LETTER 1 filename1.txt UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-5546 DIVISION OF CORPORATION FINANCE Mail Stop 5546 December 6, 2005 Via US Mail and Facsimile Patrick Ryan Chairman and CEO Aon Corporation 200 E. Randolph Street Chicago, IL 60601 Re: Aon Corporation Form 10-K for the Fiscal Year Ended December 31, 2004 Filed June 2, 2005 File No. 001-07933 Dear Mr. Ryan: We have reviewed your response letter dated November 15, 2005 and have the following comment. At this juncture, we are asking you to provide us with supplemental information, so that we may better understand your disclosure. Please be as detailed as necessary in your response. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. General 1. We note your response to prior comment two from our letter dated October 18, 2005. Please provide a summary of the Compliance Department`s report as soon as practicable following its completion. Address for us the materiality of your subsidiaries` activities relating to Iran, and whether those activities constitute a material investment risk to your security holders, in light of the impact your status as a company whose subsidiaries do business in and/or with a U.S.-designated terrorist-sponsoring state may have upon your reputation and share value. Provide us with both your conclusion and your underlying analysis. In your response, please discuss investor concern regarding investment in companies that do business with such states, as evidenced by the Arizona and Louisiana legislation referenced in our October 18 letter. Please understand that we may have additional comments after reviewing your response to our comment. Please file your response letter on EDGAR. Please contact James Lopez at (202) 551-3536 if you have any questions about the comments or our review. You may also contact me at (202) 551-3470. Sincerely, Cecilia D. Blye, Chief Office of Global Security Risk cc: Jeff Riedler Assistant Director Division of Corporation Finance Mr. Patrick Ryan Aon Corporation December 6, 2005 Page 1