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CORRESP
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March 18, 2010

Mr. Larry
Spirgel

Assistant
Director

Division
of Corporation Finance

United
States Securities and Exchange Commission

100
F Street, N.E.

Mail
Stop 3720

Washington,
D.C.  20549

  RE:

  Equifax
  Inc.

  Form 10-K
  for the Year Ended December 31, 2009

  Filed February 23,
  2010

  File No. 001-06605

Dear
Mr. Spirgel:

We
have reviewed the comment letter dated March 4, 2010 from the staff (“Staff”)
of the Securities and Exchange Commission related to the above-mentioned filing
by Equifax Inc. (the “Company” or “Equifax”).
With respect to each of the items in that letter, we are providing the
following responses.  To assist your
review, we have included the text of the Staff’s comments below in italicized
type.

Form 10-K for the Year Ended December 31,
2009

Note 9.
Obligations and Funded Status, page 87

1.              Please
tell us why it is appropriate to consolidate the information related to the
CRIP (a foreign plan) with the USRIP.
Refer to your basis in the accounting literature.

Company Response:  FASB
Accounting Standards Codification, or ASC, paragraph 715-20-50-4 states, “A
U.S. reporting entity may combine disclosures about pension plans or other
postretirement benefit plans outside the U.S. with those for U.S. plans unless
the benefit obligations of the plans outside the U.S. are significant relative
to the total benefit obligation and those plans use significantly different
assumptions.”  The benefit obligation for
the Canadian Retirement Income Plan, or CRIP, at December 31, 2009 was
$40.6 million, or 6.5%, of the $624.2 million total benefit obligation for our
pension plans.  Additionally, the primary
assumptions used to value the CRIP’s benefit obligation and net periodic
benefit cost (namely, the discount rate and expected return on plan assets
assumptions) are not significantly different from our other plans.  The discount rate used to determine the CRIP
benefit obligation at December 31, 2009 was 6.50% compared to a
weighted-average for our U.S. plans of 5.72% (which includes a range of 5.26% to
6.50%).  The expected return on plan
assets assumption for the CRIP for the year ended December 31, 2009 was
7.50% compared to a weighted-average for our U.S. plans of 8.07% (which
includes a range of 7.50% to 8.25%).  The
methodology used to determine the discount rate and expected return on plan
assets assumptions is the same for all of our pension plans.  Since the CRIP benefit obligation is not
significant relative to our total pension benefit obligation and the
assumptions are similar among all of our pension plans, we believe it was
appropriate to consolidate the disclosure of our CRIP with our U.S. pension
plans in our 2009 Form 10-K.

2.              We note
that the benefit obligation significantly exceeds the plan assets.  We also note that you disclose on page 44
that “the USRIP met or exceeded ERISA’s minimum funding requirements.”

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Please tell us in more detail why
you have no funding requirement for the USRIP under the Pension Protection Act.

Company Response:  Although
we reported a net benefit liability of $118.8 million at December 31,
2009, $52.0 million of the liability was related to our non-qualified
supplemental retirement plans which are not subject to the funding requirements
of the Pension Protection Act.  The
Company has historically contributed to its qualified pension plans amounts
exceeding any mandated minimum contribution amounts.  We have accumulated a credit balance which
can be used to offset future required contributions.  Funding requirements for 2009 were determined
prior to the merger of our U.S. Retirement Income Plan, or USRIP, and Equifax
Inc. Pension Plan, or EIPP.  For 2009,
the USRIP had a calculated minimum required contribution of $570,000; however,
the plan had a credit balance of $61.7 million that could be used to offset
this amount, thus no contribution was required.
Similarly, the EIPP had a calculated minimum required contribution of $4
million for 2009 and a credit balance of $14.3 million, thus no contribution
was required.  In addition, we made
discretionary contributions to the EIPP of $15 million in January 2009 and
$12.5 million in December 2009.  We
also made a discretionary contribution of $20 million to the combined USRIP
plan in January 2010.  As a result
of the funding contributions made and accumulated credit balances, we currently
have no funding requirement for the USRIP.

Note
10.  Restructuring Charges, page 94

3.              We note
that you had total headcount reductions of 700 positions in 2009 and 300
positions in 2008.  Please tell us why
these reductions had no impact on your benefit plans.

Company Response:  These reductions had minimal impact on our
benefit plans.  Of the 1,000 total
positions eliminated in 2009 and 2008, approximately 500 were not pension-eligible
(approximately 430 of the positions were located in international geographies,
other than Canada, which are not covered by our pension plans and the remaining
70 positions were from recently acquired companies whose employees were not
participants in our plans).  The
remaining positions were pension-eligible (approximately 400 positions were in
the U.S. and 100 were in Canada).

With respect to the pension-eligible positions, we
considered the curtailment guidance in FASB ASC paragraph 715-30-15-6 which
defines a curtailment as “an event that eliminates for a significant number of
employees the accrual of defined benefits for some or all of their future
services”.  Per FASB ASC 715-30-15-6,
curtailments include “termination of employees’ services earlier than expected.”  Effective January 1, 2009, we amended
our U.S. Equifax Inc. Pension Plan to freeze the plan for employees who did not
meet certain grandfathering criteria related to retirement eligible
employees.  Under these amendments, the
plan was closed to new participants and the service credit for
non-grandfathered participants was frozen, but these participants continued to
receive credit for salary increases and vesting of service.  As the service credit for vested employees
(those with more than five years of service) was frozen under the plan
amendment, there would be no change to our accrual for these individuals
regardless of termination.  Therefore,
only the termination of unvested employees (those with less than five years of
service) could potentially impact our pension accrual.  Of the 400 pension-eligible U.S. positions
terminated, only 150 employees had less than five years of service.  This represents 1.3% of the approximately
11,900 total U.S. plan participants and is not considered significant to our
U.S. plan.

For Canada, participants are immediately vested in
their benefit.  Termination of retirement
eligible employees would have a minimal impact on our pension accrual as these
employees are not expected to perform a significant amount of future
services.  Twenty of the 100 Canadian
terminations

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were
retirement eligible.  Therefore, only the
termination of non-retirement eligible participants could potentially impact
our pension accrual.  The 80
non-retirement eligible terminations represented 6.7% of the approximately
1,200 total Canadian plan participants which is not considered significant to
our Canadian plan.

As the U.S. and Canadian pension-eligible
terminations did not impact a “significant number of employees” per the
guidance above, these events are not considered curtailments and had minimal
impact on our plans.

*    *    *

As
requested by the Commission, the Company acknowledges that:

·                  The Company is responsible for the adequacy
and accuracy of the disclosure in its filings;

·                  Staff comments or changes to disclosure in
response to Staff comments do not foreclose the Commission from taking any
action with respect to the filings; and

·                  The Company may not assert Staff comments as
a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

Please
direct any questions or comments to me at (404) 885-8440.  My fax number is (404) 885-8087.

Sincerely,

  /s/
  Nuala M. King

  Nuala
  M. King

  Senior
  Vice President and Corporate Controller

  cc:

  Richard
  F. Smith, Chairman and Chief Executive Officer

  Lee
  Adrean, Corporate Vice President and Chief Financial Officer

  Kent
  E. Mast, Corporate Vice President and Chief Legal Officer

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