SEC Comment Letter for AFLAC INC (AFL) (CIK 0000004977) (AFL) — Apr 28, 2017
AFLAC INC (AFL) (CIK 0000004977)
Date: April 28, 2017 · CIK: 0000004977 · Accession: 0000000000-17-014838
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4546 April 28, 2017 Via E -Mail Mr. Frederick J. Crawford Chief Financial Officer Aflac Incorporated 1932 Wynnton Road Columbus, GA 31999
Re: Aflac Incorporated Form 10-K for the fiscal year ended December 31, 2016 Filed February 24, 2017 File No. 1-07434
Dear Mr. Crawford :
We have reviewed your filing an d have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure.
Please respond to the comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances , please tell us why in your response.
After reviewing your response to the comment, we may have additional comments.
Notes to Consolidated Financial Statements 7. Policy Liabilities, page 139
1. Please t ell us how much of the favorable $465 million in claims development for prior years relates to the lines of business in Japan , separately breaking out the portion related to the impact of foreign exchange . Also, provide us a description of those lines and an analysis explaining with more specificity the reason for the favorable development unrelated to foreign exchange .
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Mr. Frederick J. Crawford Aflac Incorporated April 28, 2017 Page 2
You may contact Lisa Vanjoske, Assistant Chief Acc ountant , at (202) 551 -3614 or Mark Brunhofer, Senior Staff Accountant, at (202) 551 -3638 with any questions . In this regard, do not hesitate to contact me at (202) 551 -3679.
Sincerely,
/s/ Jim B. Rosenberg
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Mail Stop 4546 April 28, 2017 Via E -Mail Mr. Frederick J. Crawford Chief Financial Officer Aflac Incorporated 1932 Wynnton Road Columbus, GA 31999 Re: Aflac Incorporated Form 10-K for the fiscal year ended December 31, 2016 Filed February 24, 2017 File No. 1-07434 Dear Mr. Crawford : We have reviewed your filing an d have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to the comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment appl ies to your facts and circumstances , please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Notes to Consolidated Financial Statements 7. Policy Liabilities, page 139 1. Please t ell us how much of the favorable $465 million in claims development for prior years relates to the lines of business in Japan , separately breaking out the portion related to the impact of foreign exchange . Also, provide us a description of those lines and an analysis explaining with more specificity the reason for the favorable development unrelated to foreign exchange . We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Mr. Frederick J. Crawford Aflac Incorporated April 28, 2017 Page 2 You may contact Lisa Vanjoske, Assistant Chief Acc ountant , at (202) 551 -3614 or Mark Brunhofer, Senior Staff Accountant, at (202) 551 -3638 with any questions . In this regard, do not hesitate to contact me at (202) 551 -3679. Sincerely, /s/ Jim B. Rosenberg Jim B. Rosenberg Senior Assistant Chief Accountant Office of Healthcare and Insurance