SecProbe.io

June 24, 2010
 Mr. Kriss Cloninger III
President, Chief Financial Officer and Treasurer
Aflac Inc.
1932 Wynnton Road
Columbus, Georgia   31999

Re: Aflac Inc.
  Form 10-K for Fiscal Year Ended December 31, 2009
  Filed February 26, 2010
  Form 10-Q for Fiscal Quarter Ended March 31, 2010
  Filed May 7, 2010
  File No. 001-07434

Dear Mr. Cloninger:
 We have limited our review to only your fina ncial statements and related disclosures and
do not intend to expand our review to other por tions of your documents.  In our comments, we
ask you to provide us with information so  we may better underst and your disclosure.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  Where a comment requests you to revise disclosu re, the information you provide s hould show us what the revised
disclosure will look like and identify the annual or quarterly filing, as applicable, in which you
intend to first include it.  If you do not be lieve a comment applies to your facts and
circumstances, please tell us why in your res ponse.  Please furnish us a letter on EDGAR under
the form type label CORRESP that keys  your responses to our comments.
 After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

Form 10-K for Fiscal Year Ended December 31, 2009

 Consolidated Financial Statements

Notes to Consolidated Financial Statements
1.  Summary of Significant Accounting Policies,
Investments, page 87

1. You disclose that when prepayment estimates  change you recalculate the effective yield
to reflect actual payments to date and antic ipated future payments and adjust the net
investment balance to the amount that woul d have existed had the new estimate been

Mr. Kriss Cloninger III
Aflac Inc.  June 24, 2010 Page 2
 applied at the time of acquisition for your co llateralized mortgage obligations.  Please
disclose the accounting model used to account for changes in anticipated prepayments on
your asset-backed and mortgage-backed securities.

Please disclose how you account for changes in  estimated prepayments for investments
that are not of high credit quality.  Pleas e consider that the accounting for asset and
mortgage-backed securities, and collateralized mortgage obligations th at are not of high
credit quality must comply with the guidance in AS C 325-40-35-4a.

2. You disclose on page 109 that dollar-denomin ated and yen-denominated investments in
banks and financial institutions that total $1.7 billion were in an unrealized loss position
for 12 months or longer.  You also disclose  on page 112 that 75% of your investments in
bank and financial institutions  in an unrealized loss positi on were investment grade at
December 31, 2009 compared to 96% at December 31, 2008.  Please disclose the following:

• the amount of investments in bank and fina ncial institutions in an unrealized loss
position that have been downgraded to  non-investment grade status and the
amount of the unrealized lo sses on these investments;
• why credit downgrades of investment s in unrealized loss positions to non-
investment grade credit ratings is no t indicative of an other-than-temporary
impairment.

Form 10-Q for Fiscal Quarter Ended March 31, 2010

Consolidated Financial Statements
Notes to Consolidated Financial Statements
Significant Accounting Policies
Note 11 – Subsequent Events, page 49
3. You had $1 billion invested in Greek financial institutions that were downgraded to
below investment grade subsequent to Ma rch 31, 2010.  Please disclose your accounting
treatment of the credit downgrade and the rationale for that treatment.
Please disclose the amortized cost and fair value of your investments in sovereign debt
and financial institutions in Port ugal, Italy, Irelan d and Spain.

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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Mr. Kriss Cloninger III
Aflac Inc.  June 24, 2010 Page 3
  In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure 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 comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Ibolya Igna t, Staff Accountant at (202)  551-3656, or Gus Rodriguez,
Branch Chief, at (202) 551-3752 if you have questi ons regarding these comments.  In this regard,
do not hesitate to contact me, at (202) 551-3679.
Sincerely,

Jim B. Rosenberg
Senior Assistant Chief
Accountant