SEC Comment Letter for AFLAC INC (AFL) (CIK 0000004977) (AFL) — Jun 13, 2011
AFLAC INC (AFL) (CIK 0000004977)
Date: June 13, 2011 · CIK: 0000004977 · Accession: 0000000000-11-036277
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-07434
Letter
May 16, 2011 Ms. June Howard Senior Vice President and Chief Accounting Officer 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 Ms. Howard:
We have reviewed your April, 19, 2011 respons e to our April 6, 2011 letter and have the following comment. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provid e the requested response. Please furnish us a letter on EDGAR under the form type label CORRE SP that keys your response to our comment.
After reviewing your response to the comment, we may have additi onal comments. Financial Statements
Consolidated Statements of Comp rehensive Income (Loss), page 79
1. Although your proposed disclosure provided in response to co mment one provides clarity on the tax effects included in other comprehensive income and accumulated other comprehensive income, it does not appear to explain the significant fluctuation in the effective tax rate applicable to other comp rehensive income in each year presented. Please provide us proposed revised disclosure to be included in future periodic reports that explains why your effective tax rate on other comprehensive income fluctuated from 50.6% in 2008 to 36.5% in 2009 to (3.4%) in 20 10. In your proposed revised disclosure please quantify the income tax effect of the dollar-denominated investment portfolio held by Aflac Japan.
Ms. June Howard Aflac Incorporated
May 16, 2011 Page 2
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 comment. 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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May 16, 2011 Ms. June Howard Senior Vice President and Chief Accounting Officer 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 Ms. Howard: We have reviewed your April, 19, 2011 respons e to our April 6, 2011 letter and have the following comment. Please respond to this letter within te n business days by providing the requested information or by advising us when you will provid e the requested response. Please furnish us a letter on EDGAR under the form type label CORRE SP that keys your response to our comment. After reviewing your response to the comment, we may have additi onal comments. Financial Statements Consolidated Statements of Comp rehensive Income (Loss), page 79 1. Although your proposed disclosure provided in response to co mment one provides clarity on the tax effects included in other comprehensive income and accumulated other comprehensive income, it does not appear to explain the significant fluctuation in the effective tax rate applicable to other comp rehensive income in each year presented. Please provide us proposed revised disclosure to be included in future periodic reports that explains why your effective tax rate on other comprehensive income fluctuated from 50.6% in 2008 to 36.5% in 2009 to (3.4%) in 20 10. In your proposed revised disclosure please quantify the income tax effect of the dollar-denominated investment portfolio held by Aflac Japan. Ms. June Howard Aflac Incorporated May 16, 2011 Page 2 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 comment. In this regard, do not hesitate to contact me, at (202) 551-3679. Sincerely, Jim B. Rosenberg Senior Assistant Chief Accountant