Prudential PLC — Regulatory Filings 2022

Jul 27, 2022

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July 27, 2022 Prudential plc 1 Angel Court london ec2r 7aG www.prudentialplc.com

BY EDGAR Division of Corporation Finance Office of Finance Securities and Exchange Commission Washington, D.C. 20549 United States

Attention:
Michael Volley

Re:
Form 20-F for Fiscal Year Ended December 31, 2021
Filed March 17, 2022
File No. 001-15040

Dear Mr. Spitz and Mr. Volley:

By letter dated July 12, 2022, the staff (the “ Staff ”) of the Securities and Exchange Commission (the “ SEC ”) provided certain comments on Prudential plc’s (the “ Company ” or “ Prudential ”) Annual Report on Form 20-F for Fiscal Year Ended December 31, 2021 (the “2021 Form 20-F”) filed on March 17, 2022, in particular by reference to the ‘Determining Adjusted Operating Profit of Operating Segments’ section on page 33 of the 2021 Form 20-F.

Upon reflection of the Staff’s comments, Prudential proposes to revise its future Form 20-F filings to remove the disclosure of the total Group adjusted operating profit based on longer-term investment returns (‘Group adjusted operating profit’) in the management discussion and analysis (MD&A) section of the filings. Prudential proposes to remove Group adjusted operating profit from both the tables and the associated narrative commentary.

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Thank you for your prompt attention to the Company’s response to the Staff’s comments. If you have any further questions, please contact Rebecca Wyatt (Chief of Financial & Capital Reporting), whose contact details are included at the foot of this letter, to assist you as required.

Yours faithfully

/s/ James Turner

James Turner

Group Chief Financial Officer

Prudential plc

cc:
(rebecca.wyatt@prudentialplc.com, telephone + 44 20 3977 9768)
Timothy Corbett, Morgan Lewis & Bockius LLP

Prudential plc, 1 Angel Court, London, EC2R 7AG. Incorporated and registered in England and Wales. Registered Office as above. Registered number 1397169. Prudential plc is a holding company, some of whose subsidiaries are authorised and regulated, as applicable, by the Hong Kong Insurance Authority and other regulatory authorities.

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