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Rating Action:

Moody's downgrades Prudential Funding, LLC's short-term debt rating to Prime-2

20 Aug 2009

Approximately $1.7 billion of securities affected.

New York, August 20, 2009 -- Moody's Investors Service has downgraded Prudential Funding, LLC's (Pru Funding) short-term debt rating for commercial paper and extendible commercial notes to Prime-2 from Prime-1. Pru Funding is a funding vehicle for its parent, Prudential Insurance Company of America (PICA, insurance financial strength (IFS) rating at A2), which is, in turn, the lead U.S. insurance subsidiary of Prudential Financial, Inc. (Prudential - NYSE: PRU; senior debt at Baa2). This rating action concludes the review for possible downgrade that was initiated on March 18, 2009. The rating outlook is stable. All other ratings of Prudential and its affiliates remain unchanged.

When Moody's downgraded Prudential's ratings in March, the rating agency placed Pru Funding's short-term debt rating under review for possible downgrade to consider whether an exception to the usual relationship between long-term senior and short-term debt ratings was warranted—i.e., an A3 senior debt rating corresponding to a Prime-2 short term debt rating. As a result of that review, the rating agency has determined that an exception is not warranted.

Moody's commented that the downgrade of Pru Funding's short-term debt rating reflects the relationship between short-term and long-term senior debt ratings in which the Prime-1 short-term debt rating is normally reserved for companies with long-term senior debt ratings of A2 or higher. Exceptions from this relationship may occur in situations where liquidity and rating transition risk are considered to be exceptional. Pru Funding's long term senior debt rating is A3, based on support from PICA, whose long-term senior debt obligations would be rated A3.

Moody's said that while it recognizes the strong liquidity profiles of life insurers, including PICA, and their stable liability structure, which tends to lower transition risk relative to A3 companies as a whole, it does not believe the liquidity of life insurers or their rating transition risk are exceptional relative to other companies. The rating agency noted that the regulatory constraints under which most insurers operate emphasize payment of policyholder claims and, in almost all cases, subordinates other claimants. Moody's believes that this subordination could lead to scenarios where regulators take conservative actions to protect policyholders that could effect otherwise normal payments to non-policyholder creditors.

Pru Funding's commercial paper issuance at June 30, 2009 was approximately $1.7 billion and was down dramatically from about $7.3 billion at year-end 2007. However, Moody's noted that issuance may increase again going forward.

Moody's last rating action taken on Prudential Funding was on June 26, 2009 when the rating agency continued the review for downgrade of Prudential Funding's Prime-1 short term debt rating that had been initiated on March 18, 2009.

The principal methodology used in rating the issuers covered by this press release is "Moody's Global Rating Methodology for Life Insurers", which can be found at www.moodys.com in the Credit Policy & Methodologies directory, in the Rating Methodologies subdirectory. Other methodologies and factors that may have been considered in the process of rating these issuers can also be found in the Credit Policy & Methodologies directory.

Prudential Financial, Inc. is an insurance and investment management organization headquartered in Newark, New Jersey. As of June 30, 2009, the company had total assets of approximately $445 billion and total shareholders' equity of $18.7 billion.

Moody's insurance financial strength ratings are opinions of the ability of insurance companies to pay punctually senior policyholder claims and obligations.

For more information, visit our website at www.moodys.com/insurance.

New York
Ann G. Perry
VP - Senior Credit Officer
Financial Institutions Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

New York
Robert Riegel
Managing Director
Financial Institutions Group
Moody's Investors Service
JOURNALISTS: 212-553-0376
SUBSCRIBERS: 212-553-1653

Moody's downgrades Prudential Funding, LLC's short-term debt rating to Prime-2
No Related Data.
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