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SEC Comment Letter for CINCINNATI FINANCIAL CORP (CINF) (CIK 0000020286) (CINF) — Mar 14, 2018

CINCINNATI FINANCIAL CORP (CINF) (CIK 0000020286)
Date: March 14, 2018 · CIK: 0000020286 · Accession: 0000000000-18-007882

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File numbers found in text: 000-04604

Date
March 13, 2018
Author
Michael J. Sewell
Form
UPLOAD
Company
CINCINNATI FINANCIAL CORP (CINF) (CIK 0000020286)

Letter

March 13, 2018 Michael J. Sewell Chief Financial Officer, Senior Vice President and Treasurer CINCINNATI FINANCIAL CORP 6200 S. Gilmore Road Fairfield, Ohio 45014-5141 Re:CINCINNATI FINANCIAL CORP Form 10-K for the Year Ended December 31, 2017 Filed February 23, 2018 File No. 000-04604 Dear Mr. Sewell: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to the comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2017 Financial Statements for the year ended December 31, 2017 Note 11-Income Taxes, page 153 1.You state that you expect to complete determination of the effects of the Tax Act on your deferred tax assets and liabilities as part of the annual income tax return filing process which is expected to be completed in the fourth quarter of 2018. Please provide us the following information pursuant to Staff Accounting Bulletin 118: •Qualitative disclosures of the income tax effects of the Act for which the accounting is incomplete; •Disclosures of items reported as provisional amounts; •Disclosures of existing current or deferred tax amounts for which the income tax effects of the Act have not been completed;

FirstName LastNameMichael J. Sewell Comapany NameCINCINNATI FINANCIAL CORP June 16, 2017 Page 2 FirstName LastName Michael J. Sewell CINCINNATI FINANCIAL CORP March 13, 2018 Page 2 •The reason why the initial accounting is incomplete; and •The additional information that is needed to be obtained, prepared, or analyzed in order to complete the accounting requirements under ASC 740. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Mary Mast at (202) 551-3613 or Jim Rosenberg at (202) 551-3679 with any questions. Division of Corporation Finance Office of Healthcare & Insurance

Show Raw Text
March 13, 2018
Michael J. Sewell
Chief Financial Officer, Senior Vice President and Treasurer
CINCINNATI FINANCIAL CORP
6200 S. Gilmore Road
Fairfield, Ohio 45014-5141
Re:CINCINNATI FINANCIAL CORP
Form 10-K for the Year Ended December 31, 2017
Filed February 23, 2018
File No. 000-04604
Dear Mr. Sewell:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we ask you to provide us with
information so we may better understand your disclosure.
            Please respond to the comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to the comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2017
Financial Statements for the year ended December 31, 2017
Note 11-Income Taxes, page 153
1.You state that you expect to complete determination of the effects of the Tax Act on your
deferred tax assets and liabilities as part of the annual income tax return filing process
which is expected to be completed in the fourth quarter of 2018.  Please provide us the
following information pursuant to Staff Accounting Bulletin 118:
•Qualitative disclosures of the income tax effects of the Act for which the accounting is
incomplete;
•Disclosures of items reported as provisional amounts;
•Disclosures of existing current or deferred tax amounts for which the income tax
effects of the Act have not been completed;

 FirstName LastNameMichael J. Sewell
 Comapany NameCINCINNATI FINANCIAL CORP
 June 16, 2017 Page 2
 FirstName LastName
Michael J. Sewell
CINCINNATI FINANCIAL CORP
March 13, 2018
Page 2
•The reason why the initial accounting is incomplete; and
•The additional information that is needed to be obtained, prepared, or analyzed in
order to complete the accounting requirements under ASC 740.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Mary Mast at (202) 551-3613 or Jim Rosenberg at (202) 551-3679 with
any questions.
Division of Corporation Finance
Office of Healthcare & Insurance