Room 4561
								January 13, 2006

Mr. Jeffery W. Yabuki
President & Chief Executive Officer
Fiserv, Inc.
255 Fiserv Drive
Brookfield, WI 53045

Re:	Fiserv Inc.
Form 10-K for Fiscal Year Ended December 31, 2004
Form 8-K filed on October 21, 2005
		File No. 001-14918

Dear Mr. Yabuki:

      We have reviewed the above referenced filings and your
letter
dated January 6, 2006 and have the following comments.  Please
note
that we have limited our review to the matters addressed in the
comments below.  We may ask you to provide us with supplemental
information so we may better understand your disclosure.  Please
be
as detailed as necessary in your explanation.  After reviewing
this
information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the year ended December 31, 2004

Consolidated Statements of Income, page 2

1. We have read your response to prior comment number two
regarding
your pharmacy network contracts.  Please clarify for us whether
revenues recognized under these arrangements are considered
product
revenues.  In addition, identify any other product revenues and
explain how you comply with Rule 5-03(1) and (2) of Regulation S-X
that requires separate reporting of revenues and costs related to
products and services.

2. We note that you consider all expenses other than interest and
income taxes to be costs of revenue.  Please explain to us how you
determined that these expenses should all be classified as costs
of
revenue under Rule 5-03(2). In addition, explain how you
determined
that none of these expenses should be classified as the line items
referred to in Rule 5-03(3) through (6), particularly selling,
general and administrative expenses.

Form 8-K Filed October 21, 2005

3. We have read your response to prior comment number 3 and it is
unclear to us how your proposed changes comply with Item
10(e)(1)(i)(A) of Regulation S-K.  Please explain to us how
modifying
the table on page 5 of your earnings release serves to present,
with
equal or greater prominence, the most directly comparable measure
calculated and presented in accordance with GAAP.  It does not
appear
to us that this table, provided on page 5, is presented with equal
or
greater prominence than the non-GAAP measure disclosed within the
second paragraph of your earnings release.

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.

	You may contact Chauncey Martin, Staff Accountant, at (202)
551-
3441 or Mark Kronforst, Senior Staff Accountant, at (202) 551-
3451
if you have questions regarding the above comments.  If you need
further assistance, you may contact me at (202) 551- 3489.

      Sincerely,



      Brad Skinner
      Accounting Branch Chief
Mr. Jeffery W. Yabuki
Fiserv, Inc.
January 13, 2006
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