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Correspondence 0001683863-25-006866 from PRUDENTIAL INVESTMENT PORTFOLIOS 12 (CIK 0001051562)

PRUDENTIAL INVESTMENT PORTFOLIOS 12 (CIK 0001051562)
Date: Aug. 20, 2025 · CIK: 0001051562 · Accession: 0001683863-25-006866

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File numbers found in text: 811-03712, 811-04930, 811-06677, 811-08565, 811-09805, 811-09999

Date
August 20, 2025
Author
Exhibit A
Form
CORRESP
Company
PRUDENTIAL INVESTMENT PORTFOLIOS 12 (CIK 0001051562)

Letter

Multi-Fund Correspondence

PGIM Funds 655 Broad Street Newark, New Jersey 07102 August 20, 2025 VIA EDGAR SUBMISSION Ms. Christina Fettig Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: PGIM Mutual Funds Dear Ms. Fettig: On July 31, 2025, you provided comments to the undersigned relating to the review by the staff (the “Staff”) of the Securities and Exchange Commission (“SEC”) of certain web pages, shareholder reports and registration statement filings for various series of investment company registrants, which are collectively known as the PGIM Funds (each of which may be referred to as a “Fund” and collectively as the “Funds”). The specific Funds covered by the Staff’s review are listed in Exhibit A to this letter. This letter responds to your comments. For your convenience and reference, I have summarized the comments in this letter and provided the Funds’ response below each such comment. 1. Comment : On the PGIM Fund Documents web page, please remove the “Money Market” designation under PGIM Core Ultra Short Bond Fund. Response: The Fund will update this disclosure accordingly. 2. Comment: On the PGIM Government Money Market Fund and PGIM Core Government Money Market Fund web pages, please update the “10% Daily Requirement” in the legend under the Daily Liquid Assets charts to read “25% Daily requirement,” and please update the “30% Weekly Requirement” in the legend under the Weekly Liquid Assets charts to read “50% Daily requirement.” Response: The Funds will update this disclosure accordingly. 3. Comment: Going forward please include a brief description of any investments categorized as “Other Instrument” in the monthly portfolio holdings of money market funds. Response : The monthly portfolio holdings of money market funds will include a brief description of any investments categorized as “Other Instrument” going forward. 4. Comment: PGIM Investments LLC is identified in the Notes to Financial Statements of the Funds’ Form N-CSR as the Funds’ chief operating decision maker (“CODM”). Please explain how all personnel of PGIM Investments LLC are considered a group for purpose of the CODM definition. Alternatively, please identify an individual or a more specific group within PGIM Investments LLC as the CODM in future filings. Response: In future filings the Funds will identify a more specific group within PGIM Investments LLC, or an individual, as the CODM.

5. Comment: Please explain whether a collateralized loan obligation-specific risk should be included in the Summary Prospectus of the PGIM Securitized Credit Fund. Response: The Fund will consider the Staff’s comment, and based on investment exposures and expectations going forward, the Fund may include disclosure around collateralized loan obligations in the Principal Risks section of its Summary Prospectus at the time of the Fund’s next annual update to its registration statement. 6. Comment: The fee tables of each of the Retirement Spending Funds include a footnote indicating that “other expenses have been updated from the most recent annual report to reflect current expenses.” Please explain in correspondence the nature of these updates. Response: Offering costs paid in connection with the initial offering of shares of the Fund are non- recurring expenses and as such were excluded from other expenses. 7. Comment: Please confirm whether the footnote to the PGIM Securitized Credit Fund’s fee table indicating that “other expenses have been updated from the most recent annual report to reflect current expenses” is accurate. Response : This footnote was included in error. In future filings, it will be updated as appropriate. If you have any questions or comments with respect to the foregoing, or if I can be of any further assistance in facilitating the Staff’s review, please contact me at 973-716-6422 or patrick.mcguinness@prudential.com . Thank you for your consideration and assistance in this matter. Sincerely yours, /s/ Patrick McGuinness Patrick McGuinness Director, Corporate Counsel

Exhibit A

File # Registrant Name Series Name FYE

Reviewed

811-08565 PRUDENTIAL INVESTMENT PGIM CONSERVATIVE RETIREMENT 3/31/2025

PORTFOLIOS 12 SPENDING FUND

811-08565 PRUDENTIAL INVESTMENT PGIM ENHANCED RETIREMENT 3/31/2025

PORTFOLIOS 12 SPENDING FUND

811-08565 PRUDENTIAL INVESTMENT PGIM MODERATE RETIREMENT 3/31/2025

PORTFOLIOS 12 SPENDING FUND

811-08565 PRUDENTIAL INVESTMENT PGIM SHORT DURATION MUNI 3/31/2025

PORTFOLIOS 12 FUND

811-08565 PRUDENTIAL INVESTMENT PGIM US REAL ESTATE FUND 3/31/2025

PORTFOLIOS 12

811-09999 PRUDENTIAL INVESTMENT PGIM CORE ULTRA SHORT BOND 1/31/2025

PORTFOLIOS 2 FUND

811-09999 PRUDENTIAL INVESTMENT PGIM INSTITUTIONAL MONEY 1/31/2025

PORTFOLIOS 2 MARKET FUND

811-09805 PRUDENTIAL INVESTMENT PGIM JENNISON FOCUSED GROWTH 2/28/2025

PORTFOLIOS 3 FUND

811-09805 PRUDENTIAL INVESTMENT PGIM QUANT SOLUTIONS LARGE- 2/28/2025

PORTFOLIOS 3 CAP VALUE FUND

811-09805 PRUDENTIAL INVESTMENT PGIM STRATEGIC BOND FUND 2/28/2025

PORTFOLIOS 3

811-04930 PRUDENTIAL INVESTMENT PGIM MUNI HIGH INCOME FUND 8/31/2024

PORTFOLIOS 4

811-06677 PRUDENTIAL INVESTMENT PGIM QUANT SOLUTIONS LARGE- 9/30/2024

PORTFOLIOS 8 CAP INDEX FUND

811-06677 PRUDENTIAL INVESTMENT PGIM SECURITIZED CREDIT FUND 9/30/2024

PORTFOLIOS 8

811-03712 PRUDENTIAL INVESTMENT PGIM FLOATING RATE INCOME 2/28/2025

PORTFOLIOS, INC. 14 FUND

811-03712 PRUDENTIAL INVESTMENT PGIM GOVERNMENT INCOME FUND 2/28/2025

PORTFOLIOS, INC. 14

Show Raw Text
CORRESP
 1
 filename1.htm

 Multi-Fund Correspondence

 PGIM Funds
 655 Broad Street
 Newark, New Jersey 07102
 August 20, 2025
 VIA EDGAR SUBMISSION
 Ms. Christina Fettig
 Securities and Exchange Commission
 100 F Street, NE
 Washington, D.C. 20549
 Re: PGIM Mutual Funds
 Dear Ms. Fettig:
 On July 31, 2025, you provided comments to the undersigned relating to the review by the staff (the “Staff”) of the Securities and Exchange Commission (“SEC”) of certain web pages, shareholder reports and registration statement filings for various series of investment company registrants, which are collectively known as the PGIM Funds (each of which may be referred to as a “Fund” and collectively as the “Funds”). The specific Funds covered by the Staff’s review are listed in Exhibit A to this letter.
 This letter responds to your comments. For your convenience and reference, I have summarized the comments in this letter and provided the Funds’ response below each such comment.
 1. Comment : On the PGIM Fund Documents web page, please remove the “Money Market” designation under PGIM Core Ultra Short Bond Fund.
 Response: The Fund will update this disclosure accordingly.
 2. Comment: On the PGIM Government Money Market Fund and PGIM Core Government Money Market Fund web pages, please update the “10% Daily Requirement” in the legend under the Daily Liquid Assets charts to read “25% Daily requirement,” and please update the “30% Weekly Requirement” in the legend under the Weekly Liquid Assets charts to read “50% Daily requirement.”
 Response: The Funds will update this disclosure accordingly.
 3. Comment: Going forward please include a brief description of any investments categorized as “Other Instrument” in the monthly portfolio holdings of money market funds.
 Response : The monthly portfolio holdings of money market funds will include a brief description of any investments categorized as “Other Instrument” going forward.
 4. Comment: PGIM Investments LLC is identified in the Notes to Financial Statements of the Funds’
 Form N-CSR as the Funds’ chief operating decision maker (“CODM”). Please explain how all personnel of PGIM Investments LLC are considered a group for purpose of the CODM definition. Alternatively, please identify an individual or a more specific group within PGIM Investments LLC as the CODM in future filings.
 Response: In future filings the Funds will identify a more specific group within PGIM Investments LLC, or an individual, as the CODM.

 5. Comment: Please explain whether a collateralized loan obligation-specific risk should be included in the Summary Prospectus of the PGIM Securitized Credit Fund.
 Response: The Fund will consider the Staff’s comment, and based on investment exposures and expectations going forward, the Fund may include disclosure around collateralized loan obligations in the Principal Risks section of its Summary Prospectus at the time of the Fund’s next annual update to its registration statement.
 6. Comment: The fee tables of each of the Retirement Spending Funds include a footnote indicating that “other expenses have been updated from the most recent annual report to reflect current expenses.” Please explain in correspondence the nature of these updates.
 Response: Offering costs paid in connection with the initial offering of shares of the Fund are non- recurring expenses and as such were excluded from other expenses.
 7. Comment: Please confirm whether the footnote to the PGIM Securitized Credit Fund’s fee table indicating that “other expenses have been updated from the most recent annual report to reflect current expenses” is accurate.
 Response : This footnote was included in error. In future filings, it will be updated as appropriate.
 If you have any questions or comments with respect to the foregoing, or if I can be of any further assistance
 in facilitating the Staff’s review, please contact me at 973-716-6422 or patrick.mcguinness@prudential.com . Thank you for your consideration and assistance in this matter.
 Sincerely yours,
 /s/ Patrick McGuinness Patrick McGuinness Director, Corporate Counsel
 2

 Exhibit A

 File #
 Registrant Name
 Series Name
 FYE

 Reviewed

 811-08565
 PRUDENTIAL INVESTMENT
 PGIM CONSERVATIVE RETIREMENT
 3/31/2025

 PORTFOLIOS 12
 SPENDING FUND

 811-08565
 PRUDENTIAL INVESTMENT
 PGIM ENHANCED RETIREMENT
 3/31/2025

 PORTFOLIOS 12
 SPENDING FUND

 811-08565
 PRUDENTIAL INVESTMENT
 PGIM MODERATE RETIREMENT
 3/31/2025

 PORTFOLIOS 12
 SPENDING FUND

 811-08565
 PRUDENTIAL INVESTMENT
 PGIM SHORT DURATION MUNI
 3/31/2025

 PORTFOLIOS 12
 FUND

 811-08565
 PRUDENTIAL INVESTMENT
 PGIM US REAL ESTATE FUND
 3/31/2025

 PORTFOLIOS 12

 811-09999
 PRUDENTIAL INVESTMENT
 PGIM CORE ULTRA SHORT BOND
 1/31/2025

 PORTFOLIOS 2
 FUND

 811-09999
 PRUDENTIAL INVESTMENT
 PGIM INSTITUTIONAL MONEY
 1/31/2025

 PORTFOLIOS 2
 MARKET FUND

 811-09805
 PRUDENTIAL INVESTMENT
 PGIM JENNISON FOCUSED GROWTH
 2/28/2025

 PORTFOLIOS 3
 FUND

 811-09805
 PRUDENTIAL INVESTMENT
 PGIM QUANT SOLUTIONS LARGE-
 2/28/2025

 PORTFOLIOS 3
 CAP VALUE FUND

 811-09805
 PRUDENTIAL INVESTMENT
 PGIM STRATEGIC BOND FUND
 2/28/2025

 PORTFOLIOS 3

 811-04930
 PRUDENTIAL INVESTMENT
 PGIM MUNI HIGH INCOME FUND
 8/31/2024

 PORTFOLIOS 4

 811-06677
 PRUDENTIAL INVESTMENT
 PGIM QUANT SOLUTIONS LARGE-
 9/30/2024

 PORTFOLIOS 8
 CAP INDEX FUND

 811-06677
 PRUDENTIAL INVESTMENT
 PGIM SECURITIZED CREDIT FUND
 9/30/2024

 PORTFOLIOS 8

 811-03712
 PRUDENTIAL INVESTMENT
 PGIM FLOATING RATE INCOME
 2/28/2025

 PORTFOLIOS, INC. 14
 FUND

 811-03712
 PRUDENTIAL INVESTMENT
 PGIM GOVERNMENT INCOME FUND
 2/28/2025

 PORTFOLIOS, INC. 14

 3