United States securities and exchange commission logo
July 12, 2022
Mark FitzPatrick
Group Chief Financial Officer
Prudential plc
1 Angel Court
London EC2R 7AG, England
Re: Prudential plc
Form 20-F for
Fiscal Year Ended December 31, 2021
Filed March 17,
2022
Response Dated May
19, 2022
File No. 001-15040
Dear Mr. FitzPatrick:
We have reviewed your May 19, 2022 response to our comment letter
and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
May 5, 2022 letter.
Form 20-F for Fiscal Year Ended December 31, 2021
Determining Adjusted Operating Profit of Operating Segments, page 33
1. Please revise future
filings to identify adjusted operating profit for the overall group as a
non-GAAP financial
measure or tell us in detail why do not believe it meets the definition
of one. Refer to
Question 104.04 of the Non-GAAP Financial Measures Compliance and
Disclosure
Interpretations for guidance.
2. Please refer to comment
1. For each significant group (equity, debt, etc.) in the assets
component, please
identify the IFRS measurement policy, quantify the IFRS amount
backed out for each
period presented and briefly discuss how this amount was measured,
and quantify the amount
added back and explain in detail how this amount was measured.
Mark FitzPatrick
Prudential plc
July 12, 2022
Page 2
3. Please refer to comment 1. For each significant group in the
policyholder liabilities
component, please clearly identify the accounting basis for
measurement (ABI SORP,
other local GAAP, etc.), and explain the key concepts behind the
measurement basis that
result in variability based on current market movements. Please also
quantify the amount
backed out for each group for each period presented and briefly
discuss how this amount
was measured, and quantify the amount added back and explain in detail
how this amount
was measured.
4. Please refer to comment 1. We note your statement that the concept for
the adjusted
operating profit was permitted by the legacy UK GAAP accounting for
insurers. Please
tell us more clearly the concepts behind the legacy UK GAAP accounting
for insurers and
how they are similar to and different from adjusted operating profit.
Additionally, noting
your reference to US GAAP, please explain to us in detail how adjusted
operating profit is
similar to and different from any relevant US GAAP measurements.
5. Please refer to comment 1. We note your statement that the use of the
performance
measure of adjusted operating profit was permitted under the
grandfathered ABI SORP.
Please tell us specifically how adjusted operating profit was
permitted under the ABI
SORP. Additionally, please clarify the specific measurement basis
provided in the ABI
SORP and how this measurement is similar to and different from
adjusted operating
profit.
6. Please refer to comment 1. We note your statement that adjusted
operating profit based
on longer-term investment returns is often used by the Group s Asia
and UK peers.
Please identify some of these peers and tell us if any of them are
also SEC registrants.
7. Please tell us how you expect your adoption of IFRS 17 to impact your
use of
performance measures based on longer-term investment returns for
segments and for the
overall Group.
You may contact John Spitz, Staff Accountant, at (202) 551-3484 or
Michael Volley,
Staff Accountant, at (202) 551-3437 with any questions.
FirstName LastNameMark FitzPatrick Sincerely,
Comapany NamePrudential plc
Division of
Corporation Finance
July 12, 2022 Page 2 Office of Finance
FirstName LastName