Eq Advisors Trust CORRESPCorrespondence with SEC

July 1, 2021

VIA EDGAR AND E-MAIL

Ms. Elisabeth Bentzinger

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Dear Ms. Bentzinger:

On behalf of EQ Advisors Trust (the “Trust”), set forth below are comments that you provided on June 4, 2021, concerning Post-Effective Amendment No. 153 to the Trust’s Registration Statement on Form N-1A (the “Post-Effective Amendment”). The Post-Effective Amendment was filed with the U.S. Securities and Exchange Commission on April 23, 2021, pursuant to the Securities Act of 1933, as amended, and Rule 485(a) of Regulation C thereunder, and pursuant to the Investment Company Act of 1940, as amended (the “1940 Act”), and the regulations thereunder. Your comments are set forth in italics and are followed by the Trust’s responses. Unless otherwise noted, defined terms have the same meanings as in the Post-Effective Amendment.

Response: The Trust confirms that the index names used in the summary prospectus are the names in common usage, including by Bloomberg, in other funds’ prospectuses, and on industry and general reference websites. Accordingly, the Trust has not modified the index names in the prospectus. Please note that the indexes are also referenced on the Bloomberg website as “Bloomberg Barclays US Long Gov/Credit Float Adjusted TR Index Unhedged USD” and “Bloomberg Barclays US Agg Total Return Value Unhedged USD” respectively, but these names are not in common usage.

K&L GATES LLP

1601 K STREET NW WASHINGTON DC 20006

T +1 202 778 9000 F +1 202 778 9100 klgates.com

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Response: The completed fee table and expense example for Class IB and K shares of the Portfolio are attached to this letter as Appendix A. Please note that the Portfolio will not issue Class IA shares, and the Trust will revise the Portfolio’s prospectus and statement of additional information to remove references to Class IA shares.

Response: The Trust has revised the “Principal Investment Strategies of the Portfolio” to add the following:

The Portfolio may invest in U.S. interest rate futures contracts, a type of derivative, to manage portfolio duration and to hedge against changes in interest rates.

In addition, the Trust has revised the Item 4 disclosure to include a description of “Derivatives Risk.”

Response: The Trust has clarified the “Principal Investment Strategies of the Portfolio” as follows:

The Portfolio uses a strategy that is commonly referred to as an index strategy. In seeking to achieve the Portfolio’s investment objective, the Sub-Adviser generally will employ a stratifiedsample sampling approach to build a portfolio whose broad characteristics match those of the Long Government/Credit Index, which means that the Portfolio is not required to purchase all of the securities represented in the Index.This strategy is commonly referred to as an indexing strategy. A stratified sampling approach seeks to match the return and characteristics of a particular index without having to purchase every security in that index by selecting a representative sample of securities for the Portfolio based on the characteristics of the index and the particular securities included therein. With respect to the Long Government/Credit Index, such characteristics may include interest rate sensitivity, credit quality and sector diversification.

Response: The “non-securitized component” of the Bloomberg Barclays US Aggregate Bond Index excludes mortgage-backed securities, asset-backed securities and commercial mortgage-backed securities, and includes treasuries, government-related, and corporate securities. The Trust has revised the referenced disclosure as follows:

The Long Government/Credit Indexis a broad-based flagship benchmark that measures the non-securitized component of the Bloomberg Barclays US Aggregate Bond Indexincludes investment grade, U.S. dollar-denominated, fixed-rate treasuries, government-related and corporate securities with 10 or more years to maturity. The Index includes investment grade, U.S. dollar-denominated, fixed-rate treasuries, government-related and corporate securities. components are a subset of issues in the Bloomberg Barclays US Aggregate Bond Index.

U.S. Securities and Exchange Commission

July 1, 2021

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Response: The “Principal Investment Strategies of the Portfolio” section of the prospectus in the Post-Effective Amendment states that the Sub-Adviser will employ an index strategy. Nevertheless, the Trust will clarify the disclosure as follows:

The Portfolio uses a strategy that is commonly referred to as an index strategy. In seeking to achieve the Portfolio’s investment objective, the Sub-Adviser generally will employ a stratifiedsample sampling approach to build a portfolio whose broad characteristics match those of the Long Government/Credit Index, which means that the Portfolio is not required to purchase all of the securities represented in the Index.This strategy is commonly referred to as an indexing strategy.

Response: The Trust has revised the “Principal Investment Strategies of the Portfolio” to include the following statement: “The Portfolio will normally maintain a dollar-weighted average maturity of more than ten years, which is consistent with that of the Index.”

Response: The Trust will revise the principal strategy disclosure to state as follows: “The Portfolio will concentrate its investments (i.e., invest 25% or more of its total assets) in securities of issuers in a particular industry or group of industries to approximately the same extent that the Long Government/Credit Index is concentrated. As of the date of this Prospectus, the Index is not concentrated in any industry.” The Trust notes that the Index currently has a greater than 25% allocation to U.S. treasuries; however, as noted in the Statement of Additional Information, securities issued or guaranteed by the U.S. government are not considered to be part of an industry.

Response: As stated in the Portfolio’s prospectus summary, securities eligible for the Long Government/Credit Index must have a maturity of 10 years or greater. Please also see the response to g. above. The Trust will revise the principal strategy disclosure to state as follows: “The Portfolio will normally maintain an average duration consistent with that of the Index.”

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July 1, 2021

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Response: The eligibility criteria for securities included in the Index are currently described in the summary prospectus (i.e., investment grade, U.S. dollar-denominated, fixed-rate treasuries, government-related and corporate securities). The Trust will revise the summary prospectus to disclose that (1) the Index is rebalanced monthly; (2) the Index currently includes more than 2,900 bonds; and (3) Index components are weighted based on market value, taking into account the component security’s price, accrued interest and par amount outstanding.

Response: The Trust notes that the “Interest Rate Risk” disclosure in the Portfolio’s summary prospectus currently states: “Very low or negative interest rates may magnify interest rate risk. A significant or rapid rise in interest rates also could result in losses to the Portfolio.” Accordingly, the risks of a low interest rate environment currently are disclosed. Further, the additional discussion in the corresponding risk factor in the statutory prospectus provides that “[i]nterest rates in the United States currently are at or near historic lows due to market forces and actions of the U.S. Federal Reserve” and that “[c]hanging interest rates, including rates that fall below zero, may have unpredictable effects on markets, may result in heightened market volatility and may detract from Portfolio performance.” The Trust believes that the risk disclosure is adequate and respectfully submits that no revisions are necessary.

Response: The Trust believes that the Portfolio’s Index constitutes a “broad-based securities market index” as defined in Item 27(b), Instruction 5, of Form N-1A. According to the relevant instruction in Form N-1A, a “broad-based securities marked index is one that is administered by an organization that is not an affiliated person of the Fund, its investment adviser, or principal underwriter, unless the index is widely recognized and used.” Bloomberg Barclays Indices, the index provider for the Index, is not affiliated with the Trust, the Adviser, or the Trust’s principal underwriter. Based on available SEC guidance discussed below regarding the meaning of “broad-based,” the Trust believes the Index is consistent with the applicable requirements of Form N-1A.

The SEC has stated that “[a] broad-based index is one that provides investors with a performance indicator of the overall applicable stock or bond markets, as appropriate,” adding that “[an] index would not be considered to be broad-based if it is composed of securities of firms in a particular industry or group of related industries.”¹ Further, Form N-1A “gives a fund considerable flexibility in selecting a broad-based index that it believes best reflects the market(s) in which it invests.”² The SEC has also stated that the “purpose of including return information for a broad-based securities market index was to provide investors with a basis for evaluating a fund’s performance and risks relative to the market.”³

The Portfolio’s Index tracks the market for investment grade, US dollar-denominated, fixed-rate treasuries, government-related and corporate securities. Further, the Index is not concentrated in

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any particular industry or group of industries, and indeed is broadly diversified, consisting of over 2,900 bond issues ranging across government and corporate markets. The Portfolio is a passively managed fund designed to track the Index, and therefore, investors would find it particularly relevant to know how the Portfolio’s performance compares to the index that it seeks to track. This approach is also in line with other bond funds that follow an index strategy to track a sub-set of the broadest measure of the bond market.⁴ Based on the aforementioned information and guidance, the Trust believes that the Index is “broad-based” and best reflects the market in which the Portfolio invests.

Response: The Trust is not aware of any specific requirement under the federal securities laws or a formal SEC position requiring an investment company to “look through” to the securities held by an underlying fund when determining the investment company’s compliance with Rule 35d-1 under the 1940 Act. The Trust notes, however, that because it will limit its investments in other investment companies to those investment companies that have adopted similar investment strategies and restrictions, investments in such investment companies generally will not cause the Portfolio to violate its own 80% policy. The Trust respectfully submits that no revisions are required.

Response: The Trust confirms that it currently values any derivatives at mark to market value for purposes of determining compliance with the Portfolio’s 80% investment policy pursuant to Rule 35d-1. The Trust notes, however, that the SEC has not provided definitive guidance as to how to calculate the asset value of derivatives for purposes of measuring compliance with a fund’s 80% investment policy adopted pursuant to Rule 35d-1. The Trust believes that the use of notional value rather than mark to market value may be an acceptable way to value certain derivatives where a fund’s investment exposure to the underlying asset is equal to the notional value of the derivative. The Trust respectfully declines to add disclosure stating that derivatives are valued on a mark to market basis rather than notional value for purposes of calculating compliance with the Portfolio’s 80% investment policy.

U.S. Securities and Exchange Commission

July 1, 2021

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Form N-1A requires that the Item 4 disclosure should be based on Item 9 disclosure. The approach here does not appear to match the Item 4 disclosure in the summary. Please revise the Item 9 disclosure so that what the Portfolio discloses in Item 4 is actually a summary of the Item 9 disclosure.

Response: The Trust notes that, as required by Item 4 of Form N-1A, the summary prospectus for each Portfolio describes the Portfolio’s principal investment strategies. Additional information associated with the Portfolios’ principal strategies is described within the statutory prospectus. The “More Information about Investment Strategies & Risks” section of the statutory prospectus affirms that the Portfolio’s principal strategies are discussed in the summary prospectus. General Instruction C.(3)(a) of Form N-1A provides that “[i]nformation that is included in Items 2 through 8 need not be repeated elsewhere in the prospectus.” The Trust submits that the information disclosed in response to Item 4 need not be identified again as a principal strategy or a principal risk in response to Item 9(b). In addition, The Trust submits that the Item 4 disclosure included in the summary prospectus is a summary of the Portfolio’s principal strategies and risks based on the Item 9 disclosure; however, the Item 4 disclosure is not required to include or repeat all of the disclosure that is included in response to Item 9.

Response: The Trust has revised the Item 9 disclosure to state the following:

Portfolio Turnover. The Portfolio does not restrict the frequency of trading to limit expenses. While the Portfolio is not expected to have high portfolio turnover, the Portfolio may engage in active and frequent trading of portfolio securities to achieve its investment objective. Frequent trading can result in a portfolio turnover in excess of 100% (high portfolio turnover). A high turnover may result in a greater amount of capital gain distributions to Portfolio shareholders than if the Portfolio had low portfolio turnover, and may generate a greater amount of capital gain distributions to Portfolio shareholders than if the Portfolio had low portfolio turnover.

Response: The Trust notes that, as required by Item 4 of Form N-1A, the Portfolios’ principal risks are identified in the summary prospectus. The “More Information on Investment Strategies & Risks” section of the statutory prospectus affirms that the Portfolio’s principal risks are discussed in the summary prospectus. In addition, this section includes a separate sub-section for principal investment risks, which provides additional information about the Portfolio’s principal risks identified in the summary prospectus, and separate subsections for “Additional Information about Risks,” which provides additional information that may be associated with the Portfolios’ principal risks but that may not be principal to a Portfolio’s investment strategies, and “General Investment Risks.” The Trust believes this approach is permissible under General Instruction C of Form N-1A, which provides that “[a] Fund may include, except in response to Items 2 through 8, information in the prospectus or the SAI that is not otherwise required” so long as the information does not impede understanding of the information that is required to be included.

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Response: The Trust believes that the statement in fundamental restriction (4) complies with Item 16 of Form N-1A, and therefore the Trust declines to revise the fundamental restriction. The Trust notes that per Item 16(c)(1)(iv) of Form N-1A, the Portfolio is required to disclose its policy with respect to concentrating investments in a particular industry or group of industries. Fundamental restriction (4) provides that the Portfolio will not concentrate its investments in a particular industry or group of industries. As noted in response to comment 1.h. above, the Index is not concentrated.

Response: The Trust is not aware of any SEC requirement to “look through” to the securities held by an underlying fund when monitoring a Portfolio’s industry concentration limit. The Trust respectfully submits that no further revisions are required.

Response: The Trust respectfully notes that it does not believe that the licensing agreement between the Adviser and index provider (to which the Trust is not a party) falls within the meaning of “other material contracts” set forth in Form N-1A, Item 28(h). Accordingly, the Trust has not included the licensing agreement as an exhibit to the Trust’s Registration Statement.

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If you have any questions or comments regarding the foregoing, please contact me at (202) 778-9351.

Sincerely,

Mark C. Amorosi

Maureen Kane, Esq.

Kiesha T. Astwood-Smith, Esq.

Victoria Zozulya, Esq.

Equitable Investment Management Group, LLC

Fatima Sulaiman, Esq.

K&L Gates LLP

APPENDIX A

COMPLETED FEE TABLE AND EXPENSE EXAMPLE

EQ/Long-Term Bond Portfolio