Room 4561

								February 8, 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
Filed February 25, 2005
		File No. 000-14948

Dear Mr. Yabuki:

      We have reviewed the above referenced filings and your
dated February 6, 2006 and have the following comments.  Please
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
as detailed as necessary in your explanation.  After reviewing
information, we may raise additional comments.

	Please understand that the purpose of our review process is
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
our review.  Feel free to call us at the telephone numbers listed
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 responses to prior comment numbers 1 and 3.
do not believe that revising your income statement classifications
prospectively beginning with your first quarter of fiscal 2006 is
appropriate.  Rather, we believe that the income statements for
year presented within your 2005 Form 10-K should comply with Rule
03 of Regulation S-X.  In addition, you should also include your
proposed supplemental cash flow disclosures related to
operations on the face of your statements of cash flows for each

      As appropriate, please amend your filing and respond to
comments within 10 business days or tell us when you will provide
with a response.  Please submit all correspondence and
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
requested information.  Detailed cover letters greatly facilitate
review.  Please understand that we may have additional comments
reviewing any amendment and your responses to our comments.

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


      Brad Skinner
      Accounting Branch Chief

Mr. Jeffery W. Yabuki
Fiserv, Inc.
February 8, 2006
Page 2