UPLOAD: SEC-generated letter

April 5, 2006

Zip+4 Code: 20549-0305

Via Fax & U.S. Mail
Douglas J. Treff, Senior Vice President and Chief Financial
Officer
Deluxe Corporation
3680 Victoria St. N.
Shoreview, Minnesota 55126

Re: Deluxe Corporation
Form 10-K for the Year Ended December 31, 2005
File 001-07945

Dear Mr. Treff:

Based upon an examination restricted solely to
considerations
of the Financial Statements, Management`s Discussion and Analysis,
and Selected Financial Data, the staff has the following comments
on
the above-referenced documents. Where indicated, we think you
should
revise your future filings in response to these comments. If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary. Please be as detailed
as
necessary in your explanation. In some of our comments, we may
ask
you to provide us with supplemental information so we may better
understand your disclosure. After reviewing this information, we
may
or may not raise additional comments.

Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 10-K For the Fiscal Year Ended December 31, 2005

Item 6- Selected Financial Data, page 15

1. You have not substantively justified the use of EBITDA or EBIT.
Your statement that EBITDA and EBIT may be used to analyze
profitability between companies and industries is not relevant to
its
presentation as a measure of operating performance. Further,
while
EBITDA and EBIT may be used by analysts as a measure of operating
performance, footnote 44 of FR-65 states this cannot be the sole
support for presenting a non-GAAP financial measure. Therefore,
please revise to eliminate the presentation of EBITDA throughout
your
filing.
2. Measures such as EBIT, EBITDA and "free cash flow" constitute
non-
GAAP measures. The presentation of these measures in filed
documents
is subject to the disclosure requirements set forth in Item 10 of
Regulation S-K. Your current presentation does not comply with
these
requirements. Please revise your presentations, as appropriate,
or
omit these measures from your filed reports.

3. If you elect to present net cash flow provided by operating
activities in your table, please also present net cash flow
provided
by/used in investing activities and financing activities for a
more
complete and balanced picture of your cash flows.

4. The purpose of the selected financial data table is to
highlight
certain significant trends in financial conditions and results of
operations. Item 301 requires disclosure of selected balances
from
your financial statements for each of the last five years. While
you
may elect to include additional items in the table, any non-GAAP
balances or related ratios should be presented in a separately
labeled section at the end of the table. They should not be
commingled with the GAAP disclosures. Please revise your format
accordingly. In this regard, please also omit the presentation
from
your narrative discussion of GAAP operating results on page 24.

5. The measures EBIT and EBITDA should be presented in an
appropriate
context with clarification of their expected use. A performance
measure looks at the degree of success or failure of an enterprise
for a given period of time. A liquidity measure looks at the
short
run ability of an enterprise to pay maturing obligations. You
refer
to the usefulness of these measures to "analyze profitability
between
companies" and you reconcile them to net income. However, you
also
state that the measures indicate whether earnings are adequate to
pay
debts, you display your related ratios under the caption
"Statement
of Cash Flows Data" and your clearest demonstration of their
purpose
and effective use appears in conjunction with your discussion of
"Cash Flows" on page 30. You have not justified the use of EBIT
and
EBITDA as performance measures. Please delete them from your
filing.
Alternatively, if they constitute liquidity measures, please
revise
your accompanying discussions and reconciliations to so state. We
may have further comments upon review of your revised
presentation.

Item 7- Management Discussion and Analysis of Condition and
Results
of Operations

Small Business, page 26

6. During the 2005 fiscal year, you began allocating corporate
costs
to New England Business Servises, Inc. ("NEBS".) However, you
have
not quantified the allocation percentage or your allocation
methodology. As such, please tells us and revise to disclose your
allocation percentages as well as your allocation methodology.

Cash Flows, page 27

7. Due to the acquisition of NEBS, your debt levels increased
significantly. Further, you have experienced a significant
decrease
in "free cash flows", as noted on page 15 of your filing, and your
working capital is negative. As such, please revise to include a
discussion of cash flow trends and your ability to service your
debt
through operating cash flows.

8. Further, due to the materiality of your debt, please consider
expanding Note 13 to include a detailed discussion regarding your
debt covenants. Your discussion should disclose and quantify any
material covenants as well as whether you were and expect to be in
full compliance within the next fiscal year.

Other Changes in Financial Condition, page 33

9. It appears that goodwill and intangible assets, including
contract
acquisition costs, constitute over 65% of your total assets. In
view
of the relative significance of these balances and given your
shareholders` deficit and your working capital deficiency, this
fact
should be specifically disclosed and the potential implications
discussed in the filing. Consideration should be given to
disclosing
and discussing the relative composition of your assets within Risk
Factors as well.

Item 8- Financial Statements and Supplementary Data

Note 1- Significant Accounting Policies

Contract acquisition costs, page 49

10. You amortize contract acquisition costs over a one to ten year
period. However, as disclosed on page 18, your supply contract
duration periods average 3 to 5 years. As such, please tell us
why
you are amortizing certain contract acquisition costs over a 10
year
period.

Revenue Recognition, page 51

11. We note that you generally recognize revenues when shipped or
as
services are performed. As such, it appears that you may be using
more than one revenue recognition methodology. If so, please tell
us
and revise future filings to disclose all of your revenue
recognition
criteria.

Other non-current assets, page 57

12. It appears that there was a $19,992,000 change in "contract
acquisition obligations." Due to the materiality, please tell us
the nature of the change. That is, explain how this balance is
derived. We note that the accrual balance is disclosed on page
33.
Further, please tell us and revise your critical accounting
policies
within MD&A, in future filings, to disclose the major assumptions
used to arrive at the estimated balance of this account as well as
how you track these obligations.

As appropriate, respond to these comments within 10 business
days or tell us when you will provide us with a response. You may
wish to provide us with marked copies of the amendment to expedite
our review. Please furnish a cover letter that keys your
responses
to our comments and provides any requested supplemental
information.
Detailed cover letters greatly facilitate our review. Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

Pursuant to Rule 101(a)(3) of Regulation S-T, your response
should be also be submitted in electronic form, under the label
"corresp" with a copy to the staff.

We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

You may contact Juan Migone at (202) 551-3312 or the
undersigned at (202) 551-3211 if you have questions regarding
comments on the financial statements and related matters.


Sincerely,




David R. Humphrey
Branch Chief-Accountant
Douglas J. Treff, Senior Vice President and Chief Financial
Officer
Deluxe Corporation
April 5, 2006
Page 5