SecProbe.io

July 9, 2015

Via Email
Rick L. Weller
Chief Financial Officer
Euronet Worldwide, Inc.
3500 College Boulevard
Leawood, Kansas  66211

Re: Euronet Worldwide , Inc.
 Form 10 -K for Fis cal Year Ended December 31 , 2014
Filed February 27 , 2015
Form 10 -Q for Fiscal Quarter Ended March 31, 2015
Filed April 30, 2015
File No. 00 1-31648

Dear Mr. Weller :

We have reviewed your filing an d have the following comment s.  In our comment s, we
may ask  you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   Where we have specifically requested a draft of your proposed disclosures in future
filings, please ensure that it clearly identifies new, revised or deleted disclosures, as appropriate.
If you do not believe our comment s apply  to your facts and circumstances or do not believe an
amendment is appropriate, pleas e tell us why in your response.

After reviewing any amendment to your filing and the informati on you provide in
response to th ese comment s, we may have additional comment s.

Form 10 -K for Fiscal Year Ended December 31 , 2014

Item 1. Business

2014 Developments, page 5

1. We note on page 5 that you have entered into an agreement with Walmart to offer money
transfer services called Walmart -2-Walmart.   In future filings, please  revise your disclosure
to summarize the material terms of any such collaboration agreement, including whether the
agreement is exclusive, material payment obligations, the duration, and material early
termination provisions.   Please also file the agreemen t as an exhibit.

Rick L. Weller
Euronet Worldwide , Inc.
July 9, 2015
Page 2

Item 8.  Financial Statements and Supplemental Data

Notes to Consolidated Financial Statements

Note 14.  Valuation and Qualifying Accounts, page 96

2. Please tell us, and revise future filings, to include an analysis of the age of the recorded trade
receivables at the end of the reporting period that are past due as required by ASC 310 -10-
50-7A.  See the guidance in ASC 310 -10-55-9.

Form 10 -Q for the Fiscal Quarter Ended March 31, 2015

Notes to the Unaudited Consolidated Financial Sta tements

Note 10.  Income Taxes, page 15

3. Your effective income tax expense has fluctuated from 26.4% at March 31, 2014 to an
effective tax rate of 49.5% at March 31, 2015.  Please provide in future interim filings the
income tax expense disclosures requir ed by Item 4.08(h) of Regulation S -X.  Show us what
your disclosure will look like in your response.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the informatio n the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosu res they have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosur e in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; 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.

Rick L. Weller
Euronet Worldwide , Inc.
July 9, 2015
Page 3

 You may contact David Irving at (202) 551 -3321 or me at  (202) 55 1-3452 if you have
questions regarding comments on the financial statements and related matters .  Please contact
Matthew Jones at (202) 551 -3786 or Michael Clampitt at (202) 551 -3434 with any other
questions.

Sincerely,

 /s/ Marc Thomas

Marc Thomas
Reviewing Accountant