Exhibit 25.1

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C.  20549

FORM T-1

STATEMENT OF ELIGIBILITY
UNDER THE TRUST INDENTURE ACT OF 1939 OF A
CORPORATION DESIGNATED TO ACT AS TRUSTEE

CHECK IF AN APPLICATION TO DETERMINE
ELIGIBILITY OF A TRUSTEE PURSUANT TO
SECTION 305(b)(2)          x

Citibank, N.A.

A National Banking Association	13-5266470
	(I.R.S. employer
	identification no.)
388 Greenwich Street, New York, New York	10013
(Address of principal executive office)	(Zip code)

Prudential plc

(Exact name of Registrant as specified in its charter)

England and Wales
(State or other jurisdiction of
incorporation or organization) Not Applicable
(I.R.S. Employer Identification
Number)

1 Angel Court

London EC2R 7AG, England

(Address, including zip code and telephone number, including area code, of registrant’s principal executive offices)

Debt Securities

1.General information.  Furnish the following information as to the Trustee:

(a)Name and address of each examining or supervising authority to which it is subject.

Name	Address
Comptroller of the Currency	Washington, D.C.
Federal Reserve Bank of New York	33 Liberty Street, New York, NY
Federal Deposit Insurance Corporation	Washington, D.C.

(b)Whether it is authorized to exercise corporate trust powers.

Yes.

2.Affiliations with Obligor.

If the obligor is an affiliate of the trustee, describe each such affiliation.

None.

Item 16.List of Exhibits.

List below all exhibits filed as a part of this Statement of Eligibility.

Exhibits identified in parentheses below, on file with the Commission, are incorporated herein by reference as exhibits hereto.

Exhibit 1 - Copy of Articles of Association of the Trustee, as now in effect.  (Exhibit 1 to T-1 to Registration Statement No. 2-79983)

Exhibit 2 - Copy of certificate of authority of the Trustee to commence business.  (Exhibit 2 to T-1 to Registration Statement No. 2-29577).

Exhibit 3 - Copy of authorization of the Trustee to exercise corporate trust powers.  (Exhibit 3 to T-1 to Registration Statement No. 2-55519)

Exhibit 4 - Copy of existing By-Laws of the Trustee.  (Exhibit 4 to T-1 to Registration Statement No. 33-34988)

Exhibit 5 - Not applicable.

Exhibit 6 — The consent of the Trustee required by Section 321 (b) of the Trust Indenture Act of 1939, as amended, the undersigned hereby consents that reports of examination of the undersigned made by Federal, State, Territorial, or District authorities authorized to make such examination may be furnished by such authorities to the Securities and Exchange Commission upon its request therefor.

Exhibit 7 - Copy of the latest Report of Condition of Citibank, N.A. (as of March 31, 2020 - attached)

Exhibit 8 - Not applicable.

Exhibit 9 - Not applicable.

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SIGNATURE

Pursuant to the requirements of the Trust Indenture Act of 1939, as amended, the trustee, Citibank, N.A., a national banking association organized and existing under the laws of the United States of America, has duly caused this Statement of Eligibility to be signed on its behalf by the undersigned, thereunto duly authorized, all in the City of New York and State of New York, on the 10th day of August, 2020.

CITIBANK, N.A.
By:
Name:	Jennifer McCourt
Title:	Senior Trust Officer

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CONSOLIDATED BALANCE SHEET Citigroup Inc. and Subsidiaries March 31, 2020 (Unaudited) December 31, 2019 In millions of dollars Cash and due from banks (including segregated cash and other deposits) $ 23,755 $ 23,967 Securities borrowed and purchased under agreements to resell (including $155,637 and $153,193 as of March 31, 2020 and December 31, 2019, respectively, at fair value), net of allowance 262,536 251,322 Trading account assets (including $190,227 and $120,236 pledged to creditors at March 31, 2020 and December 31, 2019, respectively) 365,000 276,140 Available-for-sale debt securities (including $8,989 and $8,721 pledged to creditors as of March 31, 2020 and December 31, 2019, respectively) 308,219 280,265 2020 and December 31, 2019, respectively), net of allowance 82,315 80,775 Equity securities (including $1,213 and $1,162 at fair value as of March 31, 20120 and December 31, 2019, respectively) 8,349 7,523 Loans: value) 288,430 309,548 Corporate (including $3,981 and $4,067 as of March 31, 2020 and December 31, 2019, respectively, at fair value) 432,590 389,935 Allowance for credit losses on loans (ACLL) (20,841) (12,783) Goodwill 21,264 22,126 Other assets (including $14,663 and $12,830 as of March 31, 2020 and December 31, 2019, respectively, at fair value), net of allowance 112,873 107,709 The following table presents certain assets of consolidated variable interest entities (VIEs), which are included on the Consolidated Balance Sheet above. The assets in the table below include those assets that can only be used to settle obligations of consolidated VIEs, presented on the following page, and are in excess of those obligations. In addition, the assets in the table below include third-party assets of consolidated VIEs only and exclude intercompany balances that eliminate in consolidation. March 31, 2020 (Unaudited) December 31, 2019 In millions of dollars Assets of consolidated VIEs to be used to settle obligations of consolidated VIEs Trading account assets 6,278 6,719 Loans, net of unearned income Corporate 19,845 16,175 Allowance for credit losses on loans (ACLL) (3,729) (1,841) Other assets 70 73 Statement continues on the next page. 90 Total assets of consolidated VIEs to be used to settle obligations of consolidated VIEs$66,134 $69,506 Total loans, net$58,689 $61,311 Loans, net of unearned income$62,418 $63,152 Consumer42,57346,977 Investments9871,295 Cash and due from banks$110 $108 Total assets$2,219,770 $1,951,158 Intangible assets (including MSRs of $367 and $495 as of March 31, 2020 and December 31, 2019, at fair value)4,5604,822 Total loans, net$700,179 $686,700 Loans, net of unearned income$721,020 $699,483 Consumer (including $18 and $18 as of March 31, 2020 and December 31, 2019, respectively, at fair Total investments$398,883 $368,563 Held-to-maturity debt securities (including $1,119 and $1,923 pledged to creditors as of March 31, Investments: Brokerage receivables, net of allowance68,55539,857 Deposits with banks, net of allowance262,165169,952 Assets

CONSOLIDATED BALANCE SHEET (Continued) Citigroup Inc. and Subsidiaries March 31, 2020 (Unaudited) December 31, 2019 In millions of dollars, except shares and per share amounts Liabilities Interest-bearing deposits in U.S. offices (including $1,090 and $1,624 as of March 31, 2020 and December 31, 2019, respectively, at fair value) 462,327 401,418 Interest-bearing deposits in offices outside the U.S. (including $1,557 and $695 as of March 31, 2020 and December 31, 2019, respectively, at fair value) 523,774 484,669 Securities loaned and sold under agreements to repurchase (including $62,734 and $40,651 as of March 31, 2020 and December 31, 2019, respectively, at fair value) 222,324 166,339 163,995 Trading account liabilities 119,894 Long-term debt (including $52,914 and $55,783 as of March 31, 2020 and December 31, 2019, respectively, at fair value) 266,098 248,760 Total liabilities $ 2,026,788 $ 1,757,212 Preferred stock ($1.00 par value; authorized shares: 30 million), issued shares: as of March 31, 2020— 719,200 and as of December 31, 2019—719,200, at aggregate liquidation value $ 17,980 $ 17,980 3,099,632,709 and as of December 31, 2019—3,099,602,856 31 31 107,550 Additional paid-in capital 107,840 Treasury stock, at cost: March 31, 2020—1,017,824,700 shares and December 31, 2019—985,479,501 shares (64,147) (61,660) Total Citigroup stockholders’ equity $ 192,331 $ 193,242 Total equity $ 192,982 $ 193,946 The following table presents certain liabilities of consolidated VIEs, which are included on the Consolidated Balance Sheet above. The liabilities in the table below include third-party liabilities of consolidated VIEs only and exclude intercompany balances that eliminate in consolidation. The liabilities also exclude amounts where creditors or beneficial interest holders have recourse to the general credit of Citigroup. March 31, 2020 (Unaudited) December 31, 2019 In millions of dollars Liabilities of consolidated VIEs for which creditors or beneficial interest holders do not have recourse to the general credit of Citigroup 25,393 Long-term debt 25,582 Total liabilities of consolidated VIEs for which creditors or beneficial interest holders do not have recourse to the general credit of Citigroup $ 37,716 $ 36,530 The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements. 91 Other liabilities926917 Short-term borrowings$11,397 $10,031 Total liabilities and equity$2,219,770 $1,951,158 Noncontrolling interest651704 Accumulated other comprehensive income (loss) (AOCI)(32,521)(36,318) Retained earnings163,438165,369 Common stock ($0.01 par value; authorized shares: 6 billion), issued shares: as of March 31, 2020— Stockholders’ equity Other liabilities (including $4,339 and $6,343 as of March 31, 2020 and December 31, 2019, respectively, at fair value), including allowance60,14157,979 Short-term borrowings (including $8,364 and $4,946 as of March 31, 2020 and December 31, 2019, respectively, at fair value)54,95145,049 Brokerage payables74,36848,601 Total deposits$1,184,911 $1,070,590 Non-interest-bearing deposits in offices outside the U.S.85,43985,692 Non-interest-bearing deposits in U.S. offices$113,371 $98,811