SecProbe.io

Via Facsimile and U.S. Mail
Mail Stop 6010

         June 1, 2007

Kenneth W. Stecher
Chief Financial Officer, Executive Vice President,
Secretary and Treasurer
Cincinnati Financial Corporation
6200 S. Gilmore Road
Fairfield, Ohio 45014-5141

Re:   Cincinnati Financial Corporation
Form 10-K for the Fiscal Year Ended December 31, 2006
Filed February 28, 2007
File Number:  000-04604

Dear Mr. Stecher:

We have limited our review of your filing to  the issues we have addressed in our
comments.  In our comments, we ask you to pr ovide us with additional information so we
may better understand your disclosures.  Afte r reviewing this info rmation, we may raise
additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K – December 31, 2006

Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 31

Critical Accounting Estimates, page 35

Property Casualty Insurance Loss a nd Loss Expense Reserves, page 35

1. We believe your disclosure in the Cr itical Accounting Estimates section of
MD&A regarding the estimation of the reserve for loss and loss adjustment

Kenneth W. Stecher
Cincinnati Financial Corporation
June 1, 2007 Page 2
expenses could be improved to better explain the judgments and uncertainties
surrounding this estimate and the potential impact on your financial statements.
We believe in order to meet the principa l objectives of MD&A this disclosure
should enable the investor to understand 1) management’s method for establishing
the estimate; 2) whether and if so to  what extent and why management has
adjusted their assumptions used to determine the estimate from the assumptions used in the immediately preceding period a nd 3) the potential va riability in the
most recent estimate and the impact this variability may have on reported results,
financial condition and liquidity.  Please k eep these points in mind in providing us
your responses to comments listed below.  Please provide us, in disclosure-type
format, the following information for each material line of business and also consider providing any additional information, in disclosure-type format, to achieve this objective.
a. Please expand your discussion regarding the methods you used to determine your reserve for loss and loss adjustment expense to include the following:
1. Explain how the methods you use for your short-tail business differ from the methods you use for your long-tail business.
2. Clarify which methods were used to record your reserves.  Include why
you selected each methodology over any of the other methodologies and
whether the same methodology was used for all periods.
3. Describe the method you use to calculate the IBNR reserve for each
material line of business.  For example, we understand that some
companies may calculate this rese rve by estimating the ultimate unpaid
liability first and then reducing that  amount by cumulative paid claims and
by case reserves, but there may be other methods as well.
b. You provide a brief sensitivity analysis on page 36 that appears to be based on a hypothetical change.  The sensitivity  analysis should reflect the dollar
impact of reasonably likely changes in the key assump tions used to determine
the reserves on reported results.  Please provide us with a revised sensitivity
analysis preferably in a tabular form at and explain why management believes
the scenarios quantified ar e reasonably likely.  Also explain to us why you
chose this factor as critical when you make various references throughout your other disclosure related to the importance and impact of severity.
1. Explicitly discuss how the loss and loss expense ratio and the severity
used in your assumptions as of December 31, 2006 are or are not consistent with historical loss reserve development patterns and explain why these assumptions are now a ppropriate given any potential
inconsistency identified.
c. You indicate that reserves are partly based on information obtained from the
appointed actuary.  This reference suggest s to an investor that you are placing
reliance on the firm, which requires the fi rm to be named in a ’34 Act filing.
Please advise.

Kenneth W. Stecher
Cincinnati Financial Corporation
June 1, 2007 Page 3
Liquidity and Capital Resources, page 59

Contractual Obligations, page 61

2. Please provide us with a revised table of c ontractual obligations to present life and
property casualty claims payments on a gr oss basis.  In addition, please ensure
that the amounts shown for net life claims  payments represent the cash outflows
that will be required.  Please  include a footnote to the table that explains why the
amounts in the table do not ag ree to the balance sheet.

* * * *

 Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Pl ease furnish a cover le tter with your response
that keys your response to our comments.  De tailed cover letters gr eatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:

• the company is responsible for the adequacy and accuracy of the disclosure in the filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking a ny action with respect to the filing;
and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

Kenneth W. Stecher
Cincinnati Financial Corporation
June 1, 2007 Page 4
You may contact Vanessa R obertson, Staff Accountant, at (202) 551-3649 or Jim
Atkinson, Accounting Branch Chief, at (202) 551-3674 if you have any questions
regarding the comments.  In th is regard, do not hesitate to  contact me, at (202) 551-3679.

        S i n c e r e l y ,

        J i m  B .  R o s e n b e r g
Senior Assistant Chief
Accountant