SecProbe.io

Mail Stop 3561

November  2, 2016

Jeffrey S. Sloan
Chief Executive  Officer
Global Payments  Inc.
10 Glenlake Parkway, North Tower
Atlanta, Georgia  30328 -3473

Re: Global Payments  Inc.
 Form 10-K for Fiscal Year Ended May 31, 2016
Filed July 28 , 2016
Definitive Proxy Statement on Schedule 14A
Filed August  18, 2016
Form 10 -Q for Fiscal Quarter Ended August 31, 2016
Filed October 5, 2016
File No. 1-16111

Dear Mr. Sloan :

We have reviewed  your October 12, 2016 response to our comment letter and have the
following comments.  In some of our comments , we may ask you to provide us with information
so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days  by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  commen ts, we may have additional comments.
Unless we note otherwise, our references to prior comments are to comments in our September
28, 2016 letter .

Definitive Proxy Statement on Schedule 14A

Compensation Discussion and Analysis

General

1. We note your responses to comments 4, 5 and 6, and that the increases in salaries, setting
of target bonus opportunities and determination of LTI grants were based in part on
“assessments” of the named executive officers.  Please revise your future disclos ures to

Jeffrey S. Sloan
Global Payments Inc.
November 2, 2016
Page 2

 enhance your discussion of the assessments made with respect to each named executive
officer and the manner in which such assessments corresponded to the compensation
decisions regarding each named executive officer.  Please show us what your revis ed
disclosure will look like.

For 10 -Q for Fiscal Quarter  Ended August 31, 2016

Notes to Unaudited Consolidated Financial Statements

Note 5. Other Assets, page 13

2. With reference to the specific accounting guidance on which you relied, please tell us th e
basis in GAAP for your accounting for Visa’s acquisition of your membership interests in
Visa Europe.  In doing so, please tell us:

 how the original membership interest in Visa Europe was accounted for and whether
the investment had a net book value of zero, and if so, why ;
 all the factors considered in determining the Series B and C preferred shares received
in the exchange have a value of zero ; and
 whether  you have determined it’s probable that a loss has been incurred with respect
to potential litigation involving Visa Europe and the amount accrued for such loss.

You may contact Ta Tanisha Meadows, Staff Accountant , at (202) 551 -3322 or Robyn
Manuel , Staff Accountant,  at (202) 551 -3823 if you have questions regarding comments on the
financial statements and related matters.  Please contact Danilo Castelli , Staff Attorney , at (202)
551-6521  or Lilyanna Peyser, Special Counsel , at (202) 551 -3222 wi th any ot her questions.

Sincerely,

/s/ William H. Thompson

William H. Thompson
Accounting Branch Chief
Office of Consumer Products

Cc: David M. Sheffield , Senior Vice President and Chief Accounting Officer