SecProbe.io

April 13, 2011
 Richard J. Carbone Executive Vice President and
Chief Financial Officer
Prudential Financial, Inc.
751 Broad Street
Newark, New Jersey 07102
Re: Prudential Financial, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2010
Filed February 25, 2011 File No. 001-16707

Dear Mr. Carbone:
 We have limited our review of your filing to  those issues we have addressed in our
comments. In our comments, we ask you to provi de us with information to 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 a comment
requests you to revise disclosu re, the information you provide s hould show us what the revised
disclosure will look like and identify the annual or quarterly filing, as applicable, in which you
intend to first include it.  If you do not be lieve a comment applies to your facts and
circumstances, please tell us why in your res ponse.  Please furnish us a letter on EDGAR under
the form type label CORRESP that ke ys your responses to our comments.

After reviewing the information provided, we may have additional comments and/or
request that you amend your filing.

Item 8.  Financial Statements and Supplementary Data

Notes to Consolidated Financial Statements
 2.  Significant Accounting Policies And Pronouncements

Investments and Investment-Rel ated Liabilities, page 268
 1. You state that you account for your investments on the cost basis, where your partnership
interest is so minor (generally less than 3 %) that you exercise virt ually no influence over
operating and financial policies.  Please tell us how you considered the guidance in ASC 944-
325-30-1 and 944-325-35-1 in not accounting fo r these investments on the Fair Value
Method.

Richard J. Carbone
Prudential Financial, Inc.
 April 13, 2011  Page 2

4.  Investments

Commercial Mortgage and Other Loans, page 294
 2. Please revise your disclosure to include the fo llowing for commercial real estate loans that
have been extended at maturity or otherwise restructured for which you have not considered
the loans to be impaired:

• The amount of loans and types of extensions  being made, whether loan terms are being
adjusted from the original terms, and whet her you consider these types of loans as
collateral-dependent;

• To the extent you extend commercial loans at or near maturity at the existing loan rate or
restructure the loan’s interest rate or pr incipal amount, tell us how you consider whether
it is a troubled debt restructuring;

• Your accounting policy for accruing interest income on commercial loans that have been
restructured; and

• For those with a guarantee, separately identify them and disclose:
ƒ How you evaluate the financial wherewithal  of the guarantor, addressing the type
of financial information reviewed, ho w current and objective the information
reviewed is, and how often th e review is performed;
ƒ How many times you have sought performanc e under the guarantee discussing the
extent of the successes.  As part of your response, discuss the decision making
process you go through in deciding whether to pursue the guarantor and whether
there are circumstances you would not seek to enforce the guarantee;
 We urge all persons who are responsible for th e 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 comments, please provi de 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.

Richard J. Carbone
Prudential Financial, Inc.
 April 13, 2011  Page 3

Please contact James Peklenk, Staff Accountant,  at (202) 551-3661 or Mary Mast, Senior
Accountant, at (202) 551-3613 if you have any qu estions regarding the comments.  In this
regard, do not hesitate to contact me, at (202) 551-3679.

Sincerely,    Jim B. Rosenberg Senior Assistant Chief Accountant