SecProbe.io

September 10, 2012

Via E -mail
Chris Lucas
Group Finance Director
Barclays PLC
Barclays Bank PLC
1 Churchill Place
London E14 5HP, England

Re: Barclays PLC
 Barclays Bank PLC
 Form s 20-F for Fiscal Year Ended December 31, 2011
Filed March 30, 2012
Form 6 -K Filed July 27, 2012
File Nos. 001 -09246 and 001 -10257

Dear Mr. Lucas:

We have reviewed your filings 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 filings, 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 include a draft of your
proposed disclosures that clearly identifies new or revised disclosures.  If you do not believe our
comments apply to your facts and circumstances or do not believ e an amendment is appropriate,
please tell us why in your response.

After reviewing any amendment to your filings and the information you provide in
response to these comments, including the draft of your proposed disclosures, we may have
additional com ments.

Form s 20-F for Fiscal Year Ended December 31, 2011

Board Corporate Governance and Nominations Committee Report, page 9

1. We note from your disclosure on page 10 that in 2011 you concluded that the
Committee’s performance could be improved and tha t you implemented an action plan as
a result.  In future filings, please expand your disclosure to explain the action plan and
how it changed Committee processes.

Chris Lucas
Barclays PLC
Barclays Bank PLC
September 10, 2012
Page 2

 Board Audit Committee Chairman’s Report, page 12

Internal Controls, page 13

2. Please expand your disclosure in future filings to describe the material components of the
remediation program that was implemented following the fine imposed on Barclays
Capital for breaches of client asset segregation rules and your compliance with the
program.

3. Pleas e describe your compliance with the undertakings contained in the Deferred
Prosecution Agreement related to US sanctions and US dollar payment practices.

Key Risk Issues, page 15

4. In future filings, please provide expanded disclosure that addresses the re solution of the
key risk issues presented in this section.  With respect to risks relating to your risk
management framework, please also expand your disclosure in the “Risk management”
section to explain the results of the Committee’s consideration of the se issues, including
whether changes to risk management occurred as a result of such review.

Risk Management, page 40

Credit Risk, page 52

F. Identifying Credit Risk Loans, page 62

5. Please revise your disclosure in future filings to describe how you det ermine the
emergence period for purposes of determining the appropriate amount of allowance for
loan losses.  If this varies by loan type, please provide this disclosure by loan type.
Additionally, to the extent that the emergence periods vary over time, please discuss the
drivers that result in the shortening or lengthening of the emergence periods.

I. Forbearance, page 64

6. We note your disclosure that you utilize a management overlay as the only practical
means of factoring certain recent conditions into impairment calculations for your retail
accounts until your models can be recalibrated.  Please revise your disclosure in future
filings to discuss the factors considered in determining the amount of  overlay related to
these loans  and discuss the diff erences between this process and that used for your
regular retail loan portfolio.

Chris Lucas
Barclays PLC
Barclays Bank PLC
September 10, 2012
Page 3

 Retail Credit Risk, page 69

7. Please revise your disclosure in future filings to discuss the difference between
accounting charge -off and write -off.  For example, if the accounting charge -off relates to
the valuation reserve, please clarify that.  Please also disclose the impact that the
shortened period between accounting charge -off and write -off has had on your provision
and allowance for loan losses, and quantify the im pact where possible.  In this regard, we
note that the reduction of the period between accounting charge -off and write -off from 18
months to 12 months across the majority of the unsecured portfolios was, at least in part,
disclosed as a factor driving the reduction in credit risk loans and potential credit risk
loans, as well as reduction in impairment allowances.

8. We note your disclosure on page 73 that you would not consider a retail loan to be
renegotiated where the amendment is at the request of the cus tomer, there is no evidence
of actual or imminent financial difficulty and the amendment meets with all of your
underwriting criteria.  Given the nature of retail loans, clarify how often all of these
conditions would be met at the time of the amendment an d discuss the types of situations
driving the amendment.  For example, clarify whether this situation typically occurs
when the borrower chooses to refinance based on lower current market interest rates.

9. We note that your table on page 73 excludes certain  interest -only UK home loans that
have not been classified as forbearance because the monthly contractual cash flows have
not been altered.  Please respond to the following.

 Tell us how you concluded that these loans should not be classified as forbearanc e
considering that the overall timing of contractual cash flows of the loans have
been altered.

 Tell us whether the borrower initiated the forbearance request due to financial
difficulty and clarify whether the term extensions were occurring at the end of the
interest -only period or after amortization began.

 Clarify how term extensions on this loan product differ from term extensions on
other UK home loans which do result in the classification as forbearance.

 Discuss whether you consider these loans as  a separate risk pool when
determining the appropriate amount of collective retail allowance for loan losses
and tell us how you considered paragraphs AG87 -AG88 of IAS 39 in your
conclusion.

10. We note your disclosure that you allow re -aging of an accoun t once in 12 months or
twice in 5 years, providing strict qualification criteria are met, including making three
consecutive monthly payments.  You also disclose the fact that these re -aged accounts are

Chris Lucas
Barclays PLC
Barclays Bank PLC
September 10, 2012
Page 4

 not considered to be restructured because the contrac tual monthly payments remain
unchanged.  Please respond to the following.

 Revise your disclosure in future filings to disclose the balance of re -aged loans for
each period presented and discuss changes in and levels of re -aged loans.  A
tabular roll forwa rd may be helpful.

 Disclose how you considered the change in the timing of overall contractual
payments when concluding that these loans should not be reported as renegotiated
because the monthly payment amounts have not changed.

 Discuss the “strict qualification” criteria that must be me before you allow the re -
aging to occur.

 Provide disclosure of the success rates of your re -aging criteria.  For example,
discuss the percentage of borrowers that receive a re -aging that later r equire
another re -aging or forbearance program, or that later default on the loan.

 Tell us whether you consider these loans as a separate risk pool when determining
the appropriate amount of collective retail allowance for loan losses and tell us
how you considered the guidance in paragraphs AG 87 -88 of IAS 39 in your
conclusion.

Market Risk, page 94

Margin and Balances, page 99

11. We note that your presentation analyzing net interest income has been separated between
customer interest income and non -custo mer interest income, which principally arises
from your hedging activities.  Please tell us and expand your disclosure in future filings
to better explain how interest income is earned on customer assets and customer
liabilities and the types of instrument s classified, and invested in, within each category.
For example, clarify whether customer assets represents things such as loans and
receivables classified as assets in your financial statements from which you recognize
interest income, and customer liab ilities represent things such as deposits and repurchase
agreements which are classified as liabilities in your financial statements, but where you
invest the proceeds in other assets such as securities and interest income is earned.

Net Interest Margin, page 100

12. We note your disclosure that your customer asset margin is determined by applying an
internal funding rate to customer assets and liabilities.  Please expand your disclosure in
future filings to describe how your internal funding rate is determin ed for the purpose of

Chris Lucas
Barclays PLC
Barclays Bank PLC
September 10, 2012
Page 5

 this disclosure.  As part of your expanded disclosure, please consider disclosing the range
of internal funding rates determined for each of the businesses, as well as the average
internal funding rate which is used for purposes of th is disclosure.  Please also discuss
whether there have been any changes during  the reported periods in the internal funding
rate and if so quantify the impact such changes have had on your disclosure.

Funding Risk – Liquidity, page 112

Liquidity Pool, p age 114

13. We note your tabular disclosure that you have £152 billion of assets in the liquidity pool,
of which 94% is located at Barclays Bank PLC.  Your disclosure also states that the
“residual liquidity pool” is held predominantly within Barclays Capital  Inc. (BCI) against
contractual and contingent stress outflows in the Liquidity Risk Appetite stress test at the
legal entity level.  We also note your disclosure on page 158 that indicates that Barclays
Capital has a liquidity pool of £152 billion, which appears to be the same liquidity pool.
Please revise your future filings to quantify the amount of liquidity pool that is
attributable to Barclays PLC, Barclays Bank PLC and at Barclays Capital to arrive at the
total Group liquidity pool and clarify if th ere is any difference between the “liquidity
pool” and the “residual liquidity pool.”  Discuss whether there are any restrictions on any
of the liquidity pools at any of these entities that may restrict the availability of liquidity
other entities within t he Group and , if so, revise your disclosure to provide a brief
discussion of those restrictions.  Refer to Item 303(a)(1) of Regulation S -K.

14. In this regard, we also note your disclosure that the liquidity pool moved within a month
end range of  £140 billi on to £167 billion and that at June 30, 2012  you disclose on
page 3 of your Form 6 -K filed July 27, 2012 that this range was  £152 billion to £173
billion . Given the variance in the month end range amounts, please revise to provide an
average balance of your liquidity pool during the period.

Liquidity Regulation, page 116

15. We note your disclosures here and on page 36 of your Form 6 -K filed July 27, 2012
presenting the Liquidity Coverage Ratio (LCR) and the Net Stable Funding Ratio
(NSFR).  Given that these measures are based on Basel III, which  has not yet been
implemented, they appear to be non -GAAP measures as defined by Item 10(e) of
Regulation S -K.  P lease revise future filings  to label the measure as non -GAAP and
provide further clarifying disclosures regarding the use of the metrics, including more
discussion on how they are calculated.

Chris Lucas
Barclays PLC
Barclays Bank PLC
September 10, 2012
Page 6

 Consolidated Financial Statements, page 169

Consolidated Ca sh Flow Statement, page 173

16. We note the line item net decrease/(increase) in loans and advances to banks and
customers shows a £38.3 billion decrease in loans and advances to banks and customers
during the year ended December 31, 2011, but the consolidate d balance sheet shows a
£13.6 billion increase in those two line items between December 31, 2010 and 2011.
Please tell us the factors driving the differences between the loan balances between these
two financial statements.

Notes to the Financial Statements, page 176

7 – Credit Impairment Charges and Impairment on Available -for-Sale Assets, page 182

17. Please revise your future filings to disclose your policy for evaluating interest income for
collectability.  In this regard, we note your policy tha t following impairment, interest
income continues to be recognized at the original effective interest rate on the restated
carrying amount, in accordance with paragraph AG 93 of IAS 39, but you also have
certain nonaccrual lendings , per your disclosure in footnote (a) to the average balance
sheet table on page 280.  As part of your response and expanded disclosure, please
discuss the factors considered when placing loans on non -accrual and the factors
considered when returning a loan to accrual status.

26 - Goodwill and Intangible Assets, page 214

Critical Accounting Estimates and Judgments, page 215

18. Please revise your disclosure in future filings to discuss how you determine the carrying
value of your cash generating units for the purposes of determining goodwill impairment .
Please address the following.

 Clarify in further detail whether you use a capital allocation methodology to
determine the carrying value of your cash generating units.  For example, tell us
whether, and if so how, you con sider economic capital allocated to your cash
generating units for this purpose.  Specifically, discuss whether you allocate your
shareholder’s equity to your cash generating units on a pro rata basis using
assigned economic capital as a basis for allocati on or whether you simply use the
economic capital assigned to the cash generating unit.

 To the extent the total capital required to support all of your cash generating units’
activities is more or less than the total shareholder’s equity of the Group, ple ase
tell us how you account for any difference.  In this regard, your disclosure on

Chris Lucas
Barclays PLC
Barclays Bank PLC
September 10, 2012
Page 7

 page 108 indicates that you may not allocate all of your capital to your businesses
when determining the amount of required economic capital.  For example, we
note the peri od end average economic capital requirement (including pension risk
and excluding goodwill) is less than shareholders’ equity of the Group and
shareholders’ equity excluding non -controlling interests less goodwill.  Please
clarify how any capital not alloc ated to the cash generating units is not considered
when determining the fair value of the cash generating unit.

 To the extent that you do not utilize a capital allocation model to determine the
carrying value of your cash generating units, please clarif y whether you allocate
any recognized liabilities to your cash generating units for purposes of
determining the carrying value of the cash generating units.

Additional Financial Disclosure (Unaudited), page 277

Commitments and Contractual Obligations, pa ge 278

19. We note that your contractual obligations table appears to exclude the related interest
expense on your long -term debt obligations which appears to be significant based on your
supplemental cash flow information disclosure of cash paid for interest  during each of the
three years presented and your disclosure in Note 3.  Please revise this table in future
filings to include estimated interest payments on your long -term debt and disclose any
assumptions you made to derive these amounts. To the extent that you can reasonably
estimate the amount and/or timing of payments that you will be obligated to make under
interest rate swaps or similar derivatives you use to manage interest rate risk related to
your long -term debt, please ensure these amounts are i ncluded in the table and disc