SecProbe.io

Via Facsimile and U.S. Mail Mail Stop 6010              March 21, 2008   Mr. Richard J. Carbone Executive Vice President and Chief Financial Officer Prudential Financial, Inc. 751 Broad Street Newark, NJ  07102

Re: Prudential Financial, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2007  File No. 1-16707

Dear Mr. Carbone:

We have reviewed your filing and have the following comments.  We have
limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to  other portions of your documents.  In our comments, we
ask you to provide us with information to better understand your disclosure.  Where a comment requests you to revise disclosure, the information you provide should show us
what the revised disclosure will look like a nd identify the annual or quarterly filing, as
applicable, in which you intend to first incl ude it.  If you do not believe that revised
disclosure is necessary, e xplain the reason in your res ponse.  After reviewing the
information provided, we may raise additional comments and/or request that you amend your filing.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Richard J. Carbone
Prudential Financial, Inc.
March 21, 2008
Page 2
Form 10-K for the fiscal year ended December 31, 2007

Financial Statements

Note 4:  Investments, page 197
 1. It is apparent that you invest signif icantly in mortgage- and asset-backed
securities.  It is also apparent from your disclosures in MD&A beginning on page
125 that some of your investment in these securities could be categorized as being
of high credit quality while others woul d not.  Please revise your policy note
disclosure to indicate how you account fo r these types of investments.  Please
ensure this disclosure discusses how you record interest income and how you
account for estimated prepayments, if app licable, and separately reference for us
the authoritative literature you rely u pon to support your accounting.  To the
extent you rely on SFAS 91, please disclose the significant assumptions underlying your prepayment estimates as  required by para graph 19 of that
guidance.
 Note 17:  Income Taxes, page 247

 2. Please revise your disclosure to provide the domestic and foreign components of
your pre-tax income as required by Item 4-08(h)(1)(i) of Regulation S-X.
 Note 20:  Segment Information, page 256

 3. Please revise your disclosure to provide: a. your revenues by each product or group of similar product as required by paragraph 37 of SFAS 131; and
b. your revenues by country or an indicati on why it is impracticable to provide
this information as required by paragraph 38 of SFAS 131.

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please s ubmit a letter that keys your responses to our
comments and provides the requested information.  Detailed letters greatly facilitate our
review.  Please furnish your letter to us via EDGAR under the form type label
CORRESP.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Mr. Richard J. Carbone
Prudential Financial, Inc.
March 21, 2008 Page 3   In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:  ‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
‚ the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 If you have any questions, please co ntact Mark Brunhofer , Senior Staff
Accountant, at (202) 551-3638.  In  this regard, do not hesita te to contact me, at (202)
551-3679.
Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant