SecProbe.io

February 1, 2013

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
Form 6 -K Filed October 31, 2012
File Nos. 001 -09246 and 001 -10257

Dear Mr. Lucas:

We have reviewed your response dated October 8, 2012 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 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, 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 s 20-F for Fiscal Year Ended Decemb er 31, 2011

Key Risk Issues, page 15

1. We note from your response to prior comment 4 that in future filings you intend to
include cross -references from this section to “other areas of the Form 20 -F where
disclosure is relevant to the specific key risk issu es…or which describe specific actions
taken [as a result] of such key risk issues.”  However, it is unclear from your response
and existing disclosure what other areas of your 2011 Form 20 -F specifically relate to the

Chris Lucas
Barclays PLC
Barclays Bank PLC
February 1, 2013
Page 2

 bulleted key risk issues that are pres ented on page 15.  Please advise, or describe further
how you will expand your disclosure in future filings to comply with prior comment 4.

Risk Management, page 40

Credit Risk, page 52

F. Identifying Credit Risk Loans, page 62

2. Please refer to prior comment 5.  We note your response and your proposed disclosure
regarding the emergence period for various portfolios.  You define the emergence period
as the timeframe in which losses have been incurred but not yet specifically identi fied in
portfolios of loans at the balance sheet date.  Further, your disclosure on page 63 of the
December 31, 2011 20 -F states that “ [t]he incurred but not yet reported calculation is
based on the asset’s probability of moving from the performing portfolio to being
specifically identified as impaired within the given emergence period and then on to
default within a specified period.”   Please address the following:

 Please clarify what you mean by “specifically identified as impaired.”  For example,
clarify if this is when a loan becomes past due, you receive notice of bankruptcy, etc.,
or at some other point.  To the extent this varies among your portfolios, please
explain how.

 Please clarify why you define the emergence period based on the time ta ken from
“receiving a default indicator ” to an identified impairment being incurred for  your
wholesale portfolios in the Corporate Banking and Investment Ba nking divisions.
In this regard, the period of “receiving a default indicator” appears to be pot entially
different than the point that the loss was incurred.  Additionally, clarify the types of
things you would consider to be a “default indicator” for these portfolios.

 Expand your disclosure to specifically discuss how you test these periods against  the
actual time elapsing from the initial indication of potential default to the loss event.
In this regard, it appears that the emergence period is only a portion of this timeframe ,
but your response indicates that you use the whole period to validate t hat the
emergence period is reasonable.

 Tell us in more detail why a longer (six -month period) would be used for larger
counterparties and large loan balances that are subject to individual monitoring for
early signs of default, as compared to retail bank s portfolios where individual
monitoring would not be occurring.

 Clarify how this period relates to the “write -off” period and “charge -off” periods
discussed in response to our prior comment 7.

Chris Lucas
Barclays PLC
Barclays Bank PLC
February 1, 2013
Page 3

 Retail Credit Risk, page 69

3. Please refer to prior comment 9 and address the following:

 We note your response that you were unable to identify whether customers were
experiencing financial difficulty at the time the loans were extended.  We further note
that you subsequently determined that the loans should not be classified as
forbearance, in part because they met minimum age and term requirements and you
did not lower the interest rate.  Tell us whether you evaluated if they would have
access to alternative funding at the same rate, or whether the rate at which th e loan
was extended was commensurate with the market rate for a loan of similar credit
quality at the time of extension.  If so, tell us how and if not, tell us why not.

 Clarify how long the interest -only period for these loans was typically extended.
To the extent it was for one year or more, discuss how you consider the impact on
your 30 day and 90 day arrear numbers in your response.  For example, given that the
borrower is only required to make the interest payment, it appears this could
positive ly impact the delinquency trends noted.

 Clarify whether the loans convert to amortizing after the interest -only period ends,
and if so, discuss the typical percentage impact to the monthly payment upon
conversion to an amortizing loan.  Also, discuss the periods when the vast majority of
these loans convert to amortizing (if applicable), and discuss any trends in
delinquency statistics upon the conversion to an amortizing loan, to the extent they
are different from the statistics in your response.

 Tell us the percentage of these loans that have reached maturity, and of those, tell us
how many were able to pay off the balance of the loan and how many subsequently
defaulted upon maturity.

 Tell us whether you have provided any more extensions for th ese loans, and if so,
discuss the reasons for doing so and whether you consider the loans to be in
forbearance upon the subsequent extension.

 You indicate that you believe that the subsequent performance of these loans supports
the fact that they were not  classified as forbearance because they were performing
better than those loans that were classified as such.  Please tell us how you considered
the fact that they are also not performing as well as your regular loan portfolio, which
indicates that there h as been some decline in credit quality, comparatively.  In this
regard, we note that the 30 and 90 days arrears percentages are double that of your
normal loan portfolio at December 31, 2011 and remain similarly elevated at
June 30, 2012.

Chris Lucas
Barclays PLC
Barclays Bank PLC
February 1, 2013
Page 4

  We note th at you discuss several factors you currently consider when determining if a
term extension should be classified as forbearance.  Please tell us if these factors are
consistent with what you considered historically, and if not, describe the factors
consider ed historically.

 You indicate that you do not treat these loans as a separate loan pool historically
because these are performing assets that have no objective evidence of impairment.
It is unclear how you determined that there was no evidence of impair ment
considering that the timing of the contractual cas h flows of the original loan has
changed.  Please provide additional information as to how you concluded that
including these loans in the general loan pool is appropriate considering the guidance
in AG87-88 if IAS 39  or tell us how you concluded that your models are
incorporating the increased risk elsewhere in the calculation .

4. As a related matter, we note from your Q3 2012 Interim Management Statement Question
and Answer Session document from your we bsite that approximately 44% of your
mortgage book is interest -only, and that you have been looking closely at your portfolios
of these mortgages as you are now seeing maturation of these mortgages.  Please expand
your disclosures in future filings to disc uss the following:

 Disclose the percentage of your mortgage portfolio that is interest -only.

 Discuss the key terms of your interest -only mortgage portfolio.  For example, discuss
whether these loans ever convert to amortizing, the typical interest -only p eriod, the
current LTVs for this portfolio and percentage of your interest -only loans maturing in
the next three years, separately disclosed by year.

 Separately disclose delinquency statistics for your interest -only m ortgage portfolio
from your noninteres t-only mortgage portfolio.

 Discuss whether you continue to make interest -only loans and describe any
differences in your current underwriting practices for these loans.

 Discuss the steps you are taking to mitigate the risk of a significant number of thes e
loans maturing in the next few years.  For example, discuss any programs you have to
convert these mortgages into more conventional amortizing loan products.

5. Please refer to prior comment 10.  In your response, you indicate that these loans are not
segregated into a separate pool for the purposes of determining the allowance for loan
losses and that you believe the risk of non -performance is reflected in the probability of
default being assigned to them in your impairment models.  As the need for a re -age,
even if not considered significant enough to classify a loan as impaired, would indicate
evidence of a decline in credit quality that is different from a loan that does not need a re -

Chris Lucas
Barclays PLC
Barclays Bank PLC
February 1, 2013
Page 5

 age, it is unclear how you concluded that a separate risk pool was not  appropriate under
paragraphs AG87 -88 of IAS 39.  Please provide additional information as to how you are
appropriately and timely capturing the risk related to these loans in your allowance.
For example, please specifically explain how you are applyin g a higher probability of
default to these loans when they are classified in the same pool as loans that have not
been re -aged.

Market Risk, page 94

Net Interest Margin, page 100

6. Please refer to prior comment 12.  As requested, please revise your future  filings to
disclose the range of internal funding rates as well as an average rate for the period, or
tell us why this information is not relevant for disclosure.  Also, as requested, please
discuss whether there have been any material changes to these ra tes during the period and
if so, quantify the impact such changes have had on your disclosure.

Consolidated Financial Statements, page 169

Notes to the Financial Statements, page 176

26 – Goodwill and Intangible Assets, page 214

Critical Accounting Est imates and Judgments, page 215

7. We note your response to prior comment 18 where you describe your methodology for
determining the carrying value of your cash generating units (CGUs).  In your response,
you state that for UKRBB, average economic capital has  historically been used as an
approximation for the net asset value of that CGU, whereas for all of your other CGUS,
the carrying value has been determined using the actual net asset value of the relevant
CGU.   You also state for the 2012 and future impai rment tests, you intend to fully
allocate shareholder funds on a pro forma basis based on UKRBB’s share of group risk
weighted assets, as a better approximation of the UKRBB CGU’s net asset value.
Please respond to the following:

 Tell us in more det ail how you believe your methodology for determining the
carrying value of the UKRBB CGU complies with the guidance in paragraphs 75 and
75 of IAS 36 in light of the fact that those paragraphs state that a CGU includes the
carrying value of only those asse ts that can be allocated directly or allocated on a
reasonable and consistent basis, and does not include the carrying value of any
recognized liability unless the recoverable amount of the CGU cannot be determined
without consideration of the liability.

Chris Lucas
Barclays PLC
Barclays Bank PLC
February 1, 2013
Page 6

  Given that you do not identify the specific assets and liabilities directly attributed to
the UKRBB CGU, please tell us how you are able to estimate the cash flows from
that CGU.  In your response, please address why you believe your methodology
complies wi th the guidance in paragraph 77 of IAS 36.

 Describe in more detail how your new methodology for determining the carrying
value of the UKRBB CGU is performed.  For example, your response indicates that
you now intend to fully allocate shareholder’s funds o n a pro forma basis based on
UKRBB’s share of group weighted assets, but your response also notes that the
carrying value of all of your CGUs except for UKRBB do not include any allocation
of centrally held funding, such as subordinated debt or debt securi ties in issue.  Thus,
from your response,  it is not  clear how this methodology will fully allocate
shareholder’s funds on a pro forma basis, or why it would be appropriate to allocate
centrally held funding to one CGU, but not for determining the carrying value of all
CGUs.

 Clarify whether you determine the recoverable amount of the UKRBB CGU
differently from how you determine the recoverable amount of the other CGUs given
the different methodologies used to determine the carrying value of the CGUs.

Risk Factors, page 265

8. We note your responses to prior comments 22, 24 and 26 ; however, your risk factor
disclosure should provide all relevant information needed for an investor to fully
understand the risk presented.  Please provide us with proposed dis closure to be included
in future filings that addresses our prior commen ts and does not simply cross -reference
other sections of your Form 20 -F.

Operational risk, page 268

9. Please confirm that you will include the substance of your response to prior comment 28
in the risk factors section of your 2012 Form 20 -F, as well as any additional material
changes in facts and circumstances relating to the investigations cited in our prior
comment.

Regulatory risk, page 268

10. Please either confirm that you will include the substance of your response to prior
comment 29 under the “Regulatory risk” section in future filings, updated as appropriate
to reflect more recent changes, or provide us with proposed risk factor disclosure “that
provide[s] a more precise expl anation and quantification” of the costs associated with
regulatory compliance.

Chris Lucas
Barclays PLC
Barclays Bank PLC
February 1, 2013
Page 7

 Form 6 -K filed July 27, 2012

Exhibit 99.1

Results by Business, page 11

Investment Bank, page 19

11. Please refer to prior comment 33.  Item 301 of Regulation S -X requires you to provide
enough detail about your operating results for a reader to understand the drivers behind
material changes for the reported periods.  As this Form 6 -K is incorporated by reference
into your registration statements, please revise your future filin gs to provide the
information previously requested.  For example, we note your proposed disclosure that
Fixed Income, Currency and Commodities (FICC) in the half year ended June 30, 2012
as compared to the half year ended December 31, 2011 was due to a sig nificantly
improved trading environment.  Explain what you mean by that and whether revenue
increased due to an increase in market value, volume or a combination of these or other
factors.  Furthermore, we note from your Q3 2012 Interim Management Statemen t
Question and Answer Session document on your website that your FICC model is a
conservative one, and you tend to outperform competitors when markets are weaker and
perform less well when markets are stronger.  Please dis