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                                June 4, 2020

       Jeffrey Campbell
       Chief Financial Officer
       American Express Company
       200 Vesey Street
       New York, NY 10285

                                                        Re: American Express
Company
                                                            Form 8-K Filed
April 24, 2020
                                                            File No. 001-07657

       Dear Mr. Campbell:

              We have reviewed your filing 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 8-K Filed April 24, 2020

       Exhibit 99.2
       Appendix III, page 13

   1.                                                   We note your disclosure
of adjusted diluted earnings per common share excluding credit
                                                        reserve builds, which
excludes the portion of the provision for credit losses attributable to
                                                        reserve builds. It
appears this performance measure, which excludes a portion of the
                                                        provision for credit
losses, substitutes individually tailored recognition and measurement
                                                        methods for those of
GAAP and violates Rule 100(b) of Regulation G, as discussed in
                                                        Question 100.04 of the
Non-GAAP Financial Measures Compliance and Disclosures
                                                        Interpretations
available on our website at:

http://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm. Please refrain
from
                                                        disclosing this
performance measure, or any other performance measures that excludes a
                                                        portion of the
provision for credit losses (e.g., the portion of the provision for credit
losses
                                                        that exceeds net
write-offs) in future filings.
 Jeffrey Campbell
American Express Company
June 4, 2020
Page 2
2.       To the extent that you continue to discuss or disclose an amount
related to "credit reserve
         builds" in future filings, please define how this measure is
calculated.
       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 Michael Henderson at 202-551-3364 or Marc Thomas at
202-551-3452
with any questions.



FirstName LastNameJeffrey Campbell                             Sincerely,
Comapany NameAmerican Express Company
                                                               Division of
Corporation Finance
June 4, 2020 Page 2                                            Office of
Finance
FirstName LastName