Kathleen Collins

Rebekah Lindsey

Fiserv, Inc.

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

Filed February 21, 2019

Form 8-K Furnished February 7, 2019

File No. 000-14948

We note that your adjusted net income, adjusted operating income and related margins, and adjusted EPS measures include an adjustment for “amortization of acquisition-related intangibles.” Please tell us how you determined that adjusting for amortization related only to acquisition-related intangibles, rather than all amortization expense, complies with Question 100.04 of the Non-GAAP C&DIs. Also, tell us why you believe this information is useful to investors.

Response:

In accordance with our discussion with the Staff, we will update our future earnings releases as follows:

Within the section titled “Use of Non-GAAP Financial Measures”, we will expand our disclosure to include the following additional information:

Within the section titled “Reconciliation of GAAP to Adjusted Net Income and Adjusted Earnings Per Share”, we will expand our disclosure to include the following additional information in relation to the line item shown within the excerpt below (added disclosure is shown underlined):

GAAP income from continuing operations

Adjustments:

Amortization of acquisition-related intangible assets¹

Represents amortization of intangible assets acquired through various acquisitions, including customer relationships, software/technology, and tradenames. This adjustment does not exclude the amortization of other intangible assets such as contract assets (sales commissions and deferred conversion costs), capitalized and purchased software, and financing costs and debt discounts. See additional information on page [•] for an analysis of the Company’s amortization expense.

Within the section titled “Full Year Forward-Looking Non-GAAP Financial Measures”, we will expand our disclosure to include the language presented in footnote 1 above.

Within the section titled “Selected Non-GAAP Financial Measures”, we will expand our disclosure to include the following additional information:

Total Amortization¹

Acquisition-related intangible assets

Capitalized software

Purchased software

Financing costs, debt discounts and other

Sales commissions

Deferred conversion costs

Total amortization

The Company adjusts its non-GAAP results to exclude amortization of all acquisition-related intangible assets as such amounts are inconsistent in amount and frequency and are significantly impacted by the timing and/or size of acquisitions (see corresponding adjustment on page [•]). Management believes that the adjustment of acquisition-related intangible asset amortization supplements the GAAP information with a measure that can be used to assess the comparability of operating performance. Although the Company excludes amortization from acquisition-related intangible assets from its non-GAAP expenses, management believes that it is important for investors to understand that such intangible assets were recorded as part of purchase accounting and contribute to revenue generation. Amortization of intangible assets that relate to past acquisitions will recur in future periods until such intangible assets have been fully amortized. Any future acquisitions may result in the amortization of additional intangible assets.

Kenneth F. Best, Chief Accounting Officer, Fiserv, Inc.