May 31, 2007
| Re: | Discover Financial Services |
| Registration Statement on Form 10 File No. 001-33378 |
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Ladies and Gentlemen:
Discover Financial Services, a Delaware corporation (the “Company”), hereby requests acceleration of the effectiveness of the above-referenced Registration Statement under Section 12(d) of the Securities Exchange Act of 1934, as amended, to 12:00 p.m., Washington, D.C. time, on June 1, 2007, or as soon thereafter as practicable.
In connection with this request, the Company acknowledges that:
| • | should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement; |
| • | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
| • | the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Very truly yours, | ||||
DISCOVER FINANCIAL SERVICES | ||||
By: | /s/ Kelly McNamara Corley | |||
| Name: | Kelly McNamara Corley | |||
| Title: | Senior Vice President, General Counsel and Secretary | |||
