SecProbe.io

April 23, 2015

Via E -mail
Mr. Michael Sewell
Chief Financial Officer, Senior Vice President and Treasurer
Cincinnati Financial  Corporation
6200 S. Gilmore Road
Fairfield, O H  45014 -5141

Re: Cincinnati Financial Corporation
Form 10 -K for the Fiscal Year December 31 , 2014
Filed February 27, 2015
File No. 000-04604

Dear Mr. Sewell :

We have reviewed the above  filing  and have the following comments .  In our comment s,
we ask you to provide us with information so we may better understand 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  that a comment applies to your facts and circumstances, please tell us why in your
response.  Please furnish us a letter on EDGAR under the form type label CORRESP that keys
your response s to our comment s.

After reviewing the information provided, we ma y raise additional comments and/or
request that you amend your filing.

Notes to Consolidated Financial Statements
Note 3 – Fair Value Measurements
Fair Value Hierarchy, page 137

1. Please refer to your disclosure of investments herein and in Note 2 .  Please provide us
analyses under ASC 320 -10-50-1B and ASC 820 -10-50-2B supporting your presentation s
of investments  by “major security types” and “classes.”  In this regard, tell us why you
did not furt her disaggregate your corporate and s tates, municipalit ies and political
subdivisions  fixed maturity securities and your common equities.  With respect to
corporate fixed maturity securities and common equities, y our disclosure on page s 27 and
29 suggests that further disaggregation by industry sector for cert ain sectors may be
necessary.   Regarding your tax -exempt fixed maturity securities, your disclosure on page
28 suggests that further disaggregation by general and special obligation bonds and
perhaps for Texas may be necessary .

Mr. Michael Sewell
Cincinnati Financial  Corporation
April 23, 2015
 Page 2

 2. Please provide us, for each  “class” (see comment 1 above) of Level 2 fixed maturity
securities, the inputs used in your fair value measurement.  Refer to ASC 820 -10-50-2bbb.

We urge all persons who are responsible for the 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 require.   Since the compan y 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.

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

 In responding t o our comments , please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy and accura cy of the disclosure 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 p roceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Senior Staff Accountant  Keira Nakada at (202) 551 -3659 .  In this
regard, do not hesitate to contact me at (202) 551 -3679.

Sincerel y,

 /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant