April 10, 1996




Mr. Michael E. Bartow, CPA
Second Vice President, Financial
AFLAC/AFLAC Incorporated
1932 Wynnton Road
Columbus, GA  31999

Re: AFLAC/AFLAC Incorporated
    File No. 1-7434

Dear Mr. Bartow:

     In a letter dated March 18, 1996, you request, on behalf of
AFLAC/AFLAC Incorporated ("AFLAC"), the staff's view regarding
whether restated financial data schedules need to be filed for
prior periods as a result of a stock split.  You indicate that
Item 601(c) of Regulation S-K (or Regulation S-B for small
business issuers) would appear to require a restatement due to
this recapitalization.

     The staff will not object if a registrant does not restate
prior financial data schedules for a recapitalization that is in
the form of a stock split or reverse stock split, provided that
the <EPS> tag, for the period in which the stock split occurs,
includes a footnote that states that a stock split has occurred
and the effective date of the stock split.  In addition, the
footnote should indicate that prior financial data schedules have
not been restated for this recapitalization.

     If you have any questions concerning this letter, please
call the undersigned at (202) 942-2910 or Diana J. Cravotta,
Assistant Chief Accountant at (202) 942-2960.


                                   Sincerely,




                                   Barbara Jacobs, Chief
                                   Office of Disclosure Policy