SecProbe.io

February 15, 2012
 Via E-mail

Mr. Christopher Lucas Group Finance Director Barclays PLC 1 Churchill Place London E14 5HP  England
Re: Barclays PLC
Form 20-F for Fiscal Year Ended December 31, 2010 Filed March 21, 2011
  File No. 001-09246

Dear Mr. Lucas:
 We have reviewed your response dated October 28, 2011 and have the following
comment.  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 te n business days by providing the requested
information, or by advising us when you will provide the requested response.  Where we have requested changes in future filings, please incl ude a draft of your proposed disclosures that
clearly identifies new or revise d disclosures.  If you do not be lieve our comments apply to your
facts and circumstances, please tell  us why in your response.
 After reviewing the information you provide in response to these comments, including
the draft of your proposed disclosures, we may have additional comments.
            Form 20-F for Fiscal Year Ended December 31, 2010

Risk Management, page 42
Credit Risk, page 58
Corporate Loans, page 84

1. Please revise your future filings to addre ss the following related to your response to
previous comment eight in our letter dated September 28, 2011:
 In your response you state that more freque nt monitoring is carried out where the
property market is subject to significant de terioration.  Please revise future filings
to provide a brief description of the f acts and circumstances considered when

 Mr. Christopher Lucas Barclays PLC February 15, 2012 Page 2

 concluding that deteriorati on is significant.  Please clarify whether you monitor
deterioration in a property market by geogr aphy, class of loan, t ype of collateral,
etc.
 Describe the circumstances when you woul d monitor a loan at the individual
property level and the circumstances when  you would monitor property values at
the portfolio level.

 Your disclosure indicates that you only  perform a revaluation “when necessary”
when a loan moves to the Watch or Early Warning lists.  Please describe the facts
and circumstances considered when conc luding it is necessary to perform a
revaluation when a loan is moved to these lists.

 Please provide a clearer de scription of how you incorporate the impact of any
decrease in the fair value of collateral held  into your loan loss allowance.  Please
describe how you ensure that you are captu ring any incurred losses at the balance
sheet date as a result of declines in  property values in a timely manner.
              We urge all persons who are res ponsible for the 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.

You may contact Rebekah Linds ey, Staff Accountant at ( 202) 551-3303 or me at (202)
551-3494 if you have questions regarding these comments.

Sincerely,
  /s/ Kevin W. Vaughn
Kevin W. Vaughn Branch Chief