SEC Comment Letter for BARCLAYS (BCS) — Sep 1, 2017
BARCLAYS PLC
Date: Sept. 1, 2017 · CIK: 0000312069 · Accession: 0000000000-17-031150
AI Filing Summary & Sentiment
Letter
Mail Stop 4720 September 1, 2017 Tushar Morzaria Group Finance Director Barclays PLC Barclays Bank PLC 1 Churchill Place London E14 5HP , England
Re: Barclays PLC Barclays Bank PLC Form 20-F for the Fiscal Year Ended December 31, 2016 Filed February 23, 2017 Form 6 -K Filed July 28, 2017 File No s. 001 -09246 and 001 -10257
Dear Mr. Morzaria :
We have reviewed your filings 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 business days by providing the requested information or adv ise 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, 2016
Item 8A - Consolidated Statements and Other Financial I nformation , page 219
Note 8 - Operating Expenses, page 235
1. We note your disclosure on page 194 regarding an additional charge of £395 million in Q416 relating to 2016 compensation awards reflecting a decision to more closely align income statement recognition with performance awards and your disclosure on page 56 regarding changes to your deferral arrangements. Please address the following:
Tell us all the key facts and circumstances related to your deferral arrangements before and after your changes ;
Tushar Morzaria Barclays PLC Barclays Bank PLC September 1, 2017 Page 2
Provide us t he basis for your accounting citing specific supporting accounting guidance for your arrangements before and after your changes; and
Identify the key factors tha t resulted in changing the timing of the recognition of the compensation cost.
Form 6 -K Filed July 28, 2017
Credit Risk, page 28
Analysis of Forbearance Programmes, page 30
2. We note your disclosure that Barclays International forbearance balances increased £355 million to £2.4 billion, as consistent forbearance methodologies were introduced across CIB. Please respond to the following:
Describe the nature of the changes to the forbearance methodologies.
Tell us whether the Group as a whole is now following consistent forbearance methodologies. If not, tell us the subsidiaries/divisions where a consistent methodology is not being followed and provide an estimate of the significance of the subsidiaries/division s that are using different methodologies.
Tell us whether there were any changes to the underlying allowance methodologies as a result in the change of forbearance methodologies.
We remind you that the company and its management are responsible for the a ccuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
You may contact Michael Volley, Staff Accountant, at 202-551-3437 or me at 202-551- 3512 with any questions.
Sincerely,
/s/ Stephanie L. Sullivan
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Mail Stop 4720 September 1, 2017 Tushar Morzaria Group Finance Director Barclays PLC Barclays Bank PLC 1 Churchill Place London E14 5HP , England Re: Barclays PLC Barclays Bank PLC Form 20-F for the Fiscal Year Ended December 31, 2016 Filed February 23, 2017 Form 6 -K Filed July 28, 2017 File No s. 001 -09246 and 001 -10257 Dear Mr. Morzaria : We have reviewed your filings 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 business days by providing the requested information or adv ise 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, 2016 Item 8A - Consolidated Statements and Other Financial I nformation , page 219 Note 8 - Operating Expenses, page 235 1. We note your disclosure on page 194 regarding an additional charge of £395 million in Q416 relating to 2016 compensation awards reflecting a decision to more closely align income statement recognition with performance awards and your disclosure on page 56 regarding changes to your deferral arrangements. Please address the following: Tell us all the key facts and circumstances related to your deferral arrangements before and after your changes ; Tushar Morzaria Barclays PLC Barclays Bank PLC September 1, 2017 Page 2 Provide us t he basis for your accounting citing specific supporting accounting guidance for your arrangements before and after your changes; and Identify the key factors tha t resulted in changing the timing of the recognition of the compensation cost. Form 6 -K Filed July 28, 2017 Credit Risk, page 28 Analysis of Forbearance Programmes, page 30 2. We note your disclosure that Barclays International forbearance balances increased £355 million to £2.4 billion, as consistent forbearance methodologies were introduced across CIB. Please respond to the following: Describe the nature of the changes to the forbearance methodologies. Tell us whether the Group as a whole is now following consistent forbearance methodologies. If not, tell us the subsidiaries/divisions where a consistent methodology is not being followed and provide an estimate of the significance of the subsidiaries/division s that are using different methodologies. Tell us whether there were any changes to the underlying allowance methodologies as a result in the change of forbearance methodologies. We remind you that the company and its management are responsible for the a ccuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Michael Volley, Staff Accountant, at 202-551-3437 or me at 202-551- 3512 with any questions. Sincerely, /s/ Stephanie L. Sullivan Stephanie L. Sullivan Senior Technical and Policy Advisor Office of Financial Services