SecProbe.io

September 2 , 2015

Mail Stop 4546

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, 2014
Filed March 3, 2015
Form 6 -K Filed July 29, 2015
File No s. 001-09246 and 001 -10257

Dear Mr. Morzaria :

We have limited our review  of your filing s to the financial statements and related
disclosures 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 these comments  within ten busine ss days b y providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments , we may have  additional comments.

Form 20 -F for the Fiscal Year Ended December 31, 2014

Note 18 – Fair Value of Financial Instruments, page 242

Significant Unobservable Inputs, page 252

1. We note that you disclose your ESHLA loans under non -asset backed securities and
“loan spread” is the significant unobservable input used in this  valuation technique  (i.e.
discounted cash flow) .  We also note that the range of loans spreads is 961 basis points
and 1,12 4 basis points in 2014 and 2013, respectively.  Further, we note from your
disclosure on page 243 that your valuation methodology changed in 2014 when you

Tushar Morzaria
Barclays PLC
Barclays Bank PLC
September 2, 2015
Page 2

 migrated from a credit -adjusted LIBOR rate assumption to an assumption that uses loan
spreads adjuste d for funding rates, levels of comparable assets, etc.  Please respond to the
following:
 Tell us if the change in your valuation methodology impacts the comparability of loan
spread data year -over-year.
 Tell us and revise future filings to disclose the weighted average of your significant
unobservable inputs including the loan spreads on ESHLA loans .  Alternatively,
given the wide range of unobservable inputs, provide a more expansive qualitative
discussion to discuss where within the range the vast majority of the valuations fall
within.
 Tell us and revise future filings to disclose the impact of adjustments you make to the
ESHLA loan spreads (i.e. adjustments for funding rates, levels of comparable assets,
etc.) as well as the process for determinin g the adjustments.
 Given the significant range in the sens itivity of favorable and unfavo rable changes in
unobservable inputs for the ESHLA loan spreads, please briefly expand your
discussion to disclose the process used for determining the base loan sprea ds used in
your ESHLA loan valuations (i.e. loan spreads prior to adjustments).

Form 6 -K filed July 29, 2015

Exhibit 99.1

Financial  Statement Notes  (Unaudited)

Note 9 – Fair Value of Financial Instruments, page 60

Level 3 Movement Analysis, page 6 2

2. We note here and throughout your fair value disclosures that you compare level 3
movements for the annual  period ended December 31, 2014 to level 3 movements for the
six-month  period ended June 30, 2015.  Therefore, your disclosures are comparing annual
to semi -annual information (i.e. purchases, sales, gains/losses, etc.).  Please revise future
half-year filings to disclose comparative information on a half -year basis where
applicable.

Significant Unobservable Inputs, page 66

3. We note from your disc losure that the significant unobservable inputs for assets and
liabilities are consistent with the information in Note 18 in your 2014 Annual Report.
However, we note a £14,427 million or 30% reduction in the amounts of Level 3 assets
and a £ 12,450 or 64 % decrease in Level 3 liabilities. We also note that you recognized
significant fair value losses on the ESHLA portfolio (£175 million for the half year 2015)
which are classified as Level 3.  Thus, please revise future half -year filings to present
quantita tive information about significant unobservable inputs used in your level 3 fair

Tushar Morzaria
Barclays PLC
Barclays Bank PLC
September 2, 2015
Page 3

 values, or explain to us how and why the inputs have not changed since the prior period
end.  As part of your response, please provide us with an example of your planned
discl osures for June 30, 2015.  Refer to IAS 34.16A(j) and IFRS 13.93(d).

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing s to be certain that the filing s include 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 responsible for the accuracy
and adequacy of t he 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 t he federal securities laws of the United States.

You may contact Jim Dunn  at (202)  551-3724 or me at (202) 551 -3512  with any
questions.

Sincerely,

 /s/ Stephanie Ciboroski

 Stephanie Ciboroski
Senior Assistant Chief Accountant
Office of Financial Services II