July 29, 2019

Carol B. Yancey
Chief Financial Officer
Genuine Parts Company
2999 Wildwood Parkway
Atlanta, Georgia 30339

       Re: Genuine Parts Company
           Form 10-K for the Year Ended December 31, 2018
           Filed February 25, 2019
           File No. 001-05690

Dear Ms. Yancey:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Measures, page 21

1.    We note that your current disclosure about the usefulness of your
non-GAAP measures
      indicates that you believe that the presentation of adjusted net income
and adjusted net
      income per common share is indicative of the company's core operations.
Please revise to
      provide a more substantive discussion of how your non-GAAP measures are
useful to
      investors. Refer to Item 10(e)(1)(i)(C) of Regulation S-K. Earnings
releases on Forms 8-
      K should be similarly revised.
Item 9A. Controls and Procedures
Management's conclusion regarding the effectiveness of disclosure controls and
procedures,
page 27

2.    We note in the first paragraph of this section that you discuss
management's evaluation of
 Carol B. Yancey
Genuine Parts Company
July 29, 2019
Page 2
         the the effectiveness of disclosure controls and procedures, however,
the conclusion
         references your internal control over financial reporting instead of
disclosing the
         conclusion of the effectiveness of your disclosure controls and
procedures. Please amend
         the filing to disclose the conclusion of your principal executive and
principal financial
         officers regarding the effectiveness of the company's disclosure
controls and procedures
         as of the end of the period covered by the report. In doing so, please
ensure that your
         certifications reference the Form 10-K/A. and are currently dated.
Refer to Item 307 of
         Regulation S-K. Your Form 10-Qs for the quarters ended March 31, 2019
and June 30,
         2019 should be similarly amended.
Financial Statements
Notes to Consolidated Financial Statements
2. Revenue Recognition, page F-13

3.       Please disclose the nature and amount of any contract assets and
contract liabilities along
         with the applicable disclosure requirements in ASC 606-10-50-8 through
10.
        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 Heather Clark at 202-551-3624 or Claire Erlanger at
202-551-3301 with
any questions.



FirstName LastNameCarol B. Yancey                              Sincerely,
Comapany NameGenuine Parts Company
                                                               Division of
Corporation Finance
July 29, 2019 Page 2                                           Office of
Transportation and Leisure
FirstName LastName