Separate Account 4 of Axa Equitable Life Insurance Co – ‘N-3’ on 4/30/07 – EX-99.12BB

On:  Monday, 4/30/07, at 3:29pm ET   ·   Accession #:  771726-7-200   ·   File #:  333-142461

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Registration Statement for a Separate Account (Management Investment Company)   —   Form N-3
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: N-3         Registration Statement for a Separate Account        632   4.24M 
                          (Management Investment Company)                        
 3: EX-99.12BB  Legal Opinion                                          2±    10K 
 4: EX-99.13AI  Consent of Pricewaterhousecooper LLP                   1      6K 
 5: EX-99.13AII  Consent of Kpmg LLP                                   1      7K 
 6: EX-99.13D   Powers of Attorney                                    45    160K 
 2: EX-99.6B    Form of Rider 15                                       3      9K 

EX-99.12BB   —   Legal Opinion

                                                       EPUB RIDER: LEGAL OPINION

                                                                      DODIE KENT
                                                              Vice President and
                                                       Associate General Counsel
                                                                  (212) 314-3970
                                                             Fax: (212) 707-1791

                                                                  LAW DEPARTMENT
[AXA EQUITABLE LOGO]                                                            

April 27, 2007

VIA EDGAR                                                                       

AXA Equitable Life Insurance Company                                            

1290 Avenue of the Americas                                                     

New York, New York 10104                                                        

Dear Sirs:                                                                      

This opinion is furnished in connection with the Form N-3 and Form N-4
Registration Statements of AXA Equitable Life Insurance Company ("AXA           
Equitable") under the Securities Act of 1933, as amended (the "Act"), relating  
to separate account units of interest ("Units") under group annuity contracts   
issued by AXA Equitable in connection with certain American Dental Association  
retirement plans, certain retirement plans under the Retirement Investment      
Account program and certain retirement plans under the Members Retirement       
Program (the "Contracts") (the separate accounts related to the Contracts,      
separate account numbers 3, 4, 10, 13, 66, 191, 200 and 206, being referred to  
herein collectively as the "Separate Accounts"). The securities being registered
are to be offered in the manner described in the Registration Statements        
covering the Units and the Contracts.                                           

I have examined all such corporate records of AXA Equitable and such other      
documents and such laws as I consider appropriate as a basis for the opinion    
hereinafter expressed. On the basis of such examination, it is my opinion that: 

1. AXA Equitable is a corporation duly organized and validly existing under the 
laws of the State of New York.                                                  

2. The Separate Accounts have been duly created pursuant to the provisions of   
the New York Insurance Law.                                                     

3. The assets of the Separate Accounts are owned by AXA Equitable; AXA Equitable
is not a trustee with respect thereto. Under New York law, the income, gains and
losses, whether or not realized, from assets allocated to a Separate Account    
must be credited to or charged against such Separate Account, without regard to 
the other income, gains or losses of AXA Equitable.                             

4. The Contracts provide that the portion of the assets of the Separate Accounts
equal to the reserves and other contract liabilities with respect to the        
Separate Account shall not be chargeable with liabilities arising out of any    
other business AXA Equitable may conduct.                                       

5. The Contracts and the Units issued thereunder have been duly authorized; and 
the Contracts (including the Units duly issued thereunder) constitute validly   
issued and binding obligations of AXA Equitable in accordance with their terms. 

I hereby consent to the use of this opinion as an exhibit to the Registration   
Statement.                                                                      

                                           Very truly yours,

                                        /s/ Dodie Kent

                                                 _______________________

                                    Dodie Kent

Dates Referenced Herein

This ‘N-3’ Filing		Date		Other Filings
Filed on:		4/30/07		None on these Dates
		4/27/07
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