SecProbe.io

Mail Stop 4720

September 30, 2016

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, 2015
Filed March 1, 2016
Form  6-K Filed August 1, 2016
File Nos. 001 -09246 and 001-10257

Dear Mr. Mor zaria:

We have limited our review  of your filing  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 by 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, 2015

General

1. You stated in your letter to us dated October 31, 2013 that you had continuing business
activities related to Sudan and Syria, c ountries which are designated by the U.S.
Department of State as state sponsors of terrorism, and are subject to U.S. economic
sanctions and export controls.   Your Form 20 -F does not include disclosure about
contacts with those countries beyond a reference  on page 330 to legacy guarantees
concerning Syria.   Please provide us with information regarding your contacts with
Sudan and Syria since the referenced letter.   You should describe any services or funds

Tushar  Morzaria
Barclays  PLC
Barclays Bank  PLC
September 30, 2016
Page 2

 you have provided into Sudan and Syria, directly or  indirectly, and any agreements,
arrangements or other contacts you have had with the governments of Sudan and Syria or
entities they control.

2. Please discuss the materiality of any contacts with Sudan and Syria you describe in
response to the comment abov e, and whether the contacts constitute a material
investment risk for your security holders.   You should address materiality in quantitative
terms, including the approximate dollar amounts of any revenues, assets and liabilities
associated with Sudan and S yria for the last three fiscal years and the subsequent interim
period.   Also, address materiality in terms of qualitative factors that a reasonable investor
would deem important in making an investment decision, including the potential impact
of corporate  activities upon a company’s reputation and share value.   As you know,
various state and municipal governments, universities and other investors have proposed
or adopted divestment or similar initiatives regarding investment in companies that do
business w ith U.S. -designated state sponsors of terrorism.   You should address the
potential impact of the investor sentiment evidenced by such actions directed toward
companies that have operations  associated with Sudan and Syria.

Financial Statements, page 208

Note 19 – Offsetting Financial A ssets and Financial Liabilities, page 251

3. We note your disclosure in footnote (e) to the table that the decrease in the amounts offset
is due to the conversion of Barclays daily collateralized interest rate swaps with LCH
Clearnet Ltd , for which the colla teral was offset against the derivative exposure, into
daily settled interest rate swaps in December 2015.  Please address the following:

 Tell us in more detail the specific terms that changed as a result of the conversion that
resulted in the interest ra te swaps now being considered legally settled on a daily
basis.   As part of your response, please tell us whether the timing or amount of cash
flows related to the interest rate swaps has changed.

 Tell us whether any of the interest rate swaps that were a ffected by the conversion
were included in hedge accounting relationships at the time of conversion.   If so,
please tell us your consideration of the guidance in paragraphs 91 and 101 of IAS 39.

Note 27 - Provisions, page  259

4. We note your disclosur e that as of December 31, 2015  you have recognized cumulative
provisi ons of £7.4 billion for the cost of Payment Protection Insurance (PPI) redress and
associated processi ng costs with utilization of £5.3 billion, leaving a residual provision of
£2.1 billion at December 31, 2015.  We note that you have recorded substantial

Tushar  Morzaria
Barclays  PLC
Barclays Bank  PLC
September 30, 2016
Page 3

 provisions for PPI redress for each of the past five years, including £1.0 billion in 2011,
£1.3 billion in 2012,  £1.35 billion in 2013,  £1.3 billion in 2014,  £2.2 bil lion in 2015
(which represented  30% of  the cumulative provisions reco rded) , and an additional  £0.4
billion during the first six months of 2016.   Addit ionally, we note  that these additional
provisions are recognized throughout each of the years.  For example, in the case of the
2014 provis ion, £900 million was recognized during the first half of the year, £170
million in the third quarter and  £200 million during the fourth quarter.  In the case of the
2015 provisions, £150 million was recognized during the first quarter, £600 m illion
during the second quarter and  £1.45 billion during the fourth quarter.   Given that you
have not sold these types of policies for more than  five years, please help us understand
why such significant and st eady additional provisions are recorded each year.  In doing
so, please address the following :

 Provide the total amount of policies sold that are covered under the PPI redress
program.   To the extent that the claim redress is based on total premiums paid by the
customer, the total amount sold should  be based on total premiums paid for these
policies.

 Provide  the total amount of policies that have been resolved as of each balance sheet
date rela tive to the total amount of policies sold  and covered under th e PPI redress
program .

 We note from your response letter dated March 3, 2013 where we r equested you
provide a roll forward of the level of outstanding complaints received, starting with
the amount outstanding at the beginning of  the year, complaints resolved, ne w
complaints received , and the number of complaints outstanding at the end of the
period that you did not provide that information  as it is not the basis on which the
provision is calculated.  However, in light of the substantial provisions reco gnized
each period under yo ur methodology, plea se tell us whether you believe  including
this disclosure would provide investors with additional context as to how timely you
are processing claims, volumes of claims , and levels of outstanding claims.

 We note the discussion of the role of the Board Audit Committee  with respect to the
PPI provisioning on page 11.  Please tell us if the Committee has requested an
analysis of whether alternative methodologies could be utilized to determine  the PPI
provision levels in light of the substantial change in estimates recorded for the past
five years for policies  which you have not sold in more than  five years.

 We note your disclosure on page 1 1 that the Committee evaluates management ’s
judgments to ensure the provisions are within an acceptable range.   Please  describe
the range analysis performed as part of this action .  As part of your response, please
address the substantial quarterly changes in the provision levels, which entirely relate

Tushar  Morzaria
Barclays  PLC
Barclays Bank  PLC
September 30, 2016
Page 4

 to policies sold more than  five years ago , and thus represent repeated substan tial
revisions to  the range estimates each period.

Note 35 – Pensions and Post -Retirement Benefits, page 281

5. We note your disclosure  on page 282 that past service costs include  a £429  million  gain
on the valuation of a component of the defined retirement liability.  On page  62 of your
Half Year report, you describe the gain as an alignment to statutory provisions.  Please
tell us in more detail what  this valuation gain represents, how it was calcula ted, and how
you determined it was appropriately recorded during 2015, as opposed to an earlier
period.

Management of Credit Ris k, page 354

Emergence and Outcome Periods, page 362

6. We note your tabular disclosure of your minimum emerg ence periods at a product level
per your updated retail impairment policy.  Please respond to the following:

 Tell us whether the minimum emergence periods are typically the periods used for
each product, or whether the emergence periods are typically higher than the ones
disclosed.

 Your disclosure states where shortfalls are identified at a business or portfolio level,
the prescribed minimum emergence periods are increased  to reflect your most up -to-
date experience of customer behavior.  Please explain what you mean by “shortfalls ”
being identified, and how this differs from your  at least annual  review to validate the
minimum emergence period.

 Your disclosure  states that policy enhancement now requires businesses to capture
lifetime defaults allowing consideration to cu re rates and future events, subject to a
minimum floor of 80%.  Please explain what you mean by “minimum floor ”, describe
exactly which component is subject to the minimum flo or, and why you believe it is
appropriate  to establish minimum floors.

 On page 364, you state that outcome periods are also derived at a business/portfolio
level, subject to the minimum period in the table above.  Please tell us in more detail
how the outcome periods are derived, expla in whether the minimum period for the
outcome period is in addition to the minimum period for the emergence period, and
explain how this outcome period is ultimately  used in your allowance methodology.

Tushar  Morzaria
Barclays  PLC
Barclays Bank  PLC
September 30, 2016
Page 5

 Form 6 -K Filed  August 1, 2016

Exhibit 99.1

Group Performance Review, page 6

Non-Core Performance, page 7

7. We note your dis closure on page 7 that during the second quarter of  2016, the terms of
the Education, Social Housing, and Local Authority  (ESHLA ) portfolio loans with lender
option borrower option (LOBO) features were restructured, and as a result, a £182
million charge was recognized.   Your disclosure also states that the restructuring resulted
in the de -recog nition of the £8 billion of exi sting Level 3 fair value loan a ssets with the
new restructured assets now measured on an amortized cost ba sis.  Please respond to the
following:

 Clarify whether you have any remaining ESHLA loans that are not included in the
amortized cost category.  If so, please explain the factors driving the different
accounting treatment.

 Provide an analysis showing the  rollforward of the ESHLA loans from December 31,
2015 to June 30, 2016.  For example, it appears you had £16 billion of ESHLA loan
balances as of December 31, 2015, but you only derecognized £8 billion of  Level 3
fair value loans as of June 30, 2016.

 Provide us with your analysis supporting how the ESHLA loans met the de-
recognition criteria in IAS 39.   Additionally, provide your accounting  analysis
supporting how the restructured ESHLA loans qualified as new loans which could
then be classified at amortized cost.

Barclays UK, page 8

8. We note your disclosure  that credit impairment charges increased 10% to £366 million
due to the refinement of impairment modeling in Barclaycard Consumer UK.  Please
describe to us in more detail the modeling cha nges made and the drivers for the change.
In this regard, we also note your disclosure on page 137 of your Form 20 -F that you made
policy and model cha nges in Barclaycard during 2015, including to increase coverage on
forbearance programs and accounts in recoveries.   As part of your response, please tell
us whether the total management adjustments to the impairment stock for  UK Cards
decreased from the £147 mil lion (representing 17% of the total impairment stock)
recognized at December 31, 2015, given the modeling changes.

Tushar  Morzaria
Barclays  PLC
Barclays Bank  PLC
September 30, 2016
Page 6

 Note 11 – Fair Value of Assets and Liabilities, page 70

Comparison of Carrying Amounts and Fair Values for Assets and Liabilities Not Held at Fair
Value, page 78

9. We note your presentation of assets and liabilities included in disposal groups classified
as held for sale, and the related footnote stating that the amounts only reflect assets and
liabilities where the carrying value is lower than the fair value.  As a result, the carrying
amount and fair value disclosed are the same amount as of June 30, 2016, and represent
only a subset of the total  assets and liabilities  that are included in disposal groups
classified as held for sale.  Given the stated purpose of this disclosure, tell us why you
only included the assets and liabilities  in disposal groups where the carrying value  is
lower than the fair value .

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 responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statemen t from the company
acknowledging that:

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

 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; 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 United States.

You may contact Michael Henderson, Staff Accountant  at (202) 551 -3364 or me at (202)
551-3512 with any questions.

Sincerely,

 /s/ Stephanie L. Sullivan

Stephanie L. Sullivan
Senior Assistant Chief Accountant
Office of Financial Services