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RESPONSE LETTER TO THE SEC

Ralph A. Rogers, Jr.

Senior Vice President

Chief Accounting Officer

August 29, 2007

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, 2006

    Filed February 28, 2007

    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.

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
II-5

Comment:

Critical Accounting Estimates, page II-6

Policy Liabilities, page II-8

    1.

    It appears that you have significantly revised your estimate of the liability for unpaid
policy claims recorded in prior years. Please provide us, using disclosure-type format,
proposed revisions to your existing disclosure an explanation of the reasons for your change
in estimate. For each liability and lines of business, please include the following
disclosures:

    a.

    Identify the years to which the change in estimate relates and disclose the
amount of the related liability as of the beginning of the year that was re-estimated.
Discuss and quantify offsetting changes in estimates that increase and decrease the
liability.

    b.

    Identify the changes in the key assumptions you made to estimate the liability
since the last reporting date.

    c.

    Identify the nature and timing of the change in estimate, explicitly
identifying and describing in reasonable specificity the new events that occurred or
additional information acquired since the last reporting date that led to the change in
estimate.

    d.

    Ensure your disclosure clearly explains why recognition occurred in the periods
that it did and why recognition was not required in earlier periods.

    We acknowledge that we previously commented on this matter in comment three of our January
7, 2004 comment letter. While your January 16, 2004 response stated that you would address
this comment in future filings, we are unsure how the current discussion addresses these
areas.

    2.

    Please provide us, using disclosure-type format, proposed revisions to your existing
disclosure clarifying the specific reasons for the substantial increase in your liabilities
for future policy benefits. In addition, please state why the increase in the U.S. and Japan
future policy benefit reserves of $170 million and $85 million in the fourth quarter of 2006
was necessary. Clarify what assumptions changed that required the increase in the reserve.

Response:

Below is
our response to comments 1. and 2. in disclosure format.

Policy Liabilities

     The following table provides details of policy liabilities by segment and in total as of
December 31.

    Policy Liabilities

    (In
millions)

    2006

    2005

    U.S. segment:

    Future policy benefits

    $
    4,391

    $
    3,780

    Unpaid policy claims

    816

    848

    Other policy liabilities

    158

    143

    Total U.S. policy liabilities

    $
    5,365

    $
    4,771

    Japan segment:

    Future policy benefits

    $
    36,447

    $
    34,071

    Unpaid policy claims

    1,574

    1,657

    Other policy liabilities

    2,051

    1,828

    Total Japan policy liabilities

    $
    40,072

    $
    37,556

    Consolidated:

    Future policy benefits

    $
    40,841

    $
    37,853

    Unpaid policy claims

    2,390

    2,504

    Other policy liabilities

    2,209

    1,972

    Total consolidated policy liabilities

    $
    45,440

    $
    42,329

     Our policy liabilities, which are determined in accordance with SFAS No. 60 and Actuarial
Standards of Practice, include two primary components: future policy benefits and unpaid policy
claims, which accounted for 90% and 5% of total policy liabilities as of December 31, 2006,
respectively.

     Future policy benefits provide for claims that will occur in the future and are generally
calculated as the present value of future expected benefits to be incurred less the present value
of future expected net benefit premiums. We calculate future policy benefits based on assumptions
of morbidity, mortality, persistency and interest. These assumptions are generally established at
the time a policy is issued. The assumptions used in the calculations are closely related to those
used in developing the gross premiums for a policy. As required by GAAP, we also include a
provision for adverse deviation, which is intended to accommodate adverse fluctuations in actual
experience.

     Unpaid policy claims include those claims that have been incurred and are in the process of
payment as well as an estimate of those claims that have been incurred but have not yet been
reported to us. We compute unpaid policy claims on an undiscounted basis using statistical analyses
of historical claims payments, adjusted for current trends and changed conditions. We update the
assumptions underlying the estimate of unpaid policy claims regularly and incorporate our
historical experience as well as other data that provides information regarding our outstanding
liability.

     Our insurance products provide fixed-benefit amounts that are not subject to medical-cost
inflation. Furthermore, our business is widely dispersed in both the United States and Japan. This
geographic dispersion and the nature of our benefit structure mitigate the risk of a significant
unexpected increase in claims payments due to epidemics and events of a catastrophic nature. Claims
incurred under Aflac’s policies are generally reported and paid in a relatively short time frame.
The unpaid claims liability is sensitive to morbidity assumptions, in particular, severity and
frequency of claims. Severity is the ultimate size of a claim, and frequency is the number of
claims incurred. Our claims experience is primarily related to the demographics of our
policyholders.

     As a part of our established internal control processes, we perform actuarial reviews of our
policyholder liabilities on an ongoing basis. Our fourth quarter 2006 review indicated that in
total our policyholder liabilities were fairly stated in the aggregate; however, the components,
the unpaid policy claims liability and the future policy benefits liability, of policyholder
liabilities needed to be refined. As a result of our review, we took three actions.

    1.

    During the fourth quarter of 2006, we increased Aflac’s U.S. unpaid policy claims
liability by $28 million. As part of our analysis of recent cancer claims experience, we
noted that the overall duration of cancer outpatient treatments has lengthened. Since
our reserving methods are designed to fully accrue each cancer outpatient treatment as
of the date of initial treatment, we increased our estimate of the Aflac U.S. unpaid
policy claims liability by $28 million. This change in estimate is reflected in current
year’s earnings. If we had been using the new claims factors to produce our claim
liability estimates at the end of 2005, the increase for 2006 would have been $9
million. We expect that the annual impact on future earnings will be approximately $9
million.

    2.

    During the fourth quarter of 2006, we transferred $170 million of the Aflac U.S.
unpaid policy claims liability to the future policy benefits liability in our
accident/disability, short term disability, dental and specified health event lines of
business. For the accident/disability line of business, a very small portion of the
benefits in one of our policy forms required a future policy benefits liability to be
accumulated. This amount was insignificant to our financial position in any year,
however, to provide for this obligation, we approximated this liability amount as part
of the unpaid policy claims liability. We determined that it was appropriate to modify
our calculation method to determine the future policy benefits liability for that
benefit separately from our unpaid policy claims liability and to move this liability of
$25 million into the future policy benefits liability. An additional $50 million
transfer to future policy benefits resulted from the updated calculation of the future
policy benefits liability in our short-term disability product line. In the
fourth quarter of 2006, we determined that a selection factor assumption that
should have applied to the future claim costs for that policy form was not reflected in
the calculation of the future policy benefits liability. We began using the calculation
including the selection factor in the fourth quarter of 2006. We use a total
liability calculation to determine the unpaid policy claims liability for that line of
business. For this reason, the underestimated amount of the future policy benefits
liability, approximately $50 million, was accounted for in prior periods in the unpaid
policy claims liability. As a result, we transferred $50 million from the unpaid policy
claims liability into the future policy benefits liability for that line of business.
The remaining $95 million reduction in the Aflac U.S. segment unpaid policy claims
liability resulted from a refinement in the reserving methodology for our dental and
specified health event product lines. Both of these are very recently introduced
product lines where we had limited actual experience. For this reason, we have
determined our policy liabilities for these two product lines using a total liability
approach. This approach utilized expectations of claims costs and impact of
underwriting based largely on the product pricing assumptions. However, in the
fourth quarter of 2006, we modified our methodology to use a combination of
claim cost expectations and claim completion factors to calculate the unpaid policy
claims liability for these two product lines. However, we believe that the total policy
liability that we are holding is appropriate. For this reason, the modification in
methodology resulted in a reduction in the unpaid policy claims liability of
approximately $95 million and an increase in the future policy benefits liability of $95
million.

    3.

    Also during the fourth quarter of 2006, we transferred $85 million from Aflac
Japan’s unpaid policy claims liability to its future policy benefits liability. This
transfer was primarily related to a continued decline in current period claims caused by
changes to health care delivery in Japan. Our 2006 claims review indicated that we
experienced a continued decline in the average number of hospital days associated with
the typical cancer treatment period in Japan. We believe the average number of days
declined primarily due to changes in financial incentives provided to hospitals by the
government-sponsored health care system in Japan to shorten the average hospital stay.
However, our claims statistics also indicated that the declines in the average number of
days per hospitalization are generally offset by an increase in the frequency of
hospitalizations associated with the treatment of cancer. This shift reduced current
period claims, and future period claims are anticipated to increase by similar amounts.

     In computing the estimate of unpaid policy claims, we consider many factors, including the
benefits and amounts available under the policy; the volume and demographics of the policies
exposed to claims; and internal business practices, such as incurred date assignment and current
claim administrative practices. We monitor these conditions closely and make adjustments to the
liability as actual experience emerges. Claim levels are generally stable from period to period;
however, fluctuations in claim levels may occur. In calculating the unpaid policy claim liability,
we do not calculate a range of estimates. The following table shows the expected sensitivity of the
unpaid policy claims liability as of December 31, 2006, to changes in severity and frequency of
claims. For the years 2004 through 2006, and before the effect of the fourth quarter 2006
adjustments noted above, our assumptions changed on average by approximately 1% in total, and we
believe that a variation in assumptions in a range of plus or minus 1% in total is reasonably
likely to occur.

    Sensitivity of Unpaid Policy Claims Liability

(In
millions)

    Total Severity

    Decrease

    Decrease

    Increase

    Increase

    Total Frequency

    by 2%

    by 1%

    Unchanged

    by 1%

    by 2%

    Increase by 2%

    $
    —

    $
    16

    $
    31

    $
    48

    $
    65

    Increase by 1%

    (16
    )

    —

    16

    32

    48

    Unchanged

    (31
    )

    (16
    )

    —

    16

    32

    Decrease by 1%

    (47
    )

    (32
    )

    (16
    )

    —

    16

    Decrease by 2%

    (62
    )

    (47
    )

    (31
    )

    (16
    )

    —

     The growth in the future policy benefits liability is the result of the aging of our inforce
block of business and the addition of new business. In addition, the growth in 2006 was moderately
impacted by the transfer of $170 million in the U.S. segment and $85 million in the Japan segment
from the unpaid policy claims liability to the future policy benefits liability that was discussed
above. These two transfers accounted for less than 1% of the increase in the aggregate. The table
below reflects the growth of future policy benefits liability for the years ended December 31.

    Future Policy Benefits

    (In
millions of dollars and billions of yen)

    2006

    2005

    2004

    Aflac U.S.

    $
    4,391

    $
    3,780

    $
    3,354

    Growth rate

    16.2
    %

    12.7
    %

    12.7
    %

    Aflac Japan

    $
    36,447

    $
    34,071

    $
    36,005

    Growth rate

    7.0
    %

    (5.4
    )%

    10.4
    %

    Consolidated

    $
    40,841

    $
    37,853

    $
    39,360

    Growth rate

    7.9
    %

    (3.8
    )%

    10.6
    %

    Yen/dollar exchange rate (end of period)

    119.11

    118.07

    104.21

    Aflac Japan (in yen)

    4,341

    4,023

    3,752

    Growth rate

    7.9
    %

    7.2
    %

    7.4
    %

Comment:

Investments and Cash, page II-28

    3.

    For each of your below-investment-grade securities as listed in the table on II-31 with
unrealized losses as of December 31, 2006, please tell us the specific factors that led to
your conclusion that the unrealized losses were not other-than-temporary at December 31, 2006
and June 30, 2007.

Response:

Our
below-investment-grade holdings are heavily monitored on an ongoing basis throughout each
quarter. While the documentation as follows includes certain data that may not have been available
until after each respective reporting period’s close, most of the data and credit analysis is
performed prior to the end of each quarter. The analyses are then updated shortly after each period
close for certain data.

The
following are executive summaries of our internal analyses of each
below-investment-grade
security and the factors considered, both quantitative as well as qualitative, in determining
whether an other-than-temporary loss had occurred as of and for the end of the periods requested.

Koninklijke Ahold N.V. (Ahold):

Fourth Quarter 2006 analysis

Ahold is a Netherlands-based major food retailer with operations in the Eastern U.S. and Europe.
Ahold’s Stop & Shop and Albert Heijn stores have leading market positions in the northeaster