SEC Comment Letter for PRUDENTIAL FINANCIAL INC (PFH, PRH, PRS, PRU) (CIK 0001137774) (PFH) — Dec 2, 2011

PRUDENTIAL FINANCIAL INC (PFH, PRH, PRS, PRU) (CIK 0001137774)
Date: Dec. 2, 2011 · CIK: 0001137774 · Accession: 0000000000-11-069577

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File numbers found in text: 001-16707

Date

December 2, 2011

Author

A c c o u n t i n g B r a n c h C h i e f

Form

UPLOAD

Company

PRUDENTIAL FINANCIAL INC (PFH, PRH, PRS, PRU) (CIK 0001137774)

Letter

December 2, 2011 Via E-mail Peter Sayre Senior Vice President and Principal Accounting 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. Sayre: We have completed our review of your f iling. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or the filings and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi lings to be certain that the filings include the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/ s / J o e l P a r k e r
Joel Parker
A c c o u n t i n g B r a n c h C h i e f

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December 2, 2011

Via E-mail
Peter Sayre Senior Vice President and
Principal Accounting 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. Sayre:
 We have completed our review of your f iling.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or the filings and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi lings to be certain that the filings include the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
        / s /  J o e l  P a r k e r
Joel Parker
        A c c o u n t i n g  B r a n c h  C h i e f

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