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    Chris Lucas

Group Finance Director

    1 Churchill Place

London

E14 5HP

    Tel +44 (0)20 7116 1200 (Direct)

Fax +44 (0)20 7116 7386

chris.lucas@barclays.com

Sharon Blume

Reviewing Accountant

Securities and Exchange Commission

Washington D.C. 20549

USA

31 October 2008

Dear Ms Blume

Barclays PLC and Barclays Bank PLC

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

File No. 0-1370, 1-10257

This letter responds to the comment letter (the “Comment Letter”) from the Staff of the Securities
and Exchange Commission, dated 18 September 2008, concerning the Annual Report on Form 20-F for the
fiscal year ended 31 December 2007 (the “Form 20-F”) of Barclays PLC and Barclays Bank PLC
(collectively, “Barclays”).

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, in light of the Staff’s views, Barclays has proposed providing
disclosures in our Annual Report on Form 20-F for 2008 that may differ from or supplement the
corresponding disclosure in the Form 20-F. Barclays continues to believe its prior filings are in
compliance with applicable disclosure rules and regulations promulgated by International Financial
Reporting Standards and the Commission. Accordingly, any changes implemented in future filings
should not be taken as an admission that prior disclosures were deficient or inaccurate.

Where we have provided indicative disclosures for the 2008 Annual Report, please note that these
may be subject to additional improvement and other changes where new transactions occur, or
circumstances or best practices change before the 2008 Annual Report is filed. However, we will
ensure that the disclosures actually filed address the comments made by the Commission.

 Barclays PLC. Registered in London, England. Registered No. 48839. Registered Office: 1 Churchill Place, London E14 5HP.

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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.

Our responses to your comments, along with our proposed indicative disclosures for 2008 where
appropriate, are set out in the appendices to this letter.

    Yours sincerely

    CG Lucas

    Group Finance Director

    Cc

    Dave Irving

(Securities and Exchange Commission)

    George H White

John O’Connor

(Sullivan & Cromwell LLP)

    Phil Rivett

(PricewaterhouseCoopers LLP)

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

Business Review

Critical accounting estimates

Fair value of financial instruments

Derivatives, page 49

    1.

    Please tell us whether the models you use to value derivative liabilities take into
consideration your own credit quality. If so, briefly describe the model inputs you use to
measure your own credit quality (i.e. CDS spreads, LIBOR + spread, etc.).

The models we used to value derivative liabilities did not take into consideration the effect of
changes in our own credit quality for the year ended 31 December 2007. Many derivative liabilities
are part of master netting arrangements and/or are collateralised. In common with many IFRS
reporters, own credit quality was not a significant consideration for market pricing at that time.

During 2008, as our credit spreads widened, own credit quality became a more significant
consideration for derivative market pricing and our models now incorporate our CDS spreads.

    2.

    Please quantify for us the portion of market value adjustments related to changes in your own
credit risk for each period presented.

Market value adjustments for own credit were made for issued notes held at fair value within
Barclays Capital. Adjustments for own credit were disclosed in the Form 20-F under ‘Barclays
Capital credit market positions, Own credit’ on page 53 and in note 4 on page 167. We disclosed
that the general widening of credit spreads affected the carrying value of issued notes held at
fair value and as a result revaluation gains of £658m (2006: £nil, 2005: £nil) were recognised in
trading income.

Financial Review

Off balance-sheet arrangements

SIV-Lites, page 52

    3.

    We note your disclosure here that the Group structured and helped to underwrite three
SIV-lite transactions and provided £0.55bn in liquidity facilities as partial support to the
£2.6bn of CP programmes on these transactions. We also note your disclosure on page 92 that
during the period the Group’s balance sheet expanded due to liquidity facilities that were
provided to three client SIV-lites which were restructured during the period. Please provide
us with the following additional information regarding these transactions:

    •

    clarify whether the SIV-lites are consolidated, or if they have ever been consolidated;

These SIV-lites were not consolidated at 31 December 2007 and were not consolidated in any previous
periods.

    •

    describe in further detail the structure of the SIV-lites and describe your obligations
under the facilities (e.g. liquidity provider, etc.).

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These SIV-lites are vehicles that invest primarily in high grade ABS and are managed by third party
investment managers in accordance with agreed investment guidelines. The vehicles were funded by CP
programmes and a range of rated term notes (typically Class A, Class B and capital notes) issued to
investors. Liquidity facilities were provided to cover CP funding short falls and these facilities
can be drawn as long as there has been no event of default. In addition, these vehicles enter into
vanilla hedging derivatives. CP, liquidity-lines and hedge providers rank senior to the mezzanine
Class A notes, which are senior to the mezzanine Class B notes and which are in turn senior to the capital
notes. The vehicles include default triggers to help protect the senior investors.

The Group structured and helped to underwrite these vehicles and on-going obligations included:

    •

    acting as one of the liquidity facility providers to the vehicles to cover any CP
shortfalls as long as there has been no event of default. Our facilities covered less than a
third of the CP programmes

    •

    retaining small percentages of some rated term notes and acting as vanilla derivative
hedge counterparty. These exposures were insignificant at 31 December 2007.

During 2007, our liquidity facilities on the three SIV-lites were impacted as follows:

    •

    one was partially drawn and no further drawings were possible because an event of default
prevented further drawings;

    •

    another was terminated undrawn because an event of default occurred before there were any
drawings and

    •

    the third was restructured (as detailed below).

    •

    describe how the SIV-lites were restructured during the
period. If the SIV-lites were restructured such that
your obligations have changed since inception, describe
the changes(s);

One of the vehicles was restructured in 2007. The vehicle was restructured to a static cash CDO and
we funded the acquisition of all the outstanding CP as it fell due and converted it to a senior
financing note collateralised by the underlying assets and fully credit protected by a third party
investment bank.

The Group’s position therefore changed from being one of the liquidity providers for £170m to a
holder of the £800m senior credit protected financing note.

    •

    explain how your balance sheet expanded due to liquidity facilities that were provided to
the SIV-lites which were restructured during the period; and

As explained above, our liquidity facility of £170m was restructured into a £800m senior credit
protected financing note in the second half of 2007. This increase in funding provided as part of
the restructuring meant that our balance sheet expanded.

    •

    to the extent the SIV-lites are not consolidated, please provide your analysis of the
circumstances and indicators in paragraph 10 of SIC 12 and the appendix to SIC 12 supporting
your conclusion that you do not control the SIV-lites.

We performed a SIC-12 consolidation analysis on inception of each SIV-lite based on the
arrangements in place and the assessed risk exposure. After considering the SIC-12.10 points listed
below for each of the SIV-lites, including the substance of our relationship with the SIV-lites, we
concluded that we did not control any of the SIV-lites and therefore they were not consolidated.

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Our SIC-12.10 analysis on inception considered the following:

    i)

    Under SIC-12.10 (a) the activities of the Special Purpose Entity (“SPE”) are primarily
conducted on behalf of the investors and in particular the rated term note investors who
receive leveraged returns on the notes they invest in.

    ii)

    Under SIC-12.10 (b) the investment decisions of the SPE are made by an independent third
party investment manager on behalf of the investors in accordance with the agreed investment
guidelines. The investment manager receives performance based fees from the SPE for these
services.

    iii)

    Under SIC-12.10 (c) and (d) our analysis at inception of the arrangements showed that, by
primarily providing part of the senior liquidity facilities to these vehicles, the Group did
not have the majority of the risks and rewards or the residual ownership risks of the SPE or
its assets.

It is our policy to revisit the initial SIC-12 consolidation analysis if the Group’s contractual
exposures with the entity change as explained in ‘Financial review, Off-balance sheet arrangements,
Special purpose entities, page 51’. The SIC-12 analysis was re-visited for the SIV-lite that was
restructured in the period. This analysis showed that our investment in the senior credit protected
financing note did not give the Group the majority of the risks and rewards or the residual
ownership risks of the SPE or its assets.

Barclays Capital credit market positions

Other credit market exposures, page 53

    4.

    Please tell us, and in future filings disclose, the percentage of performing US sub-prime
whole loan exposure as of the end of each reporting period. Provide us with your proposed
future disclosure.

In our 2008 interim results announcement (see Appendix A) we provided additional disclosures for
our ‘Other US Sub-Prime’ following increased market interest in this area.

The table in Appendix A shows that 88% (being (£2,805m/£3,177m)) of the total ‘other US sub-prime
whole loans’ at 31 December 2007 were performing.

In future, we propose to provide similar disclosures to the disclosures in the 2008 interim results
and we currently plan to specifically state the percentage of performing ‘other US sub-prime whole
loans’ exposure at the end of each reporting period. We continually review our disclosures and we
will therefore keep these proposed future disclosures under review and update them as necessary to
reflect, for example, future market practice, relevant significant future exposures and future
recommendations from stakeholders and regulators including the SEC.

    5.

    Please tell us, and in future filings describe, your US sub-prime “other direct and indirect
exposures”. In addition, include relevant key metrics such as average loan-to-value ratios,
agency rating information, delinquency data etc. that you use to analyze these exposures.
Provide us with your proposed future disclosure.

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In our 2008 interim results we provided additional detailed disclosure for our ‘other direct and
indirect exposures’ following increased market interest in this area. These disclosures are shown
in Appendix A and include the exposures at 31 December 2007.

US sub-prime ‘other direct and indirect exposures’ include:

    •

    asset-backed securities ,

    •

    residuals or warehouses of unsecuritised assets, and

    •

    derivatives and loans with underlying sub-prime collateral.

These exposures are analysed by taking into account a number of factors such as ratings, market
spreads and trade prices, levels of protection from subordination and the underlying sub-prime
exposures. The relevant factors for the largest remaining exposures at 30 June 2008 shown in the
table are as follows:

    •

    for derivatives (which are generally amongst the most senior obligations of the vehicles);
the ratings of notes issued by the vehicles that rank pari-passu as well as the vehicles’
ability to pay are considered.

    •

    for loans (which are generally amongst the most senior obligations of the vehicles); the
ability of the vehicles to pay these senior obligations is analysed by considering the trading
prices of the underlying assets and the level of subordination available from more junior
obligations.

In future, we propose to provide similar disclosures to the disclosures in the 2008 interim results
announcement and to include relevant key metrics (in a similar way to the bullet points above for
derivatives and loans) as appropriate at the time. As shown in our 2008 interim results, the ‘other
direct and indirect’ exposures have decreased significantly. If this trend continues then it may
not be relevant to include key metrics for these exposures in future. We continually review our
disclosures and we will therefore modify these proposed future disclosures as necessary to reflect,
for example, future market practice, relevant significant future exposures and future
recommendations from stakeholders and regulators including the SEC.

Financial Statements

Notes to the accounts

Note 49. Fair value of financial instruments, page 244

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    We note your disclosure in Note b that expected cash flows for each contract are determined
through modeling cash flows using appropriate financial-markets pricing models. Further, we
note the impact of changing the assumptions to your models (for those financial instruments
for which the fair values were measured using valuation techniques that are determined in full
for in part on assumptions that are not supported by observable market prices) to a range of
reasonably alternative assumptions would be to increase or decrease the fair value
significantly by up to £1.5bn or down to £1.2bn, respectively. In future filings, please
revise to disclose the following regarding your pricing models:

    •

    the specific pricing models you use to calculate the fair value of your financial
instruments;

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    •

    a discussion of the significant assumptions and inputs into each of these different models
for each class of financial instruments. For example, disclose the significant inputs into
these models that have the potential to most impact the value determined, and the assumptions
for those inputs for all periods presented;

    •

    the extent to which a particular valuation model is used to value certain of your asset and
liability classes; and

    •

    a discussion of how the impact of changing assumptions was calculated. For example,
disclose the reasonably likely range selected for each alternative assumption and the
corresponding percentages used in your sensitivity analysis.

Refer to paragraphs 27 and BC38 of IFRS 7. Provide us with your proposed future disclosure.

In designing the disclosures included in the 2007 Form 20-F to comply with IFRS 7, we gave
consideration to IFRS 7 B3 when determining how much detail we provided, how much emphasis we
placed on different aspects of the requirements and how we aggregated information to display the
overall picture without combining information with different characteristics. This