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                              March 22, 2022

       Edmund Reese
       Chief Financial Officer
       Broadridge Financial Solutions, Inc.
       5 Dakota Drive
       Lake Success, NY 11042

                                                        Re: Broadridge
Financial Solutions, Inc.
                                                            Form 10-K for the
Fiscal Year Ended June 30, 2021
                                                            Filed August 12,
2021
                                                            File No.: 001-33220

       Dear Mr. Reese:

              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 the Fiscal Year Ended June 30, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 36

   1.                                                   You disclose that
recurring fee revenues increased $296.7 million primarily by growth
                                                        from 5pts of new
business onboarding, 3pts of internal growth, and 2pts related to the
                                                        impact of acquisitions.
On page 38 you disclose that "Closed sales," which you define
                                                        as an estimate of the
expected annual recurring fee revenue for new client
                                                        contracts, were $238.9
million for the fiscal year ended June 30, 2020. Please tell us how
                                                        this estimate of annual
recurring fee revenue for new client contracts compared to the
                                                        actual increase in
recurring fee revenue in fiscal 2021 attributable to new client contracts
                                                        obtained in fiscal
2020. Please also clarify whether fiscal 2021 revenue from fiscal 2020
                                                        new client contracts is
considered "new business onboarding" or "internal growth" when
                                                        you discuss your fiscal
2021 results of operations.
 Edmund Reese
Broadridge Financial Solutions, Inc.
March 22, 2022
Page 2
         Please also revise your disclosure of the definition of "Closed sales"
on page 37 to
         describe how you estimate such amounts. While you define "Closed
sales" as an
         annualized amount, please consider whether titling the measure
"Annualized closed sales"
         may help to improve investors understanding and avoid confusion as to
the nature of the
         figure when disclosed in quarterly periods.
Analysis of Consolidated Statements of Earnings
Fiscal Year 2021 Compared to Fiscal Year 2020, page 39

2.       Please quantify the effects of changes in volume and price on
revenues. Refer to Item
         303(b)(2)(iii) of Regulation S-K.

3.       Please revise to quantify factors to which changes are attributed for
the increase in
         operating expenses. For example, you disclose that cost of revenues
increased due to
         higher distribution costs, higher operating costs from acquisitions
and related amortization
         expense, and other operating expenses including higher compensation.
Please also
         explain the underlying reasons for these factors. Finally, discuss
variances in these costs
         at the segment level. Refer to Item 303(b)(2)(i) of Regulation S-K.

Explanation and Reconciliation of the Company's Use of Non-GAAP Financial
Measures
Adjusted Operating Income, Adjusted Operating Income Margin, Adjusted Net
Earnings and
Adjusted Earnings Per Share, page 43

4.       We note you recognized a $45.3 million adjustment for Real Estate
Realignment and
         COVID-19 Related Expenses for the fiscal year ended June 30, 2021.
Please separately
         identify the amounts for each major component of this adjustment. To
provide clarity to
         investors, consider disclosing the major types of COVID-19 related
expenses and how
         these amounts were determined.
Consolidated Financial Statements for the Years Ended June 30, 2021 and 2020
Notes to Consolidated Financial Statements
Note 11. Other noncurrent assets, page 82

5.     Regarding deferred client conversion costs and start-up costs of
approximately $774
       million at June 30, 2021, please revise to describe the judgments used
in determining the
FirstName LastNameEdmund Reese
       amount of the costs incurred to obtain or fulfill a contract with a
customer, and the closing
Comapany    NameBroadridge
       balances               Financial
                of assets recognized    Solutions,
                                     from          Inc.
                                           the costs incurred to obtain or
fulfill a contract by main
March category
       22, 2022 of  asset.
                 Page  2 Refer to ASC 340-40-50-2 and 50-3.
FirstName LastName
 Edmund Reese
FirstName
BroadridgeLastNameEdmund      Reese
            Financial Solutions, Inc.
Comapany
March      NameBroadridge Financial Solutions, Inc.
       22, 2022
March3 22, 2022 Page 3
Page
FirstName LastName
       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 Robert Shapiro at (202) 551-3273 or Lyn Shenk at (202)
551-3380 with
any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services