SecProbe.io

Via Facsimile and U.S. Mail
Mail Stop 6010

         August 16, 2007

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

Re:   Aflac Incorporated
Form 10-K for the Fiscal Year Ended December 31, 2006
Filed February 28, 2007
File Number:  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 additional information
so we may better understand your disclosures.  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 on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.
Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page II-5
Critical Accounting Estimates, page II-6

Policy Liabilities, page II-8
 1. It appears that you have si gnificantly revised your estima te of the liability for
unpaid policy claims recorded in prior year s.  Please provide us, using disclosure-
type format, proposed revisions to your ex isting disclosure an explanation of the
reasons for your change in estimate.  Fo r each liability and lines of business,
please include the following disclosures:

Mr. Kriss Cloninger
Aflac Incorporated
August 16, 2007 Page 2
a. Identify the years to which the change  in estimate relates and disclose the
amount of the related liability as of th e beginning of the year that was re-
estimated.  Discuss and quantify offsetti ng changes in estimates that increase
and decrease the liability.
b. Identify the changes in the key assumpti ons you made to estimate the liability
since the last reporting date.
c. Identify the nature and timing of the ch ange in estimate, explicitly identifying
and describing in reasonable specificity  the new events that occurred or
additional information acquired since the last reporting date that led to the
change in estimate.
d. Ensure your disclosure clearly expl ains why recognition occurred in the
periods that it did and why recognition was not required in earlier periods.
We acknowledge that we previously comme nted on this matter in comment three
of our January 7, 2004 comment letter .  While your January 16, 2004 response
stated that you would address this comme nt in future filings, we are unsure how
the current discussion addresses these areas.

2. Please provide us, using disclosure-type  format, proposed revisions to your
existing disclosure clarifying the specific reasons for the substantial increase in your liabilities for future policy benef its.  In addition, please state why the
increase in the US and Japan future policy benefit reserves of $170 million and $85 million in the fourth quarter of  2006 was necessary.  Clarify what
assumptions changed that required  the increase in the reserve.

Investments and Cash, page II-28

3. For each of your below-investment-grade se curities as listed in the table on II-31
with unrealized losses as of  December 31, 2006, please tell us the specific factors
that led to your conclusion that the un realized losses were not other-than-
temporary at December 31, 2006 and June 30, 2007.

* * * *

 Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Pl ease furnish a cover le tter with your response
that keys your response to our comments.  De tailed cover letters gr eatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.

 We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Mr. Kriss Cloninger
Aflac Incorporated
August 16, 2007 Page 3

 In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:

• the company is responsible for the adequacy and accuracy of the disclosure in
the filing;
• staff comment or change to disclosure  in response to staff comment do not
foreclose the Commission from taking a ny action with respect to the filing;
and
• the company may not assert staff comment as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.

You may contact Tabatha Akins, Staff Accountant, at (202) 551-3658, or Mary
Mast, Senior Accountant, at (202) 551- 3613, if you have questions regarding the
comments.  In this regard, do not hes itate to contact me, at (202) 551-3679.

        S i n c e r e l y ,

         J i m  B .  R o s e n b e r g
Senior Assistant Chief
Accountant