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May 16, 2023
Peter Andreski
Global Corporate Controller, Chief Accounting Officer
Visa Inc.
P.O. Box 8999
San Francisco, CA 94128
Re:Visa Inc.
Form 10-K for Fiscal Year Ended September 30, 2022
File No. 001-33977
Dear Peter Andreski:
            We have limited our review of your filing to the financial statements and related
disclosures 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 business days by providing the requested
information or advise 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 comments, we may have additional comments.
Form 10-K for Fiscal Year Ended September 30, 2022
Overview, page 4
1.You disclose that 4.1 billion credentials were available.  Please tell us and revise to
disclose how you define this term.
2.To make it clear what type of revenues you earn from various customer categories,
consider providing illustrative examples of transactions and the money flows between you
and participating parties, including the types of revenues you earn from each party and the
basis on which the amount of your fee is determined.  For example, we note from your
disclosure that issuers charge acquirers an "interchange reimbursement fee” and acquirers
charge merchants a "merchant discount rate,” but it is not clear whether your fees relate to
or are derived from those fees of other transaction information, such as transaction value.
3.The pie chart on page 6 depicting the split of your 2022 revenues includes the term “value
added services” under both other revenues and data processing revenues.  Please revise to
be more descriptive of such services or explain why value added services revenues are

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Visa Inc.
May 16, 2023
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including in both categories.
Business
Competition, page 13
4.On page 62 you refer to yourself as a “payments network service provider.”  We note your
use of the terms “payment processors” and “processors,” for example on pages 14 and 22.
Payment processors and global or multi-regional networks are listed as electronic
payments competitors of yours.    Please tell us and revise to disclose how you define
processors and how you differentiate them from networks.  Please also define payment
facilitators.
5.On page 13, you disclose 244 billion “transactions” for calendar year 2021.  On page 37
you disclose 164.7 billion “processed transactions” for the fiscal year ended September
30, 2021.  Please tell us whether these two figures (for different periods) both measure the
same type of transactions and, if so, why the amounts varied significantly for the two
twelve-month periods.
6.In the table on page 13, please revise to disclose that the difference between “payments
volume” and “total volume” and, if such difference is cash volume, describe cash volume.
Risk Factors
Merchants' and processors' continued to push to lower acceptance costs..., page 23
7.Please revise to explain the term acceptance costs.
Release of Preferred Stock, page 33
8.Please revise to disclose the impact of the release of preferred stock on your financial
position, results of operations, and cash flows, if any.
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Overview
Litigation Provision, page 34
9.We note your disclosure that you recover the monetary liabilities related to U.S. covered
litigation through a downward adjustment to the rate at which class B common convert to
class A common.  Please tell us and revise to disclose to what extent this impacted
earnings per share for either class, if any.
Results of Operations
Operating Expenses, page 39
10.You disclose that general and administrative expenses include card benefits.  Please tell us
and revise to disclose the nature of card benefits.

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Visa Inc.
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Page 3
Consolidated Balance Sheets, page 52
11.We note your balance sheet includes client incentives in current assets, long-term assets,
current liabilities, and long-term liabilities (in other liabilities).  Please revise your
disclosure in “Client Incentives” on page 63 to clarify how upfront or in arrears client
incentive payments are recognized in your balance sheets.
Consolidated Financial Statements
Consolidated Statements of Cash Flows, page 58
12.Please tell us your basis for presenting client incentives in both “adjustments to reconcile
net income to net cash provided by operating activities” and “change in operating assets
and liabilities.”
Notes to Consolidated Financial Statements
Note 1 - Summary of Significant Accounting Policies
Revenue Recognition, page 62
13.Please tell us and revise to disclose the parties you consider to be your customers under
ASC 606.  Please also clarify what types of revenues you earn from each of these
customer categories.
14.You disclose that you recognize revenue as the “payments network services” are
performed and that fixed fees for “payments network services” are generally recognized
ratably over the related service period.  Please describe payments network services and
clarify how they relate to the listed revenue categories (service revenues, data processing
revenues, international transactions revenues and other revenues).
15.We note your disclosure that service revenues consist of revenues earned for services
provided in support of client usage of Visa payment services.  Please tell us and revise to
describe in more detail the nature of these services.
16.You state that service revenues are “primarily assessed” using a calculation of current
[quarter’s] pricing applied to the prior [quarter’s] payment volume.  Please describe for us
in more detail how service revenues are measured and recognized.  Please tell us what you
mean by “primarily” and whether your use of the term “assessed” means levied/charged,
determined/recognized (in an accounting sense), or something else.  In your response,
please tell us why these service revenues for a period are based on a prior period’s
payment volume and whether these assessed service revenues represent the contractual
amount due for the current period or an estimate of the amount due based on prior period
volume.  Finally, please tell us why other service revenues assessed to support ongoing
acceptance and volume growth initiatives are able to be measured in the same period in
which the related volume is transacted.  For these other service revenues, please tell us
when such amounts are assessed relative to the timing of the related transaction volume.
17.We note you provide gateway services through Cybersource.  Please tell us how these

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 Comapany NameVisa Inc.
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Peter Andreski
Visa Inc.
May 16, 2023
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revenues are categorized.
Note 3 - Revenues, page 66
18.We note your presentation of disaggregated revenue on a gross basis, excluding the
impact of client incentives. Please tell us whether you are able to allocate incentives to
individual categories and present such disaggregated information on a net basis.
19.We note that you disaggregate revenue by four “revenue categories” (service, data
processing, international transaction, and other) and by two geographical categories (U.S.
and international).  Please tell us how you considered the requirement of ASC 606-10-50-
5 and 55-89 through 55-91 in determining your disclosure of disaggregated revenue from
contracts with customers including the disclosure of additional disaggregated
information.  In this regard, we note from page 7 for example that you seek to grow
revenue in three primary areas – consumer payments, new flows, and value-added
services, and that, according to remarks on your fourth quarter 2022 earnings call, each of
these grew in excess of 20%, and that new flows and value-added services are
approximately one-third of revenues.  We also note prepared remarks discussing progress
on business initiatives and sales results in specific geographic regions.  Finally, we note
your business section discusses additional product offerings such as Visa Direct and that
you earn revenue from various types of entities (such as financial institutions and
merchants, etc., as described in your business disclosure).
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services