SEC Comment Letter for AFLAC INC (AFL) (CIK 0000004977) (AFL) — Apr 20, 2011
AFLAC INC (AFL) (CIK 0000004977)
Date: April 20, 2011 · CIK: 0000004977 · Accession: 0000000000-11-024790
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-07434
Letter
April 6, 2011 Mr. Daniel Amos Chief Executive Officer and Chairman of the Board of Directors Aflac Incorporated 1932 Wynnton Road Columbus, GA 31999
Re: Aflac Incorporated Form 10-K for the Year Ended December 31, 2010 Filed February 25, 2011 File No. 001-07434
Dear Mr. Amos:
We have limited our review of your filing to those issues we have addressed in our comments. In our comments, we ask you to pr ovide us with information so we may better understand your disclosure.
Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts and circ umstances, please tell us why in your response. Please furnish us a letter on EDGAR under the fo rm 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.
Financial Statements
Consolidated Statements of Comp rehensive Income (Loss), page 79
1. Please provide us proposed revised MD&A or f ootnote disclosure to be included in future periodic reports that clarifies why you record ed an income tax benefit of $32 million, or 3.4%, against total other comprehensive income of $941 million in 2010, when you recorded an income tax expense of $351 million, or 36.5%, against total other comprehensive income of $962 million in 2009 and an income tax benefit of $1,555 million, or 50.6%, against total other comprehensive loss of $3,071 million in 2008. Separately explain to us how you allocated your intraperiod taxes between continuing operations and other comprehensive income and reference for us the authoritative literature you relied upon to support your allocation.
Mr. Daniel Amos Aflac Incorporated April 6, 2011 Page 2
Notes to Consolidated Financial Statements 3. Investments Analysis of Securities in Unrealized Loss Positions Bank and Financial Institu tion Investments, page 102
2. Please provide us proposed revised disclosure to be included in future periodic reports that explains why you believe that your invest ments in Greek financial institutions are not impaired. Please explain how these institutions continue to have the ability to service their obligations despite thei r downgrade to below investment grade in the second quarter of 2010.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s 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.
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.
Please contact Kei Nakada, Staff Accountan t, at (202) 551-3659 or Mark Brunhofer, Senior Staff Accountant, at ( 202) 551-3638, if you have questions regarding the comments. In this regard, do not hesitate to contact me, at (202) 551-3679.
Sincerely,
Jim B. Rosenberg
Senior Assistant Chief Accountant
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April 6, 2011 Mr. Daniel Amos Chief Executive Officer and Chairman of the Board of Directors Aflac Incorporated 1932 Wynnton Road Columbus, GA 31999 Re: Aflac Incorporated Form 10-K for the Year Ended December 31, 2010 Filed February 25, 2011 File No. 001-07434 Dear Mr. Amos: We have limited our review of your filing to those issues we have addressed in our comments. In our comments, we ask you to pr ovide us with information so we may better understand your disclosure. Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe a comment applies to your facts and circ umstances, please tell us why in your response. Please furnish us a letter on EDGAR under the fo rm 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. Financial Statements Consolidated Statements of Comp rehensive Income (Loss), page 79 1. Please provide us proposed revised MD&A or f ootnote disclosure to be included in future periodic reports that clarifies why you record ed an income tax benefit of $32 million, or 3.4%, against total other comprehensive income of $941 million in 2010, when you recorded an income tax expense of $351 million, or 36.5%, against total other comprehensive income of $962 million in 2009 and an income tax benefit of $1,555 million, or 50.6%, against total other comprehensive loss of $3,071 million in 2008. Separately explain to us how you allocated your intraperiod taxes between continuing operations and other comprehensive income and reference for us the authoritative literature you relied upon to support your allocation. Mr. Daniel Amos Aflac Incorporated April 6, 2011 Page 2 Notes to Consolidated Financial Statements 3. Investments Analysis of Securities in Unrealized Loss Positions Bank and Financial Institu tion Investments, page 102 2. Please provide us proposed revised disclosure to be included in future periodic reports that explains why you believe that your invest ments in Greek financial institutions are not impaired. Please explain how these institutions continue to have the ability to service their obligations despite thei r downgrade to below investment grade in the second quarter of 2010. We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s 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. 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. Please contact Kei Nakada, Staff Accountan t, at (202) 551-3659 or Mark Brunhofer, Senior Staff Accountant, at ( 202) 551-3638, if you have questions regarding the comments. In this regard, do not hesitate to contact me, at (202) 551-3679. Sincerely, Jim B. Rosenberg Senior Assistant Chief Accountant