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SEC Company Response from AFLAC INC (AFL) (CIK 0000004977) (AFL) — Apr 22, 2008

AFLAC INC (AFL) (CIK 0000004977)
Date: April 22, 2008 · CIK: 0000004977 · Accession: 0000950144-08-003013

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Reasoning

File numbers found in text: 001-07434

Date
April 22, 2008
Author
Ralph A. Rogers, Jr.
Form
CORRESP
Company
AFLAC INC (AFL) (CIK 0000004977)

Letter

Securities and Exchange Commission Aflac Incorporated Form 10-K for the Fiscal Year Ended December 31, 2007 Filed February 29, 2008 File Number: 001-07434

Dear Mr. Rosenberg:

On Wednesday, April 14, 2008, Ms Akins of your staff telephoned to clarify a point related to our response dated March 20, 2008. I expressed verbally in the telephone conversation with Ms. Akins that we do intend to include the information in response to comments 1 and 3, as updated to reflect current conditions and operations, in the disclosures in future filings beginning with the March 31, 2008, Form 10-Q filing. This letter will serve to confirm my conversation with Ms. Akins and to clarify our intentions to include the disclosures requested in future filings beginning with the March 31, 2008, Form 10-Q filing.

We appreciate your consideration and efforts.

Sincerely,
Ralph A. Rogers, Jr.

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CORRESP
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SEC CORRESPONDENCE

Ralph A. Rogers, Jr.

Senior Vice President

Chief Accounting Officer

Financial Services

April 22, 2008

Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

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, 2007

    Filed February 29, 2008

    File Number: 001-07434

Dear Mr. Rosenberg:

On Wednesday, April 14, 2008, Ms Akins of your staff telephoned to clarify a point related to our
response dated March 20, 2008. I expressed verbally in the telephone conversation with Ms. Akins
that we do intend to include the information in response to comments 1 and 3, as updated to reflect
current conditions and operations, in the disclosures in future filings beginning with the March
31, 2008, Form 10-Q filing. This letter will serve to confirm my conversation with Ms. Akins and
to clarify our intentions to include the disclosures requested in future filings beginning with the
March 31, 2008, Form 10-Q filing.

We appreciate your consideration and efforts.

    Sincerely,

Ralph A. Rogers, Jr.

    cc:

    Tabatha Akins, Staff Accountant

    Mary Mast, Senior Accountant