| The Prudential Insurance Company of America | Jordan K. Thomsen |
Vice President and Corporate Counsel
The Prudential Insurance Company
of America
213 Washington Street
Newark, NJ 07102-2992
(973) 802-4193 fax: (973) 802-9560
Sara von Althann, Esq
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Pre-Effective Amendment No. 1 to Registration Statement on Form S-1 for The Prudential Variable Contract Real Property Account, Registration No. 333-223075
Ms. Von Althann:
Submitted herewith for filing electronically is a pre-effective amendment to our registration statement on Form S-1 (File#: 333-223075), which is being filed for the sole purpose of registering additional securities under variable life and variable annuity contracts. The prospectus now contains all items excluded from our initial filing on February 16, 2018, such as Appendix A, financial statements for the Real Property Account and the Real Property Partnership, exhibits required by Item 16, opinion and consent of counsel, independent auditor’s consent and powers of attorney.
Respectfully yours,
/S/ Jordan K. Thomsen | 3/29/2018 |
| Jordan K. Thomsen | Date |
The Prudential Insurance Company of America
via EDGAR