TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo September 5, 2023 Devin McGranahan President and Chief Executive Officer The Western Union Company 7001 East Belleview Avenue Denver, CO 80237 Re: The Western Union Company Form 10-K for Fiscal Year Ended December 31, 2022 Filed February 23, 2023 Item 2.02 Form 8-K Dated July 26, 2023 File No. 001-32903 Dear Devin McGranahan: We have reviewed your filings 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 December 31, 2022 Consolidated Financial Statements Consolidated Statements of Cash Flows, page 72 1. Please provide us with a quantified breakout for each period presented of the amounts included in the other non-cash items, net line item of your cash flows from operating activities. Please also present material amounts included in this line item as separate line items in your cash flows from operating activities. Refer to ASC 230-10-45-28. Item 2.02 Form 8-K Dated July 26, 2023 Exhibit 99.1 2. You present Adjusted EBITDA as a non-GAAP performance measure. Please revise your reconciliation of this measure to begin with net income, which is the most directly Devin McGranahan The Western Union Company September 5, 2023 Page 2 comparable GAAP measure. Refer to Question 103.02 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Also, present/discuss net income margin, when Adjusted EBITDA margin is presented/discussed. 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 Keira Nakada at 202-551-3659 or Rufus Decker at 202-551-3769 with any questions. FirstName LastNameDevin McGranahan Sincerely, Comapany NameThe Western Union Company Division of Corporation Finance September 5, 2023 Page 2 Office of Trade & Services FirstName LastName