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Nuala M. King

SVP & Corporate Controller

1550 Peachtree St, N.W.

Atlanta, GA 30309

(404) 885-8440

Fax (404) 885-8087

nuala.king@equifax.com

February 20, 2014

VIA EDGAR

Mr. Larry Spirgel

Assistant Director

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

        Re: Equifax Inc.

        Form 10-K for the Fiscal Year Ended December 31, 2012

        Filed February 22, 2013

        Response dated February 12, 2014

        File No. 001-06605

Dear Mr. Spirgel:

This letter is being
submitted in response to the comments provided by the Staff of the Division of Corporation Finance (the “Staff”) of
the United States Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter dated
February 12, 2014 (the “Comment Letter”) with respect to the above-referenced Form 10-K for the Year Ended December
31, 2012 (the “Form 10-K”) and Form 10-Q for the Quarter Ended September 30, 2013 (the “Form 10-Q”), filed
by Equifax Inc. (“we,” “us,” “our,” “Equifax” or the “Company”) and
the Company’s responses to prior Staff comments referenced above.

For your convenience,
we have set forth each comment from the Comment Letter in bold typeface and have included the Company’s response below it.
The numbered paragraphs in this letter correspond to the numbered paragraphs of the Comment Letter.

Form 10-K for the Year Ended December 31, 2012

Goodwill and Other Intangible Assets, page 73

Indefinite-Lived Intangible Assets, page 74

 1. We have reviewed your response to prior comment 4. While neither SFAS 141/142 nor EITF 04-1 required a limit on the life
of a reacquired right, it remains unclear why you believed it was reasonable to assume renewal of a right, and thereby an indefinite
life, in instances where Equifax had the ability to terminate the contract at the end of its term, which, as you state in your
response dated September 26, 2013, was generally the case for these older agreements. Please explain to us why it is reasonable
of you to assume Equifax would renew the right after the contract period, once it was reacquired.

    1

Response

We believe that the intangible assets we recorded
as “reacquired rights” which resulted from the acquisition of our affiliates between 2001 through 2005 have an indefinite
life as the rights underlying the asset can be utilized indefinitely. Our consideration was based on the factors in FAS 142 used
to identify the life of an asset. We believe our accounting is further supported by the remarks of the SEC staff in 2005 based
on assigning a life to a reacquired right that is consistent with a product life cycle, which in our case is indefinite. We concluded
the life of the reacquired right was indefinite based on the indefinite nature of the product life cycle as it relates to Equifax
rather than assuming renewals of the right. Your question asks why it was, “reasonable to assume renewal of a right, and
thereby an indefinite life, in instances where Equifax had the ability to terminate the contract at the end of its term”.
However, as further explained below, absent the acquisition of an affiliate, we were economically compelled to continue to renew
the affiliate agreements. We never actually canceled an affiliate agreement.

Credit Reporting Industry

Equifax began as a credit reporting agency in 1899.
Credit was initially offered through retailers to consumers based on the documentation maintained by local credit reporting agencies
about consumers in the local area. Across the country, there were many local credit reporting agencies tracking information about
consumers’ use of credit, as well as payment and delinquency patterns of these consumers. As the demand for credit expanded
and as consumer lending evolved to be more regional and then national in scope, via increasingly regional and then national banks,
auto lenders and others, the need to have a single supplier of credit information about consumers across the nation caused the
industry to consolidate, resulting in three national credit reporting agencies or networks. This consolidation was accomplished
through acquisition or, in the case of local agencies who did not want to sell their business, the establishment of affiliate relationships.
The establishment of this network which served customers credit reporting needs nationally was critical to the survival of both
the affiliate and Equifax.

Rights Conveyed through the Affiliate Agreements

These affiliate relationships consisted of rights
which benefitted the affiliate and Equifax. From the affiliate perspective, they obtained the “right” to use the Equifax
products, processes, systems and name in the territory they occupy and to sell the Equifax-owned credit files to their customers
in their territory. Equifax obtained access to consumer credit files in the affiliates’ territories and to the affiliate
sales force in that territory.

Indefinite Life of Right if Contract Could be Terminated

In your question 1 of the February 12 letter, you
asked why we believe it was reasonable to assume an indefinite life of this right, when we and the affiliate had the contractual
ability to terminate the affiliate agreement at the end of each contract term. We and the affiliate were economically dependent
on each other and would not, and did not historically, cancel these agreements at the end of the stated contract term.

    2

 · We relied on the affiliate for credit files that we could sell in other territories, and for a salesforce in that territory
that would sell our credit files.

 · It would have been very costly, and take a number of years, for us to develop a credit file and salesforce from scratch, or
to endure a period of disrupted income from not having ready access to these.

 · The affiliate relied on us for:

 - Data management and data processing (there was no standard, commercially available software to do that easily or cost effectively
for a local affiliate)

 - Use of the Equifax trade name

 - Product and feature development

 - Access to a national credit file to sell to the customers in their territory

 - Sales of their credit information to national accounts outside their territory

 · It would be very costly if not impossible for an affiliate to develop national capability.

As a result of these economic factors, we never in
our 100 year history canceled an affiliate agreement. Affiliate agreements were either renewed, or we acquired the affiliate.

Indefinite Life After Acquisition of the Right

Once we reacquired the right to do business in that
territory, it was our intent and actual practice to use the right indefinitely. In our view, the rights granted to and reacquired
from affiliates are tightly linked to the credit information product offering of Equifax because we need to offer a unified national
database to be fully competitive. Acquisition of these rights was the most effective way to directly control our ability to ensure
a national product offering. Our product offering of credit information about US consumers to commercial entities to facilitate
their lending and credit management decisions has existed since the Company’s founding in 1899. Upon acquisition, the rights
which we reacquired became a part of our product offering and core credit reporting business which has existed for over 100 years.
The demand for credit reporting information and services has generally grown over time, although it can vary somewhat with economic
cycles, and that general trend is anticipated to continue. Also, because there was nothing that would limit our ability to use
the rights indefinitely, and the accounting guidance limiting the life to the remaining contractual term of the related contract
was issued subsequent to the 2001-2005 affiliate acquisitions, at the time of those acquisitions we concluded the reacquired rights
were indefinite.

Accounting Considerations and Conclusion

As noted in our January 27, 2014 letter, when the
2001-2005 acquisitions took place (resulting in $96 million of contractual/territorial rights – reacquired rights), the guidance
in paragraph 31 of FAS 141(R), which was subsequently codified in ASC 805-20-25-30 had not been issued[1].
That guidance (FAS 141(R) and ASC 805) limited the life, and resulting value, of a reacquired right to the “remaining contractual
term of the related contract regardless of whether market participants would consider potential contractual renewals in determining
its fair value”. Neither FAS 141/142 nor EITF 04-1 placed a limit on the life of a reacquired right as acknowledged by the
remarks of the SEC staff at the 2005 AICPA National Conference on Current SEC and PCAOB Developments.

[1] FAS 141(R) was applied prospectively to business
combinations for which the acquisition date is on or after the beginning of the first annual reporting period beginning on or after
December 15, 2008

    3

It is further noted that the 2005 SEC staff remarks
also indicated that for reacquired rights involving only a limited contractual period differing views exist, including limiting
the life of the reacquired right to the remainder of the original license period or amortizing the reacquired right over the total
product life cycle, which is the useful life of the license to the acquirer. As it relates to the rights that we reacquired, the
product lifecycle would be viewed as indefinite, supporting the use of an indefinite life. As noted above, the credit reporting
industry has existed for over 100 years and will continue to exist for the foreseeable future. While there are variations in specific
product offerings, or delivery methods, the basic product offering of consumer credit information has remained unchanged historically
and will continue to remain unchanged in the future. Prior to the advent of computers, providers of credit information would request
a paper document containing credit information on a prospective borrower. Today, while the information is maintained and delivered
via the internet or other electronic connection, the basic product delivered is still credit information on a consumer. As a result,
the rights we reacquired which were to be used in our core credit reporting business which to date has had a product life cycle
which has been indefinite, were concluded to have an indefinite life.

Materiality

In evaluating alternative views of this accounting
conclusion, we determined the impact to our financial statements if the staff were to object to our accounting and concluded that
the useful life must be limited based upon the terms of the agreement that previously provided the seller with the reacquired rights.
Because the amortization of the reacquired right would have been substantially completed by 2008, with an inconsequential amount
of amortization expense in 2009, there would be no impact in the historical income statements presented in our 2013 Form 10-K.
The impact of the alternative view to the financial statements would be to increase goodwill by $80.3
million as all other identifiable assets were properly valued, decrease deferred tax liabilities by $5.9 million and decrease retained
earnings by $10 million at December 31, 2010, as the reacquired right would have been fully amortized in 2009. We do not believe
the impact to goodwill, deferred taxes and retained earnings (representing 3.4%, 2.2% and 0.3%, respectively of the December 31,
2013 balances) would constitute a material change to our financial statements.

Internal Controls Over Financial Reporting

 2. Please elaborate upon your response to our previous comment 3 so that we fully understand the process of your identification
and remediation of the material weakness in internal controls over financial reporting. Include as part of your response a sufficiently
detailed timeline that lays out your course of action. Specifically identify in this timeline when the weakness was identified,
when management concluded the weakness was material, when a remediation plan was developed and implemented including its documentation,
communication, and any testing.

    4

Response

In November 2013, we determined there was an error
in the accounting for the purchased intangibles of the CSC acquisition which occurred in December 2012. We recorded the correcting
adjustment, documented the error including a SAB 99 analysis, and concluded that there was a deficiency in the internal control
over financial reporting related to business combinations. We also determined the deficiency needed to be remediated prior to year
end. At that time, based on our preliminary evaluation, we concluded that this deficiency did not represent a material weakness.
During the fourth quarter of 2013, Equifax management defined the changes necessary to correct the deficiency in internal control
and performed the revised control activities in connection with two acquisitions which were completed in the fourth quarter.

The detailed timeline of the events related to the
conclusion that the deficiency was a material weakness and the December 2013 remediation of the material weakness in the Company’s
internal control over financial reporting is set forth below, including timing of two fourth quarter acquisitions to which the
revised control activities over business combinations were applied.

    Date

    Event

    October 18, 2013

    Equifax acquires Informconf for approximately $48 million.

    November 1, 2013

    Equifax determines that there is an error in the accounting for the CSC business combination relating to valuation and recording of reacquired rights.  Management prepares a memo documenting the accounting issue resulting in the error in the accounting for the CSC acquisition, documenting our SAB 99 analysis and the conclusion that there was a deficiency in the internal controls over financial reporting related to the accounting for business combinations.  The initial conclusion that the deficiency did not result in a material weakness is based on the materiality of the adjustment to the current period financial statements as well as qualitative factors included in management’s SAB 99 analysis.

    November 4, 2013

    Prior to the filing of the third quarter 2013 Form 10-Q, Equifax CFO sends an email to the members of the Audit Committee of the Equifax Board of Directors informing them of the need to correct the error.

    November 5, 2013

    Chairman of the Audit Committee responds to the Equifax CFO noting the Company should evaluate the changes needed to the Equifax internal controls to address the deficiency.

    5

    November 6, 2013

    Equifax filed its Quarterly Report on Form 10-Q for the third quarter ended September 30, 2013.  Because management had initially concluded that the deficiency in internal controls was not a material weakness, Item 4 Controls and Procedures disclosure indicated that controls were effective for the period ended September 30, 2013.  Because no remediation efforts had been implemented for the period ended September 30, 2013, no disclosure regarding changes to internal controls was made.

    November 7, 2013

    Equifax CFO and VP-External Reporting discuss potential control changes necessary to remediate deficiency.  Discussion centers on the need to perform a more robust review of accounting literature when material or unusual intangibles are to be recorded.

    November 8, 2013

    VP-External Reporting undertakes the task of identifying the appropriate changes to existing controls and creation of new controls.

    November 27, 2013

    In connection with the initial valuation of the intangible assets acquired as part of the business combination with Informconf, Equifax executes its new control activity by evaluating whether there are any unusual intangible assets to be identified and concludes there are none.

    December 1-16, 2013

    Equifax