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AFLAC INCORPORATED

Ralph A. Rogers, Jr.

Senior Vice President

Chief Accounting Officer

Financial Services

October 1, 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, DC 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 received your letter dated September 24, 2007 and offer the following responses to your
comments. We have listed your comments for ease of reference. The responses are presented in
disclosure format.

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

Critical Accounting Estimates, page II-6

Policy Liabilities, page II-8

Comment:

    1.

    Please refer to your second point in response to comments 1 and 2 regarding the
transfer of $170 million from the unpaid policy claim liability to the future policy
benefits liability. You state that $95 million was transferred from unpaid policy claim
liability to future policy benefit liability because you believe that the total policy
liability is appropriate. Please clarify in your proposed disclosure your justification
for transferring
the $95 million to future policy benefit liability as it is not clear from your discussion
as

    to what assumptions changed in your future policy benefit liability that would increase
the liability by $95 million.

Response:

    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. As we have developed experience on the dental and specified health
event product lines, we have modified our assumptions as to the impact of underwriting
selection. Our experience has shown that the underwriting selection impact is greater than
we had anticipated in our original pricing. In addition, for our dental plan, we have also
modified our assumption as to the impact of the various benefit waiting periods for that
plan to reflect the larger than anticipated impact of the waiting periods. Both of these
changes in assumptions resulted in current period claims being lower than anticipated in
the original pricing assumptions for these two products. Thus, our unpaid claims liability
is lower than we originally estimated. However, our analysis also shows that the future
claim cost curve will be steeper than we originally anticipated. Thus, we expect more
future claims than we previously estimated and increased our liability for future policy
benefits accordingly. For this reason, 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. As a result, the modification in methodology resulted in a transfer from the
unpaid policy claims liability of approximately $95 million to the future policy benefits
liability.

Comment:

    2.

    Refer to your third point in response to comments 1 and 2 regarding the transfer of the
$85 million reserve from unpaid policy claim liability to future policy benefit liability
in the fourth quarter of 2006. Please clarify in your proposed disclosure why there is a
relationship between a decrease in unpaid policy claim liability due to reduced hospital
days and an increase in the future policy benefit liability. Clarify what assumptions
changed in calculating your future policy benefit liability that would cause the increase
in the liability.

Response:

    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 and had no effect on net earnings. Our 2006 claims review
indicated that we have experienced a continued decline in the average number of in-hospital
days associated with the typical cancer treatment period in Japan. We believe the average
number of days per hospital visit 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 future hospitalizations associated with the treatment of cancer. As a
result, we reflected the increased number of future hospitalizations per claimant in our
future policy benefit liability. More hospitalizations per claimant will result in a larger
amount of expected future claims and an increase in our liability for future policy
benefits. Meanwhile, we are paying less for current period claims, and therefore have a
smaller unpaid claims liability.

Thank you for your time and consideration. My contact information is (706) 317-6495 or
rrogers@aflac.com.

Sincerely,

/s/ Ralph A. Rogers, Jr.

Ralph A. Rogers, Jr.

    cc:

    Tabatha Akins, Staff Accountant

    Mary Mast, Senior Accountant