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                              December 13, 2022

       Hai Tran
       Chief Financial Officer
       CSG Systems International, Inc.
       6175 S. Willow Drive, 10th Floor
       Greenwood Village, Colorado 80111

                                                        Re: CSG Systems
International, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Filed February 18,
2022
                                                            File No. 000-27512

       Dear Hai Tran:

              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 10-K for the Fiscal Year Ended December 31, 2021

       Note 2. Summary of Significant Accounting Policies
       Reclassifications, page 49

   1.                                                   We note you determined
that the settlement and merchant reserve assets consist of
                                                        restricted cash. Please
disclose the nature of the restrictions applicable to the settlement
                                                        and merchant reserve
assets. Refer to ASC 230-10-50-7 and Rule 5-02(1) of Regulation S-
                                                        X.
   2.                                                   Please explain the
changes in the facts and circumstances beginning with the second
                                                        quarter of 2021 that
led you to determine the settlement and merchant reserve assets are
                                                        restricted. Clarify for
us the nature of the cash flow activity in settlement and merchant
                                                        reserve liabilities
that allowed you to reclassify the changes in settlement and merchant
                                                        reserve liabilities
from cash flows from operating activities to cash flows from financing
                                                        activities. In light of
the presentation changes and reclassifications tell us how you
 Hai Tran
CSG Systems International, Inc.
December 13, 2022
Page 2
         considered the accounting and disclosure guidance in ASC 250.
Settlement and Merchant Reserve Assets and Liabilities, page 55

3.       We note that your payments services requires you to hold your
customer's cash in trust,
         indicating the fiduciary nature of the settlement and merchant reserve
activity. Please tell
         us and disclose the following regarding your payments services
resulting in settlement and
         merchant reserve assets and liabilities recorded by the company:
             Clarify the nature, terms and features of any agreements that
control the custody and
             use of funds received for customers. In this regard, your response
should address who
             holds legal ownership or title to the funds and how the funds are
encumbered and
             what conditions, legal or otherwise govern the custody and use of
the funds.
             Clarify the terms and conditions associated with your customer
fund obligations.
             Your response should address how this is an obligation of the
company versus an
             obligation of your customers. Explain the impact to the company in
the event you fail
             to perform.

       You may contact Joseph Cascarano, Senior Staff Accountant, at (202)
551-3376 or
Robert S. Littlepage, Accountant Branch Chief, at (202) 551-3361 with any
questions.



FirstName LastNameHai Tran                                     Sincerely,
Comapany NameCSG Systems International, Inc.
                                                               Division of
Corporation Finance
December 13, 2022 Page 2                                       Office of
Technology
FirstName LastName