25th 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 25, 2025 |
ATTACHMENTS / EXHIBITS
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