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Via Facsimile and U.S. Mail
Mail Stop 6010

                                                                                                May 19, 2006

Mr. Kriss Cloninger III
President, Chief Financial Officer and Treasurer
Aflac Incorporated
1932 Wynnton Road
Columbus, Georgia 31999

Re: Aflac Incorporated
Form 10-K for the Fiscal Year Ended December 31, 2005
            Filed February 28, 2006
 File No. 001-07434

Dear Mr. Cloninger:

We have limited our review of your filing to those issues we have addressed in
our comments.  In our comments, we ask you to  provide us with information so we may
better understand your disclosure.  Please be as de tailed as necessary in  your explanation.
After reviewing this information, we may raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2005

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

Deferred Policy Acquisition Co sts and Policy Liabilities

Policy Liabilities, page II-8

1. We note that you provide a sensitivity analysis aro und the entire unpaid policy
claims liability reserve balance.  To  aid an investor in understanding the
variability that is reasonably likely from your estimated loss reserve, please
provide us, in disclosure-type format, a modified sensitivity analysis which

Mr. Kriss Cloninger III
Aflac Incorp orated
May 19, 2006
Page 2

illustrates re asonably lik ely change s in th e key as sumptions used to ar rive at
manage ment’s best estimate and quantif y the effect on operations and financial
position of reasonably likely changes in those assum ptions.  Explain why
manage ment believes the scenarios quantified are reasonably likely.

2. Please identify and describe those key a ssum ptions that m aterially af fect the
estim ate of the unpaid policy claim s liabili ty reserve.  For example, significant
assum ptions could be those assum ptions that involved the greatest am ount of
judgm ent or those assum ptions that have the greatest financial im pact on the loss
reserve balance.  In addition please disclose the f ollowing:
a. For each of your key assum ptions qu antify and explain what caused th em
to change historically ov er the periods presented.
b. Discuss whether and to what exten t managem ent has adjus ted each of th e
key assum ptions used in calcu lating the m ost recent estim ate of the
reserve given the historical changes, current trends observed and/or other
factors.  This discussion should reco ncile the historical changes, the
current trends and/or other factors observed to w hat managem ent has
calculated as its m ost recent key assum ptions.

Please respond to these comm ents within  10 business days or tell us when you
will prov ide us with a res ponse.  Please furnish a letter that  keys your response to our
comment and provide the request ed infor mation.  Detailed le tters greatly facilitate our
review.  Please file your letter on E DGAR under the form  type label CORRESP.

 We urge all persons who are responsible  for the accuracy and adequacy of the
disclosu re in the f iling to  be cer tain that the filing include s all in form ation required under
the Securities Exchange Act of 1934 and th at they have provided all inform ation
investors require for an inform ed invest ment decision.  Since the com pany and its
manage ment are in possession of all f acts re lating to a com pany’s disclosure, they are
responsib le for the accu racy and adequacy of the disclosu res they have m ade.

 In connection with responding to our co mments, please provide, in your letter, a
statem ent fr om the company ackno wledging th at:

‚ the com pany is respon sible for the adequacy  and accuracy of the dis closure in the
filing;
‚ staff comm ents or chang es to dis closure in response to staff comm ents do not
foreclose the Comm ission from  taking any actio n with respe ct to the f iling; and
‚ the com pany m ay not assert staff comments as a defense in any proceeding initiated
by the Comm ission or any person under the federal securities laws of the United
States.

Mr. Kriss Cloninger III
Aflac Incorp orated
May 19, 2006
Page 3

In addition, please be advise d that the Division of Enfo rcement has access to all
inform ation you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filin g or in respo nse to our comm ents on your filing.

You m ay contact Dana Hartz,  Staff Accountant, at ( 202) 551-3648 or Mary Mast,
Review Accountant, at (202) 551-3613 if you have questions regarding the comm ents.
Please contact m e at (202) 551-3679 with any other questions.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief
Accountant