SecProbe.io

CORRESP
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    Barclays PLC

One Churchill Place

London E14 5HP

Michael R. Clampitt

Senior Attorney

Securities and Exchange Commission

Washington D.C. 20549

USA

31 October 2008

By Hand and EDGAR, “CORRESP” Designation

Dear Mr Clampitt

Barclays PLC and Barclays Bank PLC

Form 20-F for the Fiscal Year Ended December 31, 2007

File No. 0-09246, 1-10257

I am writing in response to your letter, dated 3 October 2008, concerning the Annual Report of
Barclays PLC and Barclays Bank PLC (collectively, “Barclays”) on Form 20-F for the fiscal year
ended 31 December 2007 (the “Barclays Form 20-F”).

To facilitate the Staff’s review, Barclays has included in its responses the captions and numbered
comments in bold text and has provided Barclays’ responses immediately following each numbered
comment.

In some of the responses, Barclays has proposed to make changes to disclosures in future filings,
beginning with our Annual Report on Form 20-F for 2008.

We acknowledge that:

    •

    Barclays 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

    •

    Barclays 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.

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Our responses to your comments, along with our proposed additional disclosures for 2008, are set
out in the appendix to this letter.

Yours sincerely

/s/
CG Lucas

CG Lucas

Group Finance Director

    Cc

    Sharon Blume

Dave Irving

Matt McNair

(Securities and Exchange Commission)

    George H. White

John O’Connor

(Sullivan & Cromwell LLP)

    Phil Rivett

(PriceWaterhouseCoopers LLP)

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Form 20-F Comments and Responses

General

    1.

    Where the answer to an item is in the negative, you must respond to the item by making a
statement to that effect. See General Instruction C(a) to the Form 20-F. Please revise
future filings accordingly.

We will revise our future filings to expand the Form 20-F cross-reference table in the initial
pages of the Barclays Form 20-F by providing a more detailed description of each item of Form 20-F,
along with a cross-reference to where each such item is disclosed or a statement that such item is
not applicable to Barclays.

Corporate Governance, page 143

    2.

    Please provide the information required by Item 15(b)(4) of the Form 20-F.

We will revise our future filings to include this information.

Note 42, Related party transactions and Directors’ remuneration, page 208

    3.A.

    You do not fully comply with Item 7.B.2 of Form 20-F because you do not identify the key
management members to whom the preferential loans were made (i.e., the £1,250 loan made at 5%
and the £665 interest-free loan). Please confirm that you will disclose this information in
future filings.

We understand that the comment relates to the requirement under Item 7.B.2 of Form 20-F for foreign
banks to disclose certain information regarding loans made to key management personnel that are not
made in the ordinary course of business, including (i) the member of key management who received
the loans and (ii) the nature of the loan recipient’s relationship to the foreign bank.

We note that, Note 42 to the Barclays Form 20-F, discloses that (i) a loan of £1,540 was
outstanding to a non-Director member of key management at a staff preferential rate of interest
(5%) and (ii) a loan of £665 had been provided to a non-Director member of key management on an
interest free basis. The loan of £1,540 at a staff preferential rate of interest reflects the
amortized principal amount of a home mortgage loan. At the time the home mortgage loan was
granted, we had in place a corporate policy of providing home mortgage loans at preferential rates
of interest to all staff members. This policy has since been discontinued. These home mortgage
loans were made on substantially the same terms, including interest rates and collateral, to all
staff members who applied for such loans. The loan of £665 provided on an interest free basis
relates to the granting of loans to purchase commuter rail tickets. The commuter rail ticket loans
are still provided to all Barclays staff members upon request.

Given the amounts and purposes of the loans as described in the preceding paragraph, we believe
that the inclusion of certain additional information regarding the loans, such as the names of the
members of key management who received the loans and the nature of their relationship to Barclays,
in the Barclays Form 20-F would not constitute material information for investors. We note that,
if the relevant requirements had been provided for under Item 404 of Regulation S-K, the inclusion
of such information would not be required to be included because the value of any single loan does
not exceed the de minimis threshold of $120,000. We acknowledge that Item 7.B.2 of Form 20-F does
not contain an analogous de minimis threshold for loans which would not be deemed to constitute
material loan disclosure under Item 404 of Regulation S-K. However given the non-material nature
of the additional information required to be provided under Item 7.B.2. in this circumstance, we do
not believe it necessary to amend our disclosure in the Barclays Form 20-F in response to this
comment.

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    3.B.

    In addition, you do not state the largest amount of loans to related parties outstanding
during the year. In the future, please either provide all of the information required by Item
7.B.2. or make the representations contemplated in Instruction 2 to Item 7.B.

We will revise our future filings to include this information.

Exhibits

Exhibit 12

    4.

    Please file the certifications required under Exchange Act Rules 13a-14(a) and 15d-14(a) as
separate exhibits.

We will file the certifications required under Exchange Act Rules 13a-14(a) and 15d-14(a)
separately for each of the Group Chief Executive and the Group Finance Director, and separately for
each of Barclays PLC and Barclays Bank PLC in future filings.

    5.

    Certifications required under Exchange Act Rules 13a-14(a) and 15d-14(a) must be in the exact
form set forth in Form 20-F. Your certifications contain inappropriate modifications. Please
confirm that future certifications will be in the exact form set forth in the Form 20-F.
Refer to Instructions as to Exhibits of the Form 20-F.

We confirm that future certifications will be in the exact form set forth in the Form 20-F with a
separate certification for each of Barclays PLC and Barclays Bank PLC, rather than a joint
certification for the two companies.

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