SecProbe.io

April 26, 2012

Via E-mail
Mr. Michael J. Sewell Chief Financial Officer, Senior  Vice President 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, 2011
Filed February 29, 2012
File No. 000-04604

Dear Mr. Sewell:

We have reviewed your filing and have the following comments.  In our comments, we
ask you to provide us with information so  we may better underst and your disclosure.

Please respond to this letter within 10  business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe a comment applies to your facts and circ umstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the fo rm type label CORRESP that keys your
responses to our comments.
 After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing.

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

Executive Summary, page 38

1. Please tell us why you refer to a mortgage and financial guaranty segment which does not
appear to be reported in your financial statements.
 2012 Reinsurance Programs, page 98

2. You disclose that, if the pool pa rticipants and reinsu rers that participated in USAIG were
unable to fulfill their financial obligations a nd all security collater al that supports the
participants’ obligations became worthless, you could be liable for an additional pool
liability of $220 million and your financial pos ition and results of operations could be
materially affected. Please provide us furthe r information regarding the terms of this
arrangement that could cause you to be liabl e for this additional  pool liability, your
accounting treatment and an analysis of the accounting literature supporting your

Mr. Michael J. Sewell
Cincinnati Financial Corporation
April 26, 2012
  Page 2

 treatment. In your response, also tell us th e names of pool participants and reinsurers,
their A.M. Best Ratings, the amounts owed by each participant a nd reinsurer and the
amount of any disputed items.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In responding to our comments, please provi de a written statement from the company
acknowledging that:

 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Please contact Ibolya Ignat, Staff Account ant, at (202) 551-3656 or Gus Rodriguez,
Accounting Branch Chief, at (202) 551-3752 if you have questions regarding the comments.  In
this regard, do not hesitate to contact me at (202) 551-3679.

Sincerely,
   /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant