DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-55,453

PRUDENTIAL FINANCIAL, INC.
INDIVIDUAL LIFE-CUSTOMER SERVICE DIVISION
DRESHER, PENNSYLVANIA

Negative Determinations Regarding Eligibility
To Apply for Worker Adjustment Assistance
And Alternative Trade Adjustment Assistance

In accordance with Section 223 of the Trade Act of 1974, as
amended (19 USC 2273), the Department of Labor herein presents the
results of an investigation regarding certification of eligibility
to apply for worker adjustment assistance.
The investigation was initiated on August 16, 2004 in response
to a petition filed on behalf of workers of Prudential Financial,
Inc., Individual Life-Customer Service Division, Dresher,
Pennsylvania. Workers at the subject firm are employed as customer
service employees for the insurance industry. The employees are
responsible for fielding concerns from existing insurance
customers.
The investigation revealed that Prudential Financial, Inc.,
Individual Life-Customer Service Division, Dresher, Pennsylvania
does not produce an article within the meaning of Section 222(a)(2)
of the Act. In order to be considered eligible to apply for
adjustment assistance under Section 223 of the Trade Act of 1974,
the worker group seeking certification (or on whose behalf
certification is being sought) must work for a "firm" or
appropriate subdivision that produces an article and there must be
a relationship between the workers' work and the article produced
by the workers' firm or appropriate subdivision. The customer
service workers described above do not support a firm or
appropriate subdivision that produces an article domestically and
thus the worker group cannot be considered import impacted or
affected by a shift in production of an article.
In addition, in accordance with Section 246 the Trade Act of
1974 (26 USC 2813), as amended, the Department of Labor herein
presents the results of its investigation regarding certification
of eligibility to apply for alternative trade adjustment assistance
(ATAA) for older workers.
In order for the Department to issue a certification of
eligibility to apply for ATAA, the worker group must be certified
eligible to apply for trade adjustment assistance (TAA). Since the
workers are denied eligibility to apply for TAA, the workers cannot
be certified eligible for ATAA.







Conclusion
After careful review of the facts obtain in this
investigation, I determine that workers of Prudential Financial,
Inc., Individual Life-Customer Service Division, Dresher,
Pennsylvania are denied eligibility to apply for adjustment
assistance under Section 223 of the Trade Act of 1974, and are also
denied eligibility to apply for alternative trade adjustment
assistance under Section 246 of the Trade Act of 1974.
Signed in Washington, D.C. this 9th day of September 2004.
/s/ Linda G. Poole

______________________________
LINDA G. POOLE
Certifying Officer, Division of
Trade Adjustment Assistance