SecProbe.io

Via Facsimile and U.S. Mail
Mail Stop 6010

         March 10, 2008

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

Re:   Aflac Incorporated
Form 10-K for the Fiscal Year Ended December 31, 2007
Filed February 29, 2008
File Number:  001-07434

Dear Mr. Cloninger:

 We have reviewed your filing and have the following comments.  We have
limited our review of your filing to only your financial statements and related disclosures
and do not intend to expand our review to ot her portions of your document.   In our
comments, we ask you to provide us with  information to better understand your
disclosure. Where our comments request you to revise disclosure, the information you
provide should show us what the revised disc losure will look like and identify the annual
or quarterly filings, as app licable, in which you intend to first include it.  If you do not
believe that revised disclosure  is necessary, explain the reason in your response.  After
reviewing the information provided, we may raise additional comments and/or request
that you amend your filing.

            Please understand that the purpos e of our review 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.

Mr. Kriss Cloninger III
Aflac Incorporated
March 10, 2008 Page 2  Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page II-6
 Critical Accounting Estimates, page II-7

 Policy Liabilities, page II-9

 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: 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 comment ed on this matter in comment one of
our August 16, 2007 comment letter, and also  in comment three of our January 7,
2004 comment letter.  However, we are unsure how the current discussion addresses the change in estimates that occurred during the year ended December 31, 2007.

Note 3. Investments page II-64

 2. Please revise your disclosure to comp ly with paragraph 17b of FSP FAS 115-
1/FAS 124-1.  More specifically, please pr ovide a more robust discussion of your
rationale for concluding that unrealiz ed losses are not other-than-temporary
impairments, particularly given that 77% of the unrealized loss has been in an
unrealized loss position for more than 12 months.  Your discussion on page II-72
only discusses a small part of the unreali zed losses.  In addi tion, please revise to
discuss your significant concentrat ion of unrealized losses in the
banking/financial institution industry and th e significant increase in the unrealized
losses in that industry from the prio r year clarifying why you believe no
impairment is required.

Mr. Kriss Cloninger III
Aflac Incorporated
March 10, 2008 Page 3  3. You state on page II-76 that you have va riable interest ent ities that you do not
consolidate because you are not the primar y beneficiary.  Please refer to Item
303(a)(4) of Regulation S-K regarding disclosures of off-balance sheet
arrangements.

a. Please tell us the extent that the foll owing items are applicable and material,
for your non-consolidated CDO for whic h you have material exposure, and
provide us revised disclosure  or tell us why revised di sclosure is not necessary
to address these items:

• Categories and rating of assets the off-balance sheet entity holds;

• Weighted-average life of assets th e off-balance sheet entity holds;

• Forms of funding (commercial paper, medium-term notes, etc) and
weighted-average life of the funding the off-balance sheet entity holds;

• Any material difficulties the off-balance sheet entity has experienced in
issuing its commercial paper or other financi ng during the period;

• Any material write-downs or downgrades  of assets the off-balance sheet
entity holds;

• Maximum limit of the losses to be borne by any first loss note holders;

• Detailed disclosure regarding your  obligations under the liquidity
facilities.  For example, consider the following items, to the extent
applicable:

• whether there are triggers associ ated with your obligations to
fund,

• whether there are any terms that  would limit your obligation to
perform,

• any obligations under the facilities  (e.g., to purchase assets from
or commercial paper the off-balan ce sheet entity issued), and their
material terms,

• whether there are any other liqui dity providers, and if so, how
your obligation ranks with the other liquidity providers;

Mr. Kriss Cloninger III
Aflac Incorporated
March 10, 2008 Page 4
• Whether any agreement required you to  purchased securities issued by
any off- balance sheet entities th at you manage.  If not, consider
discussing your  reasons for the purchase;

• Whether you provided or assisted the o ff-balance sheet ent ity in obtaining
any other type of support, or whether it is your current intention to do so;
and

• Potential impact on debt covenants, capital ratios, credit ratings, or
dividends, should you be required to consolidate the entity or incur
significant losses associated with the entity.
 b. Please revise your disc losures to address:

• the scenarios where you would have to  consolidate the off-balance sheet
entity, and your expectation of the likelihood of such consolidation; and

• the frequency of which you reconsider , and the typical triggers which
require you to reconsider, whether you are the primary beneficiary of the
entity.

• any known trends or uncertainties that  you may reasonably expect to have
a material favorable or unfavorable impact on your income from
operations, liquidity and capital resources .  In this regard, please consider,
to the extent material in light of your  particular facts and circumstances,
disclosing the amount of any material lo ss you expect to realize as a result
of your involvement with any mate rial off-balance sheet entity.

c. Tell us why you do not believe you are re quired to consolidate the CDO in
light of the funding requirements.  A ddressing FIN 46R in your response.

d. Please provide in your financial statem ents all the disclosures required by
paragraph 24 of FIN 46R.

* * * *

Please provide us the information requested within 10 business days  of the date of
this letter or tell us when you will provide a response prior to the expiration of the 10-day
period.  Please furnish a letter with your responses that keys your responses to our
comments.  Detailed letters gr eatly facilitate our review.  You should furnish the 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

Mr. Kriss Cloninger III
Aflac Incorporated
March 10, 2008 Page 5  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.
  In connection with responding to our comment, 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 comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement 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 comments 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