[LETTERHEAD OF AMERICAN EXPRESS COMPANY]









                                                              March 23, 2007

BY EDGAR CORRESPONDENCE

Kevin W. Vaughn
Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 4561
100 F Street, N.E.
Washington, DC 20549

         Re:      American Express Company
                  Form 10-K for Fiscal Year Ended December 31, 2005
                  Filed March 6, 2006
                  File No. 1-07657
                  -------------------------------------------------

Dear Mr. Vaughn:

         We refer to (i) comment 2 of the comment letter, dated January 3,
2007 (the "January 3rd Comment Letter"), from the staff (the "Staff") of the
Division of Corporation Finance of the Securities and Exchange Commission
concerning the Form 10-K for the fiscal year ended December 31, 2005 of
American Express Company (the "Company") filed with the Commission on March 6,
2006 (the "Form 10-K") and (ii) the Company's response to comment 2 as
contained in the letter, dated March 5, 2007 (the "March 5th Response
Letter"), from the undersigned to you.

         Based on a discussion on March 22, 2007 between members of the Staff
and finance and accounting personnel from the Company and personnel from
PricewaterhouseCoopers LLP, the Company's independent public accountants, the
Company is submitting this letter to supplement its response to comment 2
contained in the March 5th Response Letter.

         We have set forth below the text of the comment 2 contained in the
January 3rd Comment Letter, followed by the Company's supplemental response.

         Please be advised that the Company is requesting confidential
treatment of portions of this letter in accordance with Rule 80(b) of the
Securities and Exchange Commission. In addition, accompanying this letter is
the Company's request under Commission Rule 83 for confidential treatment
under the Freedom of Information Act ("FOIA"), a copy of which letter (without
enclosures) is also being sent to the Commission's FOIA Officer.

                                   * * * * *

                                     -1-

Note 19 OPERATING SEGMENTS AND GEOGRAPHIC OPERATIONS, PAGE 95

2.   We note your response to comment 8 in your November 17, 2006 letter
     and have the following comments:

     a. We do not believe that the Global Establishment Services and Global
        Network Services operating segments meet the aggregation criteria in
        paragraph 17 of SFAS 131. It does not appear that the segments
        currently have similar economic characteristics or that there is
        supportable objective evidence that the economic characteristics will
        converge in the long run. Additionally, it does not appear that the
        segments have similar customers. Therefore, please revise your
        financial statements to present these operating segments separately.

     b. We do not believe that the Consumer and Small Business Card Services
        and Travelers Check and Prepaid Card Product Services operating
        segments meet the aggregation criteria in paragraph 17 of SFAS 131.
        It does not appear that the segments have similar products or
        distribution methods. Additionally, we believe that in order to
        conclude that the above segments have similar economic
        characteristics, you must consider more than one economic metric.
        Please revise your financial statements to present the Travelers
        Check and Prepaid Card Product Services operating segment separately
        or to present the operating segment in the Corporate and Other
        section of your segment disclosure.

     c. We do not believe the International Payments Services, International
        Banking Services, and Global Commercial Services operating
        segments meet the aggregation criteria in paragraph 17 of SFAS
        131. It does not appear that the segments have similar economic
        characteristics since net income margin is not expected to
        converge in the long run. In fact it appears that net income
        margins for the segments are expected to diverge. Additionally,
        it does not appear that the segments have similar products and
        services, types of customers or distributions methods. We also
        believe International Banking Services is a reportable operating
        segment since it meets the criteria in paragraph 18(c). Please
        revise your financial statements to separately present the
        International Payment Services, International Banking Services,
        and Global Commercial Services operating segments.

         The Company is seeking confidential treatment of its response to
comments 2.a., b. and c. Please refer to Annex A to the confidential treatment
request that accompanies this letter for the response to this comment.

                                   * * * * *

                                     -2-

         The Company acknowledges that it is responsible for the adequacy and
accuracy of the disclosure in the Form 10-K and that Staff comments or changes
to disclosure in response to Staff comments on the Form 10-K do not foreclose
the Commission from taking any action with respect to the filing. The Company
also acknowledges that it may not assert Staff comments as defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

                                   * * * * *

         If you have any questions or comments regarding the foregoing, do not
hesitate to contact the undersigned at 212-640-5478.

                                              Very truly yours,

                                              /s/ Daniel T. Henry
                                              Daniel T. Henry
                                              Executive Vice President and
                                                acting Chief Financial Officer

cc:  Mr. Michael Volley
     Ms. Joan C. Amble




                                     -3-