SecProbe.io

September 24, 201 4

Via E -mail
Tushar Morzaria
Group Finance Director
Barclays PLC
Barclays Bank PLC
1 Churchill Place
London E14 5HP
United Kingdom

Re: Barclays PLC
 Barclays Bank PLC
Form s 20-F for the Fiscal Year Ended December 31, 201 3
Filed March 14, 2014
File No s. 001-09246 and 001 -10257

Dear Mr. Morzaria :

We have reviewed your filing s 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 s, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your respons e.

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

Form 20-F for the Fiscal Year Ended December 31, 201 3

Note 19 - Offsetting Financial Assets and Financia l Liabilities, page 291

1. We note your disclosure in footnote (f) to the table that certain amounts have been
restated in order to accurately reflect the identification of contracts with enforceable
netting arrangements.   Please respond to the following:
 Tell us when and how the error was first identified and by whom.
 Clarify the factors driving the change in conclusion that the amounts were actually
not subject to enforceable netting arrangements.
 Tell us whether you identified any control deficiencies as  a result of the identification
of this error, and if so, describe the nature of the deficiencies.

Tushar Morzaria
Barclays PLC
Barclays Bank PLC
September 24, 2014
Page 2

  Tell us whether you established any new controls as a result of the identification of
this error, and if so, describe to us the nature of the control enhance ments.

Note 29 – Contingent Liabilities and Commitments, page 303

2. We note your disclosure that further details about your litigation provision class can be
found in Note 30.   Please explain how your disclosure that combines matters that resulted
in a pro vision, a contingent liability or both provides insight into the nature and expected
timing of the resulting economic outflows of your litigation provision class, as
contemplated by paragraph 85 of IAS 37.

3. Please clarify whether legal and competition and  regulatory matters represent a single
contingent liability class. Additionally, please explain how your disclosure provides
insight in the nature of your contingent liabilities when it also includes information about
the nature of your provisions.    Refer  to paragraphs 86 and 87 of IAS 37.

4. Please tell us and revise your disclosure in future filings to clearly describe how you
evaluate whether both a provision and a contingent liability can arise from the same set of
circumstances.   Refer to paragraph 88 o f IAS 37.

Note 30 – Legal, Competition and Regulatory Matters, page 303

5. We note your disclosure on page 309 stating that you have not disclosed an estimate of
the potential financial effect on the Group of contingent liabilities arising from the
matters  where it is not practicable to do so.   Given that you can estimate the possible
financial effects for certain cases but not others, we believe that this fact should be
disclosed along with your estimate of the possible financial effects, which may be
aggregated for all of the litigation matters for which you are able to make such an
estimate. Such aggregated disclosure should mitigate your concern that providing these
estimates could seriously prejudice your position in these matters. Alternatively, and if
true, you could include a statement that the possible financial effects beyond the level of
current reserves established would not have a material impact on your statement of
financial condition, operations and cash flows. Please provide us with your prop osed
disclosure.

6. We note your disclosure that you have not provided disclosure about in cases where
disclosure could prejudice the conduct of the matters.  Disclose the nature of the general
nature of the dispute, for each of these cases, as contemplated by paragraph 92 of IAS 37.
Refer also to Example 3 in IE of IAS 37.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are

Tushar Morzaria
Barclays PLC
Barclays Bank PLC
September 24, 2014
Page 3

 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 provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the
filing s;

 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 s; and

 the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the U nited
States.

You may contact Jim Dunn  at (202) 551 -3724 or me at (202) 551 -3512  if you have
questions.

Sincerely,

  /s/ Stephanie J. Ciboroski

 Stephanie J. Ciboroski
Senior Assistant Chief Accountant