SEC Division of Investment Management staff letter: Equitable Life Assurance Society

The staff of the Division of Investment Management will not recommend enforcement action to the Commission against The Equitable Life Assurance Society of the United States, Equitable Variable Life Insurance Company, or Equico Securities, Inc. under Section 5 of the Securities Act of 1933 and Sections 8, 11, and 17 of the Investment Company Act of 1940 if Equitable succeeds to the position of depositor of the Separate Accounts in connection with the merger of Equitable Variable into Equitable. This no-action assurance is contingent upon Equitable filing amendments to registration statements on Form N-8B-2 under the 1940 Act and new registration statements on Form S-6 under the 1933 Act to cover securities transactions effected under the variable life insurance policies after the merger. The staff also indicated it would not recommend enforcement action if Equitable and the Separate Accounts continue to rely on previously granted exemptive orders without filing amended applications, provided the specific representations regarding the merger's impact on the accounts and policies are maintained.

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. ~J.:.,,~~1it.V\ ~V.le The Equitable Life Assurance . - ....:~-~:.:.,::,',...... "'.,,,- ~. . "-,...._.,-~~,"....~~.,,"....,~.,._",. Society of the United States REPONSE OF THE OFFICE OF Equitable Varable Life Insurance INSURCE PRODUCTS Company' DIVISION OF INVESTMENT MANAGEMNT Equico Securities. Inc. By letters dated Decmber 29, 1995, and Decmber 6, 1996, you seek assurace that the sta af the Division of Investment Management wil not recommend enforcement action to the Commission agâist The Equitable Life Assurace Society of the Uïited States ("Equitable"), Equitable Varable Life Insurace Company ("Equitable Varable"), or Equico Securities, Inc. ("Equico") under Section 5 of the Securities Act of 1933, as amended (the "1933 Act"), and Rule 145 thereunder, or Sections 8 and 11 of the Investment Company Act of 1940, as amended (the "1940 Act"), if Equitable succees to the position of depositor of cert separte accounts of Equitable Varable (the "Separte Accounts") in connection with

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