SecProbe.io

November 26 , 2014

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
Forms 20 -F for the Fiscal Year Ended December 31, 2013
Filed March 14, 2014
File Nos. 001 -09246 and 001 -10257

Dear Mr.  Morzaria :

We have reviewed your response dated October 22, 2014  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
requeste d 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 re viewing 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 the Fiscal Year Ended December 31, 2013

Note 29 – Contingent Liabilities and Commitments, page 303

1. We have considered your response to prior comment s 2 and 3 and note that you state that
“providing the disclosure required in respect of both provi sions and contingent liabilities
in a single note is the most appropriate approach, since a single or similar fact pattern or
set of circumstances may give rise to both provisions and contingent liabilities.”   We also
note your response to prior comment 4 which states, “In cases where there are multiple

Tushar Morzaria
Barclays PLC
Barclays Bank PLC
November 26 , 2014
Page 2

 proceedings in relation to a single fact pattern or set of circumstances, both a provision
and a contingent liability may be identified. For example, an obligation resulting in a
probable outflow may be iden tified in relation to a regulatory investigation but not a legal
proceeding, or vice v ersa, depending on th e facts.  In  addition, it will often be the case
that matters arising from separate but similar sets of circumstances will be classified
differently – where there are differences in the detailed fact pattern or legal analysis, for
example.” The determination of each provision and contingent liability  class , based  on
paragraph 87 of IAS 37, hinges on whether or not the nature of the items aggregated into
a class are “sufficiently similar for a single statement about them to fulfill
the  requirements  of paragraphs 85(a) and (b) and 86(a) and (b) of IAS 37.”   We note
that you have identified Other Conduct and Litigation as separate provision classes and
defined legal, competition and regulatory matters as a separate contingent liability
class.   Paragraph 85 and 86 require disclosure for each class of provision and contingent
liability, respectively. Please address each of the following:
 Expand your disclo sure to include a discussion of the nature of the obligation , the
expected timing of any resulting outflows of economic benefits and an indication of
the uncertainties about the amount or timing of those outflows as required by
paragraph 85 (a) and (b) of  IAS 37 for the Other Conduct provision class, as well as
your Litigation provision class.   Additionally, tell us where your current disclosures
by provision class provide information about the expected timing of any resulting
outflows of economic benefit s as required by paragraph 85(a) of IAS 37.
 Tell us where you have provided the disclosure required by paragraph 85 of IAS 37
for your Sundry provision class.

 Expand your disclosure to include a description of the nature of the contingent
liability and, where practicable, an estimate of its financial effect and an indication of
the uncertainties relating to the amount or timing of any outflow, as required by
paragraph 86 of IAS 37.

In cases where the underlying matter that impacted a provision class also impacted
another class of provision or contingent liability please consider cross referencing
information that is similar to each class of provision or contingent liability

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
in possession of all facts relating to a company’s disclosure, they are responsibl e for the accuracy
and adequacy of the disclosures they have made.

Tushar Morzaria
Barclays PLC
Barclays Bank PLC
November 26 , 2014
Page 2

 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 filings;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filings; and

 the company may not assert staff comments as a defense in any proceeding initiate d by
the Commission or any person under the federal securities laws of the United 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