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                              October 28, 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 October 6, 2021 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       September 23, 2021 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2020

       Item 1A. Risk Factors, page 25

   1.                                                   We reissue in part
comment 1. We note your response to this comment. Tell us about
                                                        other potential
litigation risks to which you could be exposed other than    operational loss
                                                        or disruption due to
the increasing frequency of natural disasters and other extreme
                                                        weather events.
       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of
       Operations, page 50

   2.                                                   We reissue in part
comment 2. Please tell us whether you have identified any
                                                        pending climate
change-related legislation, regulations, and international accords that
                                                        could have a material
effect on your business, financial condition, and results of
 John T. Greene
Discover Financial Services
October 28, 2021
Page 2
         operations. Please also tell us your process for identifying such
developments and how
         you assessed potential materiality. In addition, explain how you
considered providing
         disclosure addressing the difficulties involved in assessing the
timing and effect of
         pending climate-related laws, regulations or guidance.
3.       We reissue in part comment 3. Tell us what consideration you gave to
providing the type
         of climate-related disclosure in your SEC filings as provided in your
Corporate
         Responsibility Report.
4.       We reissue in part comment 4. Please tell us how you considered
providing a discussion
         of the significant physical effects of climate change on your
operations and results, such
         as effects on the severity of weather. As part of your response,
address the potential for
         indirect weather-related impacts that have affected or may affect your
third-party vendors
         or third-party service providers.
5.       We reissue in part comment 5. Your response indicates in part, "We
recognize that a
         material increase in the incidence of severe weather events or trends
could potentially
         have a material adverse impact on our business operations, customers
and/or heighten
         regulatory expectations around managing such risks." Please tell us
about the transition
         risks identified as part of your risk management activities and
explain why you
         concluded that disclosure was not necessary. Consistent with our prior
comment, include
         information about specific transition risks beyond those related to an
increase in the
         incidence of severe weather events, such as policy and regulatory
changes, market trends,
         credit risks, and technological changes.
6.       Your response to comment 6 states that you have not incurred material
compliance costs
         related to climate change. Describe the nature of the compliance costs
you have incurred
         and provide us with quantitative information supporting your statement
that the related
         amounts were not material.
       You may contact Todd Schiffman at 202-551-3491 or Erin Purnell at
202-551-3454 if
you have questions regarding these comments.



FirstName LastNameJohn T. Greene                              Sincerely,
Comapany NameDiscover Financial Services
                                                              Division of
Corporation Finance
October 28, 2021 Page 2                                       Office of Finance
FirstName LastName