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May 6, 2015

Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

Division of Corporation Finance

United States Securities and Exchange Commission

Washington, D.C. 20549

 Re: Cincinnati Financial Corporation

Form 10-K for the Fiscal Year December
31, 2014

Filed February 27, 2015

File No. 000-04604

Dear Mr. Rosenberg:

We have received your letter dated April 23, 2015, in response
to our Annual Report on Form 10-K for the fiscal year ended December 31, 2014. We appreciate that your review was intended to assist
us in our compliance with applicable disclosure requirements and to enhance the overall disclosure in our filings.

The following reflects our careful review of the comments you
provided (keyed to your letter dated April 23):

Notes to Consolidated Financial Statements

Note 3 – Fair Value Measurements

Fair Value Hierarchy, page 137

COMMENT 1.

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 presentations of investments
by “major security types” and “classes.” In this regard, tell us why you did not further disaggregate your
corporate and states, municipalities and political subdivisions fixed maturity securities and your common equities. With respect
to corporate fixed maturity securities and common equities, your disclosure on pages 27 and 29 suggests that further disaggregation
by industry sector for certain 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.

RESPONSE TO COMMENT 1:

In determining the appropriate presentation of investments by
“major security types” and “classes” within Note 3 – Fair Value Measurements and Note 2 – Investments
of our Form 10-K for the fiscal year ended December 31, 2014, we considered the guidance under ASC 320-10-50-1B, Investments-Debt
and Equity Securities-Overall-Disclosure, which states:

“Major security types shall be based on the
nature and risks of the security. In determining whether disclosure for a particular security type is necessary and whether it
is necessary to further separate a particular security type into greater detail, an entity shall consider all of the following:

a. (Shared) activity or business
sector

b. Vintage

c. Geographic concentration

d. Credit quality

e. Economic characteristic.”

We also took into consideration guidance under ASC 820-10-50-2B,
Fair Value Measurement-Overall-Disclosure, which states:

“A reporting entity shall determine appropriate
classes of assets and liabilities on the basis of the following:

a. The nature, characteristics,
and risks of the asset or liability

b. The level of the fair value hierarchy within
which the fair value measurement is categorized.

The number of classes may need to be greater for fair
value measurements categorized within Level 3 of the fair value hierarchy because those measurements have a greater degree of uncertainty
and subjectivity. Determining appropriate classes of assets and liabilities for which disclosures about fair value measurements
should be provided requires judgment. A class of assets and liabilities will often require greater disaggregation than the line
items presented in the statement of financial position. However, a reporting entity shall provide information sufficient to permit
reconciliation to the line items presented in the statement of financial position. If another Topic specifies the class for an
asset or a liability, a reporting entity may use that class in providing the disclosures required in this Topic if that class meets
the requirements in this paragraph.”

Corporate Fixed-Maturity Securities

One of our fixed-maturity major security types is corporate
securities. We identify corporate fixed-maturity securities as a major security type since these securities are similar in nature
and risk and are different from other types of fixed-maturity securities. The economic characteristics that corporate fixed-maturity
securities share include: issuance by corporations versus the government; the interest received is taxable versus non-taxable securities;
the effective interest rate is generally higher than non-taxable securities; the diverse revenue source used to repay the security
is from the selling of products/goods/services from corporations; similar credit quality (approximately 94% are investment grade);
and the ability to make future principal and interest payments. These economic characteristics are the unique distinctions that
we consider when purchasing or holding a corporate fixed-maturity security and all of our corporate fixed-maturity securities have
these characteristics.

In addition, we considered business sector, vintage and geographic
concentration. We concluded that none of these characteristics provide for a unique major security type:

 · Business sector – We have no significant concentration in any
one sector, and we do not believe repayment ability or effective interest rate is directly or indirectly tied to business sector.
As of December 31, 2014, the largest concentration within a single business sector was insurance, which consists of $758 million
in fair value, representing 13.7% of the corporate fixed-maturity portfolio or 8.0% of total fixed maturities.

 · Vintage – We have no concentration in any one contractual maturity
period.

 · Geographic concentration – All corporate fixed-maturity securities
in our portfolio are issued by domestic or multinational corporations that have a diverse source of geographic revenues supporting
the securities.

Based on our analyses of the nature and risks of these securities,
we have concluded that further disaggregation by sector, vintage, geographic concentration, credit quality or economic characteristics
is not required. While we may include supplementary information on page 27 of our Form 10-K for the fiscal year ended December
31, 2014, relating to investment-grade and below investment-grade holdings, this disclosure affirms that further disaggregation
by credit quality provides little differentiation within our corporate fixed-maturities major security type. We believe our current
disclosure in Notes 2 - Investments and 3 – Fair Value Measurements, identifying corporate fixed-maturity securities as a
single major security type, is in accordance with ASC 320-10-50-1B and ASC 820-10-50-2B.

States, Municipalities and Political Subdivisions Fixed-Maturity
Securities

A second fixed-maturity major security type is states, municipalities
and political subdivisions securities. We identify states, municipalities and political subdivisions fixed-maturity securities
as a major security type since these securities are similar in nature and risk and are different from other types of fixed-maturity
securities. The economic characteristics, business sector and credit quality that these securities share include: issuance and
management by a governmental entity; included in the public sector; similar source of funding from a taxing authority; support
exclusively or in part by a governmental entity or otherwise authorized entity to collect taxes or other pertinent revenue; the
interest received is generally tax exempt; 98% of the securities are investment grade; and generally issuance for public projects,
public infrastructure or public benefit. These characteristics are the unique distinctions that we consider when purchasing or
holding a state, local municipality and political subdivision fixed-maturity security.

In addition, we considered vintage and geographic concentration.
We concluded that these characteristics do not provide for a unique major security type:

 · Vintage – We have no concentration in any one contractual maturity
period.

 · Geographic concentration – Since locally issued bonds and special
revenue bonds are issued in various municipalities throughout a given state and they are not financially dependent on each other
or the state they are issued in, there is no geographic concentration or dependence on the financial stability of a given state.
For example, within Texas, the $439 million fair value of securities on page 28 of our Form 10-K for the year ended December 31,
2014, were issued from approximately 166 municipalities that are geographically diverse. They are not dependent upon each other
or guaranteed by each other and do not represent an obligation of the State of Texas.

Based on our analyses of the nature and risks of these securities,
we have concluded that further disaggregation by sector, vintage, geographic concentration, credit quality or economic characteristic
is not required. The supplemental information on page 28 of our Form 10-K for the fiscal year ended December 31, 2014, which summarizes
more than 1,500 municipal bond issues, was provided starting with our Form 10-K for fiscal year ended 2010 to demonstrate our well
diversified investment portfolio and the lack of significant concentration. During this time period, certain states exhibited financial
stress and we added this disclosure to demonstrate the lack of exposure to any single state or municipality. We believe our current
disclosure in Notes 2 and 3, identifying states, municipalities and political subdivisions fixed-maturity securities as a single
major security type, is in accordance with ASC 320-10-50-1B and ASC 820-10-50-2B.

Common Equity Securities

We identify common equities as a major security type, since
these securities are similar in nature and risk. Our approach to purchasing or holding a common equity over the past 40 plus years
is to identify corporations that pay a dividend and have a history or potential ability of increasing their dividend on an annual
basis. If a common equity ceases paying a dividend, it is generally removed from our portfolio. These common equities are also
mainly blue chip companies that have had the ability to increase dividends over the long term. In terms of economic characteristics,
71 of the 72, or 98% of the common equity portfolio fair value, are United States domiciled corporations. They are all dividend-paying.
They all historically increase their dividend, and they have a history of stable earnings and stock price increases. Further disaggregation
based upon vintage, geographic location or credit quality was considered, but deemed either not applicable or to not provide unique
characteristics that differentiate the underlying nature and risk. In addition, we considered whether activity or business sector
within this major security type required further disaggregation; however, we note that such does not change the nature and risk
of dividend-paying stocks. Rather, the nature and risk is driven by strength in the balance sheet of the issuer, strong history
of earnings and a proven track record of paying dividends regardless of the underlying sector or industry.

Supplemental business description information provided for our
common equities by industry sector on page 29 of our Form 10-K for the fiscal year ended December 31, 2014, is supplementary disclosure
we started in 2009 following the market decline to illustrate the diversification of our investment portfolio, as well as to compare
to the S&P 500 Industry Weightings. This information demonstrates a lack of significant concentration in any single industry
or sector. We consider the industry sector information to be appropriate for inclusion in Item 1 of our Form 10-K; however, this
information is not representative of a difference in the nature and risks of our common equities. As such, we believe our current
disclosure in Notes 2 and 3, identifying common equities as a single major security type, is in accordance with ASC 320-10-50-1B
and ASC 820-10-5-2B.

COMMENT 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.

RESPONSE TO COMMENT 2:

As identified in our response to comment 1 above, our class
of Level 2 fixed-maturity securities consist of corporate and states, municipalities and political subdivisions. Our Level 2 fixed-maturity
securities also include commercial mortgage-backed, government-sponsored enterprises, foreign government, and convertibles and
bonds with warrants attached. We referred to the guidance under ASC 820-10-50-2bbb, which states the following requirements:

“For recurring and
nonrecurring fair value measurements categorized within Level 2 and Level 3

of the fair value hierarchy, a description
of the valuation technique(s) and the inputs used in the fair value measurement.

If there has been a change in valuation
technique (for example, changing from a market approach to an income approach or the use of an additional valuation
technique), the reporting entity shall disclose that change and the reason(s) for making it.

For fair value measurements
categorized within Level 3 of the fair value hierarchy, a reporting entity shall provide quantitative information about the significant
unobservable inputs used in the fair value measurement. A reporting entity is not required to create quantitative information to
comply with this disclosure requirement if quantitative unobservable inputs are not developed by the reporting entity when measuring
fair value (for example, when a reporting entity uses prices from prior transactions or third-party pricing information without
adjustment). However, when providing this disclosure, a reporting entity cannot ignore quantitative unobservable inputs that are
significant to the fair value measurement and are reasonably available to the reporting entity.”

All asset classes of fixed-maturity securities that we own share
common characteristics of contractual provisions that define the amount and timing of cash flows and therefore can be valued using
standardized and widely accepted methodologies that rely upon a common set of inputs. Commercial mortgage-backed fixed-maturity
securities can have more variable cash flows within the contractual provisions and therefore require additional analysis and inputs
to appropriately determine a valuation.

The valuation techniques and inputs we use in our fair value
measurement for each class of Level 2 fixed-maturity securities are as follows:

Corporate (which includes convertibles and bonds with warrants
attached) securities are valued using methodologies that model information generated by market transactions involving
identical or comparable assets, as well as discounted cash flow methodologies. Common inputs include prices from recently executed
transactions of similar securities, market place quotes, benchmark yields, spreads off benchmark yields, interest rates and U.S.
Treasury or swap curves.

States, municipalities and political subdivisions securities
are valued using methodologies that model

information generated by market transactions involving identical
or comparable assets, as well as discounted cash flow methodologies. Common inputs include prices from recently executed transactions
of similar securities, market place quotes, benchmark yields, spreads off benchmark yields, interest rates and U.S. Treasury or
swap curves.

Government-sponsored enterprises securities are valued
using methodologies that model information generated by market transactions involving identical or comparable assets, as well as
discounted cash flow methodologies. Common inputs include prices from recently executed transactions of similar securities, market
place quotes, benchmark yields, spreads off benchmark yields, interest rates and U.S. Treasury or swap curves.

Commercial mortgaged-backed securities are valued using
methodologies that model information generated by market transactions involving identical or comparable assets, as well as discounted
cas