United States securities and exchange commission logo
September 23, 2021
John T. Greene
Executive Vice President, Chief Financial Officer
Discover Financial Services
2500 Lake Cook Road
Riverwoods, Illinois 60015
Re: Discover Financial
Services
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed February 17,
2021
File No. 001-33378
Dear Mr. Greene:
We have reviewed your filing 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 the Fiscal Year Ended December 31, 2020
Item 1A. Risk Factors, page 25
1. Disclose any material
litigation risks related to climate change and the potential impact to
the company.
Item 7. Management s Discussion and Analysis of Financial Condition
and Results of
Operations, page 50
2. There have been
significant developments in federal and state legislation and regulation
and international
accords regarding climate change. We note that you have not discussed
the impact of pending
or existing climate change-related legislation, regulations, and
international accords
in your SEC filing. Please revise your disclosure to identify material
existing climate
change-related legislation, regulations, and international accords and any
material effect on your
business, financial condition, and results of operations.
John T. Greene
Discover Financial Services
September 23, 2021
Page 2
3. In your 2020 Corporate Responsibility Report, you refer to
climate-related projects that
you have undertaken. If material, please describe these projects and
quantify related
capital expenditures in your filing. Please also tell us what
consideration you gave to
providing the same type of climate-related disclosure in your SEC
filings as you provided
in your Corporate Responsibility Report.
4. If material, discuss the significant physical effects of climate
change on your operations
and results. This disclosure may include the following:
severity of weather, such as floods, hurricanes, sea levels,
extreme fires, and water
availability and quality;
quantification of material weather-related damages to your
property or operations;
potential for indirect weather-related impacts that have affected
or may affect your
major customers or suppliers; and
any weather-related impacts on the cost or availability of
insurance.
5. Disclose the material effects of transition risks related to climate
change that may affect
your business, financial condition, and results of operations, such as
policy and regulatory
changes that could impose operational and compliance burdens, market
trends that may
alter business opportunities, credit risks, or technological changes.
6. Quantify any material increased compliance costs related to climate
change.
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 Todd Schiffman at 202-551-3491 or Erin Purnell at
202-551-3454 if
you have questions relating to these comments.
FirstName LastNameJohn T. Greene Sincerely,
Comapany NameDiscover Financial Services
Division of
Corporation Finance
September 23, 2021 Page 2 Office of
Finance
FirstName LastName