SecProbe.io

June 10, 2010
 Richard J. Carbone Executive Vice President Prudential Financial, Inc. 751 Broad Street Newark, New Jersey 07102
Re: Prudential Financial, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2009 Filed February 26, 2010
  File No. 001-16707

Dear Mr. Carbone:
 We have limited our review of your filing to  those issues we have addressed in our
comment.  In our comment, we ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  Where our comment requests you to revise disclosure, the in formation you provide should show us what the
revised disclosure will look like and identify th e annual or quarterly filing, as applicable, in
which you intend to first include it.  Please furnish us a letter on EDGAR under the form type
label CORRESP that keys your responses to our  comment.  If you do not  believe our comment
applies to your facts and circumstances,  please tell us why in your response.

After reviewing the information you provide in  response to this comment, we may have
additional comments and/or requ est that you amend your filing.
 Notes to Consolidated Financial Statements, page 247

4.  Investments, page 273

1. Please revise your note disclosure to state the name of each person in which the total
amount invested in the person and its aff iliates exceeds 10% of your total stockholders’
equity.  Separately disclose the name and a ggregate amount invested as recorded in your
Consolidated Statements of Financial Po sition (e.g., amounts in fair value terms for
available for sale securities, and amounts in amortized cost terms for held to maturity
securities).  In your revised disclosure, pl ease address your concentration in Japanese
government bonds that you reference on page 164.  Refer to note (6) of Rule 7-03(a)(1)
of Regulation S-X.

Richard J. Carbone
Prudential Financial, Inc. June 10, 2010 Page 2

             We urge all persons who are res ponsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.                In responding to our comment, please provide a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact Staci Shannon, Staff Accountant, at (202) 551-3374 or Lisa Vanjoske,
Assistant Chief Accountant, at  (202) 551-3614 if you have questi ons regarding the comment.
Please contact me at (202) 551-3679 with any other questions.
Sincerely,

Jim B. Rosenberg
Senior Assistant Chief Accountant