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June 3, 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 May 19, 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 May 19):

Notes to Consolidated Financial Statements

Note 3 – Fair Value Measurements

Fair Value Hierarchy, page 137

Comment 1.

Please expand your analyses under ASC 320-10-50-1B and ASC
820-10-50-2B provided in your response to our prior comment 1 to further support your determination of “major security types”
and “classes” of fixed maturity securities. In this regard, your disclosure on page 26 shows significant concentrations
within credit rating categories for your taxable and tax-exempt fixed maturity securities, and your disclosure on page 28 shows
significant concentrations of tax-exempt fixed maturity securities for locally issued general obligation bonds versus special revenue
bonds. Help us understand why these disclosures are material yet further disaggregation under ASC 320-10-50-1B and ASC 820-10-50-2B
is not necessary. Also, compare and analyze the risks and economics by credit rating category and between general obligation versus
special revenue bonds.

Response to Comment 1.

Relevant Accounting Guidance

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.”

We also took into consideration guidance under ASC 942-320-50-2,
Financial Services—Depository and Lending – Investments—Debt and Equity Securities, which states:

“In complying with the requirements in the preceding
paragraph, financial institutions shall include in their disclosure all of the following major security types, although additional
types also may be necessary:

 a. Equity securities, segregated by any one of the following:

 1. Industry type

 2. Entity size

 3. Investment objective

 b. Debt securities issued by the U.S. Treasury and other
U.S. government corporations and agencies

 c. Debt securities issued by states of the United States
and political subdivisions of the states

 d. Debt securities issued by foreign governments

 e. Corporate debt securities

 f. Residential mortgage-backed securities

 ff. Commercial mortgage-backed securities

 fff. Collateralized debt obligations

 g. Other debt obligations.”

Credit Rating Categories Comparison and Analysis of Risk
and Economics

In reference to the disclosure of credit ratings on page 26
of our Form 10-K for the fiscal year ended December 31, 2014, we have compared and analyzed the risks and economics by the various
rating categories below of our taxable and tax-exempt fixed-maturity securities. At the end of our analysis we will provide our
conclusion on whether further disaggregation by major security types and classes are necessary.

The following table recites the definitions we use for investment-grade
(based on classifications as provided by Moody’s, S&P and other commonly accepted definitions) identified on page 26
of our Form 10-K for the fiscal year ended December 31, 2014:

Table 1

The following table recites the definitions we use for non-investment
grade (based on classifications as provided by Moody’s, S&P and other commonly accepted definitions) identified on page
26 of our Form 10-K for the fiscal year ended December 31, 2014:

Table 2

This table below summarizes our fixed maturities yield-to-market
(interest income/fair value) by credit rating category at December 31, 2014:

Table 3

The table below summarizes our other-than-temporary impairments
by credit rating category for the years ended December 31, 2014, 2013 and 2012:

Table 4

We generally do not invest in securities denominated in foreign
currencies. The table below summarizes the fair value of our U.S. dollar denominated and foreign currency denominated fixed-maturity
securities at December 31, 2014:

Table 5

The table below summarizes the fair value for all of our investment-grade,
non-investment grade and nonrated fixed-maturity securities at December 31, 2014:

Table 6

*not rated by Moody’s or S&P, however
approximately 85% are rated in our 2014 Statutory filing as NAIC high quality or higher (i.e. investment grade), investment grade
by Fitch or are insured

Credit Rating Categories Analysis and Conclusion

Our analysis of taxable and tax-exempt fixed maturity securities
considers credit rating categories in the context of ASC 320-10-50-1B, ASC 820-10-50-2B and ASC 942-320-50-2. Although there are
various rating categories that may be assigned to securities that represent incremental levels of creditworthiness, we believe
the most significant delineation among securities with regards to credit ratings is between investment-grade and non-investment-grade
securities. Investment-grade securities are defined as those that have the capacity to meet their financial commitments, while
non-investment grade securities are those that have less than adequate capacity, may have filed bankruptcy or have already failed
to pay one or more of its obligations such that they may be challenged to meet their financial commitments. As defined above, securities
rated BBB or higher are those that have the capacity to meet their financial commitments and are investment-grade securities. Securities
rated BB or lower are those that may be challenged to meet their financial commitments. Therefore we considered whether our investment-grade
and non-investment grade securities should be considered separate classes of assets or major security types for purposes of financial
statement disclosure.

Note that a small portion of our portfolio represents securities
that are not rated by either Moody's or S&P but generally are rated in our 2014 statutory filing as NAIC high quality or higher,
investment grade by Fitch or are insured. For simplicity, we have defined these securities as nonrated for purposes of our discussion
herein.

In assessing our fixed-maturity securities, we considered the
characteristics of the investment-grade and non-investment grade securities within our portfolio. We first considered the interest
rates of the securities within the three categories. In table 3 above, we illustrate the low, high, and average interest
rates by credit rating for our fixed maturity securities. In every rating level, the low and high rates overlap each other and
thus there are no defining lines. What exist are common interest rates within, and across, each of the various rating categories.
With overlapping interest rates and commonality among the average rates, we do not believe that the interest rates on our fixed-maturity
securities represent a characteristic that varies in any significant or meaningful way between investment-grade, non-investment-grade,
or nonrated securities.

We further considered the history of other-than-temporary impairments
for the most recent three years ended December 31, by investment-grade, non-investment grade, and nonrated securities, which are
presented in table 4. Based on the lack of any significant impairments across all security types, we do not believe that
this represents a characteristic that varies significantly that would suggest a level of differentiation that would require the
identification of additional major security types or classes to be reported resulting from non-payment risk.

Finally, we considered the currency denomination of our investment-grade,
non-investment grade, and nonrated securities. We note that table 5 illustrates our fixed-maturity securities that are in
the United States dollar denomination or a foreign currency denomination. At December 31, 2014, all of our fixed-maturity securities
are in the United States dollar denomination and therefore we do not believe currency denomination represents a characteristic
that varies in any significant or meaningful way that would require the identification of additional major security types or classes.

In addition to the assessment of the characteristics of our
securities by credit rating category above, we considered the materiality of the different rating categories at December 31, 2014.
In table 6 above, we have segregated our fixed-maturity portfolio into investment-grade, non-investment-grade, and nonrated
securities. The investment-grade securities represent 93.9% of the portfolio while the non-investment-grade and nonrated represent
only 3.4% and 2.7% of the portfolio, respectively. Because such a significant portion of our fixed-maturity securities is investment-grade
and the remaining is not, we further believe that separating non-investment grade securities as a separate class or major security
type would not provide meaningful information due to their immateriality to our financial statements.

Based on the expanded analysis performed above on our fixed-maturity
securities, including our response to the SEC's prior comment 1, we conclude that no additional major security types or classes
exist in our portfolio of fixed maturities for which additional disaggregation and disclosure would be material or required. The
disclosure on page 26 of our Form 10-K for the fiscal year ended December 31, 2014, related to credit rating categories is considered
by us to be supplemental disclosure and  not meant to be material disclosure. To avoid confusion in the future, we will remove
the credit rating table on page 26 and include the following supplemental information in our future SEC filings: Our investment-grade
and non-investment grade fixed-maturity securities represent 94% and 3% of the portfolio, respectively. The remaining 3% represents
fixed-maturity securities that are not rated by Moody's or S&P.

General Obligation and Special Revenue Bonds (Municipal
Bonds) Comparison and Analysis of Risk and Economics

In reference to the disclosure of our municipal bonds on page
28 of our Form 10-K for the fiscal year ended December 31, 2014, we have compared and analyzed the risks and economics by general
obligation and special revenue bonds below. At the end of our analysis we will provide our conclusion on whether further disaggregation
by general obligation and special revenue bonds is necessary.

Municipal Bonds

Municipal bonds are debt issued by states, cities, and counties
to fund projects. Interest paid by the issuer to bond holders is often exempt from all federal taxes, as well as state or local
taxes depending on the state in which the issuer is located, subject to certain restrictions. Generally, interest paid on bonds
that are issued for the general purpose of a governmental entity or to fund projects that are constructed for the public good are
generally exempt from federal income tax, while interest earnings on bonds issued to fund projects partly or wholly benefiting
only private parties, sometimes referred to as private activity bonds, may be subject to federal income tax. However, qualified
private activity bonds, whether issued by a governmental unit or private entity, are exempt from federal taxes because the bonds
are financing services or facilities that, while meeting the private activity tests, are needed by a government. Municipal bonds
fall into several categories. The main types are general obligation bonds and special revenue bonds.

General obligation bonds are bonds that are backed by
the “full faith and credit” of the issuer, with no specific project identified as the source of funds to pay the interest
or repay the debt.

In other words, the issuer can make interest and principal payments
using any source of revenue, such as tax revenues, fees, or the issuance of new securities, and if it encounters fiscal difficulty
it can raise taxes or fees to offset the shortfall. General obligation bonds are therefore seen as being relatively safe, and defaults
are rare. Investors can buy general obligation bonds directly, but there are also a number of mutual funds that specialize in general
obligation bonds.

Special revenue bonds are bonds that are backed by the
revenue generated by the specific project being financed by the bond issue. In other words, the money raised by the bond offering
finances the project, and the project – once complete – generally generates the revenues to pay the interest and principal
on the bonds. Projects could include water works, sewers, hospitals, airports, toll roads, housing projects, convention centers,
bridges, and similar endeavors.

Special revenue bonds are generally higher risk than general
obligation bonds, and they typically offer higher yields. But they are not generally defined as high risk bonds and in fact, they
are assigned a similar rating as general obligation bonds.

Within the special revenue bond category, there are “essential
services” special revenue bonds, which include projects related to water, sewer, and power systems. Since the revenue
from such projects is seen as being more reliable, essential services special revenue bonds are seen as being lower-risk than bonds
financed by revenue from non-essential services.

Typically, most bond fund managers will invest in a combination
of general obligation and special revenue bonds due to the similarities.

The following table lists a multitude
of characteristics that are, in most cases, shared by general obligation and special revenue bonds:

Table 7

The table below provides the fair values
for our general obligation and special revenue bonds by rating category at December 31, 2014:

Table 8

Yield-to-market at December 31, 2014,
for ou