SecProbe.io

Via Facsimile and U.S. Mail
Mail Stop 6010

         March 30, 2009

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, 2008
 Filed February 20, 2009
 File Number:  001-07434

Dear Mr. Cloninger:

We have reviewed your filing and have the following comments.  In our
comments, we ask you to provide us with  information to better understand your
disclosures.  Where a comment requests 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 filing, as appli cable, in which you intend to fi rst 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 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.

Market for Registrant’s Common Equity, Related Stoc kholder Matters and Issuer
Purchases of Equity Securities
 Recent Sales of Unregistered Securities; Us e of Proceeds from Registered Securities,
page 38
 1. We note the discussion of your common stock issuances by the AFL Stock plan
and your statement that these issuances exceeded the number of shares remaining for issuance under your Form S-3 shelf regi stration statement for the Plan.  Please

Kriss Cloninger III
Aflac Incorporated March 30, 2009 Page 2
identify the exemption you relied on for th ese issuances and describe the factual
basis for your determination that  the exemption was available.
 Managements’s Discussion and Analysis of Financial Condition and Results of
Operations
 Critical Accounting Estimates, page 42

Investments, page 42
 2. Please refer to your investments determin ed by the discounted cash flow pricing
model that you discuss in Note 4 to the consolidated financial statements.  Please
disclose the impact on the financial statements at December 31, 2008 of the
reasonably likely changes in the key assump tions used to estimate the fair value
of these investments.
 Analysis of Financial Condition, page 62

Composition by Credit Rating, page 77
 3. Please revise your disclosure for the securi ties in your investment portfolio that
are guaranteed by third parties to include  the credit rating with and without the
guarantee. Also disclose any significant concentration in  an individual guarantor,
both direct exposure (i.e. i nvestments in a guarantor) and indirect exposure (i.e.
investments guaranteed by a guarantor).
 3. Investments, page 116

 4. Please tell us the factors you considered in concluding that there was no evidence
of credit deterioration in the perpetual securities for the year ended December 31,
2008. Please disclose, if the case, that downgr ades of certain perpetual securities
to below investment grade were not in re sponse to circumstances and events that
existed at December 31, 2008. If not the case,  tell us why other than temporary
impairments were not recorded in 2008.
 5. In your disclosure of your unrealized loss position in Ford Motor Credit ( FMCC)
you disclose that FMCC continues to mainta in adequate stand-alone liquidity and
a stable credit outlook.  Please revise your disclosure to  reconcile this statement to
the definition of the CCC cr edit rating.  In addition, pleas e revise your disclosure
to include the factors that support your assertion that it is not probable that you
will be unable to collect all amounts due.

Kriss Cloninger III
Aflac Incorporated March 30, 2009 Page 3  4. Financial Instruments and Fair  Value Measurements, page 148

 6. Please revise your disclosure to clarify whether and, if so to what extent,  you
adjusted the quotes and prices obtained from the brokers and pricing services
during the periods presented.

7. Please revise your disclosure regarding th e transfers into Level 3 to include any
gain or loss you recognized during the peri od, and, to the extent you exclude that
amount from the realized/unrealized gain s (losses) line item in the Level 3
reconciliation, the amount you excluded. In  addition, please clarify the specific
inputs that became unobservable in the second, third and fourth quarters of 2008.

* * * *

 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.

 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 comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking a ny 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 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 comments on your filing.

Kriss Cloninger III
Aflac Incorporated March 30, 2009 Page 4
Please contact Vanessa Robe rtson, Staff Accountant, at  (202) 551-3649 or Joel
Parker, Accounting Branch Chief, at (202) 551-3651 if you have any questions regarding
the processing of your response as well as  any questions regarding comments on the
financial statements and related matters.  Y ou may contact Scot Foley, Staff Attorney, at
(202) 551-3383 or Suzanne Hayes, Legal Branch  Chief, at (202) 551-3675 with questions
on comment one.  In this regard, do not he sitate 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