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Mail Stop 4561

         September 18, 2008
  Chris Lucas Group Finance Director Barclays PLC and Barclays Bank PLC 1 Churchill Place London, E14 5HP, England
 Re:  Barclays PLC and Barclays Bank PLC
Form 20-F for the Fiscal Year Ended December 31, 2007
File No.  1-09246, 1-10257
 Dear Mr. Lucas:

We have reviewed your filings and have the following comments.  Please be as
detailed as necessary in your explanation.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

* * * *

Chris Lucas
Barclays PLC and Barclays Bank PLC
September 18, 2008 Page 2 of 5  Form 20-F for Fiscal Year Ended December 31, 2007

 Business Review

 Critical accounting estimates

Fair value of financial instruments
Derivatives, page 49

1. Please tell us whether the models you use to value derivative lia bilities take into
consideration your own credit quality.  If  so, briefly describe the model inputs you
use to measure your own credit quality (i.e. CDS spreads, LIBOR+spread, etc.).

2. Please quantify for us the portion of mark et value adjustments related to changes
in your own credit risk for each period presented.

Financial Review
 Off balance-sheet arrangements

SIV-Lites, page 52
3. We note your disclosure here that the Group structured and helped to underwrite
three SIV-lite transactions and provided £0.55bn in liquidity facilities as partial
support to the £2.6bn of CP programmes on these transactions.  We also note your disclosure on page 92 that during the period the Group’s balance sheet expanded
due to liquidity facilities th at were provided to three cl ient SIV-lites which were
restructured during the period.  Please pr ovide us with the following additional
information regarding these transactions:

• clarify whether the SIV-lites are conso lidated, or if they have ever been
consolidated;
• describe in further detail the structure of the SIV-lites and describe your
obligations under the facilities (e.g. liquidity provider, etc.).
• describe how the SIV-lites were restru ctured during the pe riod.  If the SIV-
lites were restructured such that your obligations have changed since inception, describe the change(s);
• explain how your balance sheet expanded due  to liquidity fac ilities that were
provided to the SIV-lites which were restructured during the period; and
• to the extent the SIV-lite s are not consolidated, please provide your analysis
of the circumstances and indicators in paragraph 10 of SIC 12 and the
appendix to SIC 12 supporting your conc lusion that you do not control the
SIV-lites.

Chris Lucas
Barclays PLC and Barclays Bank PLC
September 18, 2008 Page 3 of 5  Barclays Capital credit market positions

Other credit market exposures, page 53
4. Please tell us, and in future filings disclose, the percentage of performing US sub-
prime whole loan exposure as of the end of each reporting period.  Provide us with your proposed future disclosure.
 5. Please tell us, and in future filings describe, your US sub-prime “other direct and
indirect exposures.”  In addition, include relevant key metrics such as average
loan-to-value ratios, agency rating inform ation, delinquency data etc. that you use
to analyze these exposures.  Provide us  with your proposed future disclosure.
  Financial Statements

 Notes to the accounts

 Note 49.  Fair value of financial instruments, page 244

6. We note your disclosure in Note b that expected cash flows for each contract are
determined through modeling cash flows using appropriate financial-markets pricing models.  Further, we note the im pact of changing the assumptions to your
models (for those financial instruments fo r which the fair values were measured
using valuation techniques that are determ ined in full or in part on assumptions
that are not supported by observable mark et prices) to a ra nge of reasonably
alternative assumptions would be to in crease or decrease the fair value
significantly by up to £1.5bn or down to £1.2bn, respectively.  In future filings, please revise to disclose the follo wing regarding your pricing models:

• the specific pricing models  you use to calculate the fa ir value of your financial
instruments;

• a discussion of the significant assumptions and inputs into each  of these different
models for each class of financial instruments.  For example, disclose the
significant inputs into these models that have the potential to most impact the value determined, and the assumptions for those inputs for all periods presented;

•
the extent to which a particular valua tion model is used to value certain of
your asset and liability classes; and

• a discussion of how the impact of ch anging assumptions was calculated.  For
example, disclose the reasonably likely  range selected for each alternative
assumption and the corresponding percentages used in your sensitivity
analysis.

Chris Lucas
Barclays PLC and Barclays Bank PLC
September 18, 2008 Page 4 of 5
Refer to paragraphs 27 and BC38 of IF RS 7.  Provide us with your proposed
future disclosure.

* * * *

Please send us your response to these comments within 10 business days or tell us
when you will provide us with a response.  Please furnish a cover letter keying your
responses to our comments and provide any requested supplemental information.  Please
file your response letter on E DGAR.  Please understand that  we may have additional
comments after reviewing your responses to our comments.
   We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

Chris Lucas
Barclays PLC and Barclays Bank PLC September 18, 2008 Page 5 of 5
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact Dave Irvi ng, Staff Accountant, at (202) 551-3321, or me at
(202) 551-3474 if you have any questions.
Sincerely,

Sharon Blume Reviewing Accountant