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SEC CORRESPONDENCE / AFLAC INCORPORATED

Ralph A. Rogers, Jr.

Senior Vice President

Chief Accounting Officer

Financial Services

June 19, 2009

Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

Division of Corporate Finance

U.S. Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

    Re:

    Aflac Incorporated

Form 10-K for the Fiscal Year Ended December 31, 2008

Filed February 20, 2009

File Number: 001-07434

Dear Mr. Rosenberg:

     We appreciate the efforts of the Securities and Exchange Commission to improve the financial
reporting process and compliance. We make every effort to be transparent in our financial
reporting in order to allow investors to understand our Company and the matters which affect our
financial position and results of operations.

     Below we have listed your comments for ease of reference and our responses. The responses are
presented in disclosure format as requested.

Comment:

Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of
Equity Securities

Recent Sales of Unregistered Securities; Use of Proceeds from Registered Securities, page 38

    1.

    We note your response to comment one which states that the shares were not issued pursuant to
an effective registration statement or a valid exemption. Please note that the subsequent
filing of a registration statement does not register the issuance of shares that were
previously issued. Please tell us what, if anything, you have done or plan to do in terms of
providing risk factor disclosure and recording a contingent liability.

Response:

     The dollar amount of the theoretical exposure to Aflac for the sale of the subject securities
without an effective registration statement or a valid exemption under the Securities Act of 1933
is not material to Aflac. Accordingly, the Company has determined that it is not necessary to add a
risk factor or to record a contingent liability.

Comment:

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Critical Accounting Estimates, page 42

Investments, page 42

    2.

    Please refer to your response to comment two and your revised disclosures. For your
sensitivity analysis, please revise your proposed disclosure to clarify whether the changes
shown are reasonably likely scenarios and how they were determined to be reasonably likely.
If they are not reasonably likely changes, then revise the disclosure to include what the
reasonably likely changes would be.

Response:

     In response to your comment, we propose to precede our current disclosure with the following
comment in our future filings beginning with the quarter ending June 30, 2009.

     Management
believes that under normal market
conditions, a movement of 50 basis points would be reasonably likely. Therefore, we selected a
uniform magnitude of movement (50 basis points) and provided both upward and downward movements in
the key assumptions used to estimate the fair value of these investments. Since the changes in
fair value are relatively linear, the readers of these financial
statements can make their own judgment as to the movement in
interest rates and the change in fair value based upon this data. The
following scenarios provide a view of the
sensitivity of our securities priced by our DCF pricing model.

Comment:

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Composition by Credit Rating, page 77

    3.

    Please refer to your response to comment three. Please revise your disclosure to include
that your direct and indirect exposure to third party guarantors is immaterial.

Response:

     In response to your comment, we propose the following addition to our disclosures in our
future filings beginning with the quarter ending June 30, 2009.

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     As of June 30, 2009, our direct and indirect exposure to securities in our investment
portfolio that were guaranteed by third parties was immaterial both individually and in the
aggregate.

Comment:

Note 3. Investments, page 116

    4.

    Please refer to your response to comment five and your revised disclosures. Please revise
your disclosure to discuss the factors that you considered to support the fact that there were
no adverse business, financial, or economic conditions that would indicate that FMCC is not
likely to have the capacity to meet their financial commitments.

Response:

     As noted in the Company’s April 8, 2009 response and the March 31, 2009 Form 10-Q filing, the
Company disclosed both the adverse and the favorable business conditions that we considered as part
of our conclusion that our investment in Ford Motor Credit Corporation (FMCC) was not
other-than-temporarily impaired. These conditions included a decline in profitability, largely
attributable to decreased volume, tighter financing margin, and increased credit write-offs; offset
by improved lease residual contributions and market value adjustments to derivatives primarily
linked to embedded options in lease financing.

     In terms of economic and financial factors considered as part of the other-than-temporary
impairment evaluation, the Company disclosed in our response dated April 8, 2009 and our March 31,
2009 Form 10-Q filing that the unrealized losses in FMCC were impacted by the widening of credit
spreads globally as a result of the contraction in global capital market liquidity. For FMCC
specifically, we included in our April 8, 2009 response and our March 31, 2009 Form 10-Q filing
that FMCC had increased its liquidity position during 2008 and 2009 through various facilities
including $10 billion in public retail term ABS, $22 billion in private transactions and $5 billion
in term funding. As a result of these transactions, FMCC reduced its cost of funding to 5.0% in
first quarter of 2009 from 5.6% in first quarter of 2008. As disclosed, we concluded that these
credit facilities provided FMCC with adequate stand-alone liquidity and a stable credit outlook
over the period until the contractual maturity of its obligation to us which is January 2013.
Subsequent to the filing of our first quarter Form 10-Q, FMCC completed an additional $3 billion in
auto receivable securitizations.

     As a wholly-owned subsidiary of Ford Motor Company (Ford), we also considered Ford’s financial
position, its ongoing commitment to FMCC and its ability to deliver on that commitment.
Specifically, Ford’s first quarter 2009 pretax loss was a substantial improvement over the pretax
loss for fourth quarter 2008, driven by improved pricing and cost reductions. Financially, Ford
increased gross cash levels during the first quarter of 2009 by $8 billion with the main
contributor being a $10 billion revolver drawdown. Ford’s cash position was also favorably
impacted by a reduction in personnel costs and restructuring of certain employee benefit
obligations. Ford also reduced its outstanding secured loans, unsecured debt and convertible notes
by $10 billion which will result in annual interest savings. Ford’s liquidity was most recently
favorably impacted by a $1.4 billion common stock offering in May 2009. As a result of these 2009
favorable business and financial developments, Ford is better able to deliver on its ongoing
commitment to FMCC if needed.

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     After reviewing our April 9, 2009 response and our first quarter 2009 disclosures, we believe
that our future disclosures related to FMCC should be updated to include the additional FMCC
liquidity of $3 billion completed in June and to describe our consideration of Ford’s financial
position and ability to deliver on its ongoing commitment to FMCC. As a result, we are proposing
to add the following additional disclosure to be included in the FMCC discussion for our future
filings beginning with the quarter ending June 30, 2009, with any appropriate updates. To
highlight the additional disclosures we are proposing to include, we have included a marked version
of our complete first quarter 2009 disclosure related to FMCC.

     Also included in the unrealized losses in the other corporate sector as of March 31, 2009, was
an unrealized loss of $129 million on Aflac Japan’s $305 million (30.0 billion yen) investment
issued by Ford Motor Credit Corporation (FMCC). This investment is a debt security issued by FMCC,
a wholly owned financing subsidiary of Ford Motor Company (Ford). Ford has reiterated its
commitment to continue to own 100% of FMCC, and both Moody’s and Standard & Poor’s rating services
have indicated that they expect this commitment to continue. Financial subsidy payments from Ford
and lease program residual value support payments inextricably link FMCC’s financing business to
the parent. Our investment in FMCC matures in January 2013.

     Ford’s first quarter 2009 results were a substantial improvement over fourth quarter 2008,
driven by improved pricing and cost reductions. Ford also improved its gross cash levels during
the first quarter of 2009 by $8 billion with the main contributor being a $10 billion revolver
drawdown. Ford also reduced its outstanding secured loans, unsecured debt and convertible notes by
$10 billion which will result in annual interest savings. Ford’s liquidity was most recently
favorably impacted by a $1.4 billion common stock offering in May 2009. As a result of these 2009
favorable business and financial developments, we believe Ford is better able to deliver on its
ongoing commitment to FMCC if needed.

     We believe that the unrealized loss on FMCC was related to sharply lower reported earnings by
FMCC in 2008, compared with 2007. We believe FMCC’s decline in profitability is largely
attributable to decreased volume, a tighter financing margin, and increased credit charge-off
costs; offsetting these negatives were improved lease residual contributions, and market value
adjustments to derivatives primarily linked to embedded options in lease financing. We also believe
that the unrealized losses in FMCC were impacted by the widening of credit spreads globally as a
result of the contraction in global capital market liquidity over the past several quarters. As of
March 31, 2009, FMCC had a credit rating of CCC+ by S&P, Caa1 by Moody’s, and B- by Fitch Ratings.
Under current NRSRO guidelines, obligors in these credit rating categories are subject to high
credit risk and are current with their financial commitments; however, they are dependent upon
favorable business, financial and economic conditions to meet future financial commitments.
However, despite its credit rating and the difficult market conditions, FMCC completed $5 billion
of term funding through April 2009, including $3 billion of eligible funding through the Term
Asset-Backed Securities Loan Facility (TALF). In June 2009, FMCC completed an additional $3
billion in TALF eligible funding. FMCC cost of funding actually declined to 5.0% in the first
quarter of 2009, compared with 5.6% in the first quarter of 2008. FMCC also increased available
liquidity primarily as the result of a continued

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reduction in its managed receivables balance and cash cost reductions in the quarter ended
March 31, 2009, related to personnel reductions and restructuring plans. Taken collectively, we
believe these credit facilities and other liquidity enhancement measures provide FMCC with adequate
stand-alone liquidity and a stable credit outlook over the relatively near term contractual
maturity of its obligation to us.

     We have considered the factors impacting the fair value of FMCC as of March 31, 2009, and
based on our credit analysis, we believe that FMCC’s ability to service its obligation to Aflac is
currently not impaired. Furthermore, the contractual terms of this investment do not permit the
issuer or its parent to settle the security at a price less than the amortized cost of the
investment. Accordingly, we currently believe it is probable that we will collect all amounts due
according to the contractual terms of the investment. Because we do not intend to sell and we do
not believe it is likely that we will be required to sell this investment before a recovery of fair
value, we do not consider our investment in FMCC to be other-than-temporarily impaired as of and
for the period ended March 31, 2009.

     Thank you for your time and consideration. I look forward to discussing these items with you
and your colleagues as needed. My contact information is (706) 317-6495 or rrogers@aflac.com.

Sincerely,

/s/ Ralph A. Rogers, Jr.

Ralph A. Rogers, Jr.

    cc:

    Vanessa Robertson, Staff Accountant

Joel Parker, Accounting Branch Chief

Scot Foley, Staff Attorney

Suzanne Hayes, Legal Branch Chief

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