SecProbe.io

September 8, 2010

Chris Lucas Group Finance Director Barclays PLC 1 Churchill Place London E14 5HP, England
Re: Barclays PLC  Form 20-F
Filed March 19, 2010 File No. 001-09246
 Dear Mr. Lucas:
 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 this letter within ten business days by amending your filing, by
providing the requested information, including a draft of your proposed disclosures to be made in
future filings or by advising us when you will prov ide the requested response, as is appropriate
for each comment listed below.  If you do not be lieve our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Form 20-F for the fiscal year ended December 31, 2009

General
 1. We are aware of press releases by the U.S. Department of Justice and the New York
County District Attorney’s Office, dated August 18, 2010, to the effect that you have
agreed to forfeit $298 million for having conduc ted illegal transactions on behalf of
customers from Cuba, Iran, Sudan, and certain  other sanctioned countries from the mid-
1990s through 2006.  We note the disclosure on page 222 of your Form 20-F, in Note 36
to the financial statements, regarding this ma tter.  We also note from the disclosure on
page 117 of your Form 20-F that you opera te in Africa and the Middle East, regions
generally understood to include Sudan, Syri a, and Iran.  As you know, Cuba, Iran, Sudan,
and Syria are identified by the U.S. Departme nt of State as state sponsors of terrorism,
and are subject to U.S. economic sanctions and export controls.

Chris Lucas Barclays PLC
September 8, 2010 Page 2

Please describe to us the natu re and extent of your past, cu rrent, and anticipated business
activities related to, or contacts with, C uba, Iran, Sudan, and Syria, whether through
subsidiaries, affiliates, or other direct or indirect arrangements.  Your response should
describe any business contacts you have had with the governments of the referenced
countries or entities affiliat ed with, or controlled by, t hose governments.  Identify any
state-owned entities that have received fi nancing from, or arranged by, you, and the uses
made of the funds received.  In addition, disc uss the applicability of Section 104 of the
Comprehensive Iran Sanctions, Accountabi lity, and Divestment Act of 2010 to your
activities related to Iran.
 2. Please discuss the materiality of your business activities and other contacts with Cuba,
Iran, Sudan, and Syria, described in respons e to the foregoing comment, and whether
they constitute a material investment risk for your security holders.  You should address materiality in quantitative terms, incl uding the approximate dollar amounts of any
revenues, assets, and liabilities associated with  each of the referenced countries for the
last three fiscal years and the subsequent period.  Also, addr ess materiality in terms of
qualitative factors that a reasonable inve stor would deem important in making an
investment decision, including the potentia l impact of corpor ate activities upon a
company’s reputation and share value.  As you may know, various state and municipal governments, universities, and other investor s have proposed or a dopted divestment or
similar initiatives regarding investment in companies that do business with U.S.-
designated state sponsors of terrorism.  Your  materiality analysis  should address the
potential impact of the investor sentiment evidenced by such actions directed toward
companies that have operations associated w ith Cuba, Iran, Sudan, and Syria.  In this
regard, please also address the potential im pact of the forfeiture and underlying legal
matters described in the Department of Jus tice and New York County District Attorney’s
Office press releases.

Section 1.  Business Review

Balance Sheet Commentary
Total Assets and Risk Weighted Assets by Business 2009/08, page 14

3. We note the statement in your Q4 Earni ngs call that you have  worked with your
counterparties throughout the year to eliminate offsetting contracts at no cost and with no
capital impact, which contribu ted to a reduction in the derivatives gross up of well over
£500 billion.  Please tell us and revise fu ture filings to more thoroughly discuss the
reasons for the large fluctuations in derivativ e asset and liability balances in the periods
presented.

Adjusted Gross Leverage 2009/08, page 15

4. Please revise your reconciliation in future fili ngs to disclose your leverage ratio according
to IFRS for the periods presented.

Chris Lucas Barclays PLC
September 8, 2010 Page 3

5. In this regard, please tell us and revise future filings to discuss material fluctuations in the
leverage ratio and adjusted gross leverage  ratio in the periods presented.  In your
discussion, please address any mate rial variations in the levera ge ratio and adjusted gross
leverage ratio at each month end during 2009 and 2010 to date.

6. We note your disclosure that limited netting is permitted under IFRS even for receivables
and payables with the same counterparty wh ere there are contractually agreed netting
arrangements.  Please tell us and revise your future filings to discuss the specific
differences in netting provisions appl icable to U.S. GAAP and IFRS.

Risk Management, page 89
 7. We note in September 2009, Barclays Capital transferred assets of £7,454m, including
£5,087m in credit market assets, to Protium Finance LP (Protium), a newly established
fund.  In addition, as part of the trans action, we note Barclays extended a £7,669m 10-
year loan to Protium, which will be repa id during the term from cash generated by the
fund and is secured by the assets of the fund.  Please provide us with the following
additional information:
• It is our understanding that you have not consolidated Protium for accounting purposes
and have derecognized the transferred assets .  Please provide us with your accounting
analyses that support your determination that derecognition of  the transferred assets is
appropriate and that consolidati on of Protium is not required.
• Tell us how these assets are reported for re gulatory purposes.  If they remain on your
balance sheet, explain why there is a difference between your regulatory and IFRS
reporting.
• We note the loan to Protium was assesse d for impairment at June 30, 2010 that no
impairment was identified.  Please provide us  with your analysis that supports this
determination and any updates through the current date.
 Section 3.  Financial Statements

Accounting Policies
9.  Sale and Repurchase Agreements (including stock borrowing and lending), page 172

8. You disclose that securities delivered under repurchase agreements are retained on the
balance sheet when substantially all the risk s and rewards of owners hip remain with the
Group.

• Please tell us in detail and revise future filings to clearly disclose whether you have
derecognized any securities delivered  in your repurchase agreements.
 • If you have, please provide us the specific facts and circumstances  related to these
transactions and provide us your accounting anal ysis that supports your treatment.  Also,
revise future filings to quan tify the amount derecognized at each balance sheet date, the
average amount derecognized for the peri ods presented and discuss how you calculated
the average amount.

Chris Lucas Barclays PLC
September 8, 2010 Page 4

 9. If you have derecognized any securities delivered under repurchase agreements at the subsidiary level, tell us how the transactions are reflected in the consolidated financial statements.

Note 6 – Other Income, page 187
 10. We note you exchanged certain Ti er 2 perpetual debt for new issuances of lower Tier 2
dated loan stock during 2009 re sulting in a gain of £1,170m.  Please describe the specific
terms of the old and new debt issuances and tell us how you determined such terms were
substantially different.  In addition, te ll us how you accounted for any embedded
conversion option on the new debt, including the amount recorded in your financial
statements.  Refer to paragraph AG31 of IAS 32 and paragraph 40 of IAS 39.
 Note 22 – Intangible Assets, page 200

11. We note that you acquired the New York Stock Exchange’s Designated Market Maker
(DMM) assignments of LaBranche & Co. in the first quarter of 2010 and the DMM rights
of Bear Wagner Specialists  LLC in 2009.  Tell us whet her your business has been
adversely impacted by the lack of timely mark et data in the internal order/execution
system of the NYSE or by lower trading volumes and lower volatility. If so, please tell us
what consideration you gave in testing th ese and any other recorded DMM rights for
impairment under IAS 36 and tell us the us eful life and amortization method used.
 Item 19.  Exhibits

 12. Please tell us why you have omitted certain schedules, exhibits and annexes from the amended and restated stock purchase agreement filed as Exhibit 4.36 to your Form 20-F.
 Form 6-K filed 08/05/2010

Note 16 – Acquisitions, page 75
 13. We note approximately £2.6bn of the assets you acquired as part of the 2008 Lehman
Brothers acquisition had not been rece ived by June 30, 2010.  Further, we note
approximately £2.0bn of these assets were rec ognized as part of the accounting for the
acquisition and are included in  the balance sheet at June 30, 2010.  Finally, we note the
related ongoing litigation.  Please provide us with the following additional information:

• Tell us how you determined the £2.0 bn of asse ts to be recognized as part of the
acquisition and on the balance sh eet at June 30, 2010.  Explain to us in detail why these
assets were recognized while £0.6 bn were not;
• Tell us why the amounts recognized and ac quired but not received changed from
December 31, 2009 to June 30, 2010 (£1.8 bn vs. £2.0 bn and £2.3 bn vs. £2.6 bn respectively);

Chris Lucas Barclays PLC September 8, 2010 Page 5

• Describe the types of assets that were recognized and thos e that were not;
• Tell us why you believe these assets have not been delivered;
• Considering it has been almost two years since you acquired these assets and you still
have not received them, tell us why you believe recording them on your books is
appropriate and why no write-offs are necessary; and
• Provide us with an update of  the ongoing litigation through the current date, including
whether any accruals have been recorded.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact David Irving at (202) 551-3321 or Sharon Blume at (202) 551-3474 if
you have questions regarding comments on the fina ncial statements and related matters.  Please
contact Eric Envall at (202) 551- 3234, Pradip Bhaumik of the Office of Global Security Risk at
(202) 551-3333 or me at (202) 551- 3366 with any other questions.

Sincerely,

Michael Seaman Special Counsel