SEC Comment Letter for AFLAC INC (AFL) (CIK 0000004977) (AFL) — Sep 24, 2007
AFLAC INC (AFL) (CIK 0000004977)
Date: Sept. 24, 2007 · CIK: 0000004977 · Accession: 0000000000-07-046474
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-07434
Letter
Via Facsimile and U.S. Mail Mail Stop 6010 September 24, 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 reviewed your August 29, 2007 response to our August 16, 2007 comment letter and have the following comments. In our comments, we ask you to provide us with information so we may better understand your disclosure. 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. Please refer to your second point in res ponse to comments 1 and 2 regarding the transfer of $170 million from the unpaid pol icy claim liability to the future policy benefits liability. You state that $95 million was transferred from unpaid policy claim liability to future policy benefit lia bility because you beli eve that the total policy liability is appropriate. Please clar ify in your proposed disclosure your justification for transferring the $95 million to future policy benefit liability as it
Mr. Kriss Cloninger Aflac Incorporated September 24, 2007 Page 2 is not clear from your discussion as to what assumptions changed in your future policy benefit liability that would increase the liability by $95 million. 2. Refer to your third point in response to comments 1 and 2 regarding the transfer of the $85 million reserve from unpaid policy claim liability to future policy benefit liability in the fourth quarter of 2006. Please clarify in your proposed disclosure why there is a relationship be tween a decrease in unpaid policy claim liability due to reduced hosp ital days and an increase in the future policy benefit liability. Clarify what assumptions cha nged in calculating your future policy benefit liability that would cause the increase in the liability.
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
Show Raw Text
Via Facsimile and U.S. Mail
Mail Stop 6010
September 24, 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 reviewed your August 29, 2007 response to our August 16, 2007
comment letter and have the following comments. In our comments, we ask you to
provide us with information so we may better understand your disclosure. 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. Please refer to your second point in res ponse to comments 1 and 2 regarding the
transfer of $170 million from the unpaid pol icy claim liability to the future policy
benefits liability. You state that $95 million was transferred from unpaid policy
claim liability to future policy benefit lia bility because you beli eve that the total
policy liability is appropriate. Please clar ify in your proposed disclosure your
justification for transferring the $95 million to future policy benefit liability as it
Mr. Kriss Cloninger
Aflac Incorporated
September 24, 2007 Page 2
is not clear from your discussion as to what assumptions changed in your future
policy benefit liability that would increase the liability by $95 million.
2. Refer to your third point in response to comments 1 and 2 regarding the transfer
of the $85 million reserve from unpaid policy claim liability to future policy
benefit liability in the fourth quarter of 2006. Please clarify in your proposed
disclosure why there is a relationship be tween a decrease in unpaid policy claim
liability due to reduced hosp ital days and an increase in the future policy benefit
liability. Clarify what assumptions cha nged in calculating your future policy
benefit liability that would cause the increase in the liability.
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