| August 16, 2010 | ||
| By EDGAR | ||
| Securities and Exchange Commission | ||
| Division of Corporation Finance | ||
| 100 F Street, N.E. | ||
| Washington D.C. 20549 | ||
| Attention: | Mr. Jim Rosenberg, | |
| Senior Assistant Chief Accountant | ||
| Re: | Principal Financial Group, Inc. | |
| Form 10-K for the Fiscal Year Ended December 31, 2009 | ||
| Form 10-Q for the Quarterly Period Ended March 31, 2010 | ||
| File No. 001-16725 | ||
| Dear Mr. Rosenberg: | ||
| This letter supplements the response of Principal Financial Group, Inc. to the comments of the | ||
| Division of Corporation Finance of the Securities and Exchange Commission contained in your | ||
| letter dated June 29, 2010, concerning the company’s annual report on Form 10-K and quarterly | ||
| report on Form 10-Q, both referenced above. Our response was dated and filed via EDGAR on | ||
| August 13, 2010, and inadvertently failed to include the following language. | ||
| We acknowledge that we are responsible for the adequacy and accuracy of the disclosure | ||
| contained in our periodic reports filed pursuant to the Securities Exchange Act of 1934, and that | ||
| your comments or our changes to disclosure in response to your comments do not foreclose the | ||
| Commission from taking any action with respect to our reports. Further, we acknowledge that | ||
| we may not assert your comments as a defense in any proceeding initiated by the Commission or | ||
| any person under the federal securities laws of the United States. | ||
| Sincerely, | ||
| /s/ Terrance J. Lillis | ||
| Terrance J. Lillis | ||
| Senior Vice President and | ||
| Chief Financial Officer | ||
| (515) 247-4885 | ||
| cc: | Vanessa Robertson (Securities and Exchange Commission) | |
| Mary Mast (Securities and Exchange Commission) | ||
