VISA INC. (V) – Company response

To avoid giving undue prominence to your non-GAAP results, please revise to present and discuss your non-GAAP results after your discussion and analysis of GAAP results. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Corporation Finance Interpretations 102.10(a). We will revise our future filings to move the discussion of our non-GAAP results after the discussion of our Results of Operations. 1 Results of Operations Net revenue, page 45 2. Increases in each component of net revenue appear to be primarily volume related. This factor appears to recur annually as the primary factor impacting…