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Correspondence

 BARCLAYS HAS CLAIMED CONFIDENTIAL

TREATMENT OF PORTIONS OF THIS LETTER

 IN ACCORDANCE WITH 17 C.F.R. 200.83

 Barclays PLC

 One Churchill
Place

 London

 E14 5HP

 Tel: 020 7116 1000

 www.barclays.com

 16 March 2011

Michael Seaman

 Special Counsel

Securities and Exchange Commission

 Washington
D.C. 20549

 USA

 VIA EDGAR

 Dear Mr Seaman,

 Barclays
PLC and Barclays Bank PLC

 Form 20-F for the Fiscal Year Ended December 31, 2009

File No. 0-10257, 1-09246

 This letter
responds to the comment letter (the ‘Comment Letter’) from the Staff of the Securities and Exchange Commission (the ‘Commission’), dated 17 February 2011, concerning the Annual Report on Form 20-F for the fiscal year
ended 31 December 2009 (the ‘2009 Form 20-F’) of Barclays PLC and Barclays Bank PLC (collectively, ‘Barclays’).

Our responses to your comments are set out as an appendix to this letter. To facilitate the Staff’s review, Barclays has included in its responses
the captions and comments in bold text and has provided Barclays responses immediately following each numbered comment.

 In some of the
responses, and in light of the Staff’s comments, Barclays may provide further disclosures in our Annual Report on Form 20-F for 2010 (‘2010 Form 20-F’) that may differ from or supplement the corresponding disclosure in the 2009 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.

 In addition, in accordance with what we
understand to be the Staff’s policy with respect to requests for confidential treatment of responses to the Staff’s comment letters, we are submitting two separate letters to the Staff’s comments. Concurrent with the submission to you
of this letter, confidential treatment of portions of this letter is being requested under the Commission’s rules in accordance with 17 C.F.R. § 200.83. Accordingly, a separate version of this response letter

 Barclays Bank PLC. Authorised
and regulated by the Financial Services Authority.

 Barclays PLC. Registered in England. Registered No: 1026167. Registered Office: 1 Churchill
Place, London E14 5HP.

containing confidential information of Barclays is being filed by hand and not via EDGAR. This letter being submitted via EDGAR does not contain confidential information of Barclays and therefore
is not submitted on a confidential basis.

 We trust that the information provided in this letter responds adequately to the questions you have
raised. We would be pleased to provide any further information to the extent you would find this helpful.

 Yours sincerely,

/s/ C.G. Lucas

 C.G. Lucas

Group Finance Director

cc

Wayne Carnall

Stephanie Hunsaker

David Irving

Sharon Blume

Eric Envall

 (Securities and Exchange Commission)

George H. White

John O’Connor

 (Sullivan & Cromwell LLP)

Andrew Ratcliffe

 (PricewaterhouseCoopers LLP, Barclays Audit Engagement Team)

Rob Enticott

 (PricewaterhouseCoopers LLP, SEC Services)

 Barclays Bank PLC. Authorised
and regulated by the Financial Services Authority.

 Barclays PLC. Registered in England. Registered No: 1026167. Registered Office: 1 Churchill
Place, London E14 5HP.

 BARCLAYS HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS

OF THIS LETTER IN ACCORDANCE WITH 17 C.F.R. 200.83

 Mr M Seaman

 Securities and Exchange Commission

Appendix

 Form 20-F for the Fiscal Year
Ended December 31, 2009

 General

 Response to the Comment Letter from the Staff of the Commission dated 17 February 2011

1
Tell us whether you have open-ended repurchase agreements and reverse repurchase agreements as of May 31, 2010, June 30, 2010 and July 31, 2010,
and the corresponding periods of the previous year and quantify the amount outstanding as of each of the dates. As part of your response, please tell us whether these types of agreements are concentrated at certain Barclays’ subsidiaries, and
if so, which ones. For example, please confirm whether or not any of these agreements exist at Barclays Bank PLC or whether they are exclusively at the U.S. broker-dealer (BCI), or in other subsidiaries.

The following table provides the amount of open-ended reverse repurchase agreements and open-ended repurchase agreements that existed as of the dates
requested.

 Open-ended Reverse Repos

2010

2009

May

June

July

May

June

July

$m

$m

$m

$m

$m

$m

 Consolidated

49,039

19,868

55,859

35,899

11,627

29,127

 Comprised of:

 BB PLC

38,755

16,887

46,622

24,357

7,598

19,537

 BCI

10,284

2,981

9,237

11,542

4,029

9,590

 Open-ended Repos

2010

2009

May

June

July

May

June

July

$m

$m

$m

$m

$m

$m

 Consolidated

42,320

22,833

47,188

39,980

29,120

46,190

 Comprised of:

 BB PLC

34,103

20,007

41,572

34,254

24,346

40,356

 BCI

8,217

2,826

5,616

5,726

4,774

5,834

 As is illustrated in the above table,
this activity is largely concentrated in BB PLC with some activity occurring in BCI.

 BARCLAYS HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS

OF THIS LETTER IN ACCORDANCE WITH 17 C.F.R. 200.83

 Mr M Seaman

 Securities and Exchange Commission

Appendix

2
Tell us whether you convert open-ended repurchase agreements and reverse repurchase agreements to overnight or date-certain agreements and describe the business
purposes behind the changes. As part of your response, please tell us the amounts converted at or near the May, June and July 2010 and 2009 month ends, and whether the conversions were done at the request of the counterparty.

 Open-ended repurchase agreements and reverse repurchase agreements are arm’s length transactions that are re-priced to
market interest rates and margined on a daily basis. They are consistent in form to a series of overnight trades where there is an upfront agreement to roll the trades until one of the parties exercises its right to terminate. The benefit of
open-ended contracts is that the operational burden of settling interest on a daily basis is eliminated. However, this means that with open-ended repurchase and reverse repurchase agreements there is no mechanism, other than by terminating the
contracts, to facilitate the settlement of interest, principal or collateral balances. Further, the collateral held or placed is based on the principal balance of the financing arrangement and excludes the value of accrued interest. Therefore the
unsettled interest balance represents exposure to/from the respective counterparty that must be periodically settled.

 In order to facilitate
settlement and manage cash flows (e.g., payment of interest), in the normal course of business, these transactions are periodically terminated by exercising our right to determine the settlement date (i.e., convert to a date-certain contract.)
Establishing the term end date is generally done at our request, however counterparts will periodically initiate the request. The actual decision to convert the transaction to a date-certain contract can, and does, occur on any date during the
month. However, our businesses will typically view the optimal dates for such conversion as being each quarter-end. This balance sheet netting, achieved through converting open-ended agreements to date-certain, assists them in meeting their
respective balance sheet limits as determined by the Barclays Capital Balance Sheet Steering Committee. Therefore the majority of the conversions of the open-ended trades to establish a date-certain settlement date occur at quarter-end.

As discussed in our response of 31 January 2011 to your 22 December 2010 comment letter, business balance sheet limits and usage are set and
monitored by the Barclays Capital Balance Sheet Steering Committee. Individual businesses are required to meet defined balance sheet limits and are not permitted to exceed them without prior approval by nominated Steering Committee members.

 It should be noted that open-ended intra-group agreements between BCI and BB PLC are also converted to establish a date-certain settlement
date, even though businesses do not have balance sheet limits at the BCI stand alone entity level. The purpose of such conversions and terminations is to facilitate settlement and manage cash flows as outlined above.

The following table provides the amount of repurchase and reverse repurchase agreements converted to establish a date-certain settlement date as of the
last business day of the applicable month.

 BARCLAYS HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS

OF THIS LETTER IN ACCORDANCE WITH 17 C.F.R. 200.83

 Mr M Seaman

 Securities and Exchange Commission

Appendix

 Reverse Repos

2010

2009

May
$m

June
$m

July
$m

May
$m

June
$m

July
$m

 Consolidated

88

14,234

192

157

5,649

236

 Comprised of:

 BB PLC

73

10,518

173

46

3,272

236

 BCI

15

3,716

19

111

2,377

—

Repos

2010

2009

May
$m

June
$m

July
$m

May
$m

June
$m

July
$m

 Consolidated

153

10,713

723

356

6,511

190

 Comprised of:

 BB PLC

147

7,401

712

356

3,890

190

 BCI

6

3,312

11

—

2,621

—

 The following table provides the IFRS
balance sheet netting applied to the above conversion to a date-certain arrangement:

 Balance Sheet Reduction

2010

2009

May
$m

June
$m

July
$m

May
$m

June
$m

July
$m

 Consolidated

19

11,882

84

117

6,892

18

 Comprised of:

 BB PLC

13

8,616

76

6

4,269

18

 BCI

6

3,266

8

111

2,623

—

 By way of context, the following
table provides a summary of the Group’s total assets:

2010

2009

May
$bn

June
$bn

July
$bn

May
$bn

June
$bn

July
$bn

 Barclays Total Assets

2,615

2,372

2,603

2,873

2,541

2,720

 BARCLAYS HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS

OF THIS LETTER IN ACCORDANCE WITH 17 C.F.R. 200.83

 Mr M Seaman

 Securities and Exchange Commission

Appendix

 Balance sheet netting is only appropriate where the date-certain repurchase and reverse repurchase
contracts have an offsetting date-certain repurchase or reverse repurchase contract with the same counterparty that satisfies the IFRS criteria outlined in Q5 below. Netting may be achieved when an existing open-ended contract is converted to
date-certain in order to offset an existing date-certain contract (e.g., an open-ended reverse repurchase agreement is converted to date-certain to offset an existing date-certain repurchase agreement).

For certain counterparties all of their open-ended repurchase and reverse repurchase agreements will be converted and terminated to most efficiently
facilitate the settlement of the entire portfolio of transactions. Netting will only be applied to those transactions within the portfolio that satisfy the necessary netting criteria. Accordingly the amount of balance sheet netting may be lower than
the amount of transactions converted from open-ended to date-certain on these dates.

3
To the extent you convert open-ended repurchase agreements and reverse repurchase agreements to overnight or date-certain agreements, describe the typical time
period of the date-certain agreement, whether any fees are paid to convert the agreements, and how the agreements regarding the changes are documented, such as whether the agreements specified upfront that at a date in the future the repurchase
agreement and reverse repurchase agreement would convert to an overnight or date-certain maturity, or whether the changes are determined at a later date and documented separately at that date.

Open-ended transactions that are converted to a date-certain settlement date are typically done so on the last business day of the month into overnight
transactions with a maturity date generally the 1st business day of the following month. In the original open-ended transaction documents there is no reference to the date of any settlement and no fees are paid in order to facilitate the settlement
of the open-ended agreement. However, they do legally provide that either counterparty may settle the transaction on 1 days notice, via conversion to a date-certain agreement. Such a right must exist in order to facilitate ultimate settlement.

 When we give such notice to settle (i.e., when we convert to a date-certain agreement), we generally also enter into a contract which
provides for a new open-ended agreement subsequent to the settlement of the date-certain agreement. The combined arrangements provide Barclays with the legal right and ability to settle, what were open-ended agreements, on a net basis. Such
settlement then occurs on the 1st business day of the following month, before the new open-ended arrangement commences later that day.

4
Tell us whether you have any repurchase agreements or reverse repurchase agreements that were originally open-ended, but were then converted to overnight or
date-certain agreements at or near month end, and then re-converted back to open-ended agreements after the balance sheet date. If so, please quantify those amounts as of May 31, 2010, June 30 2010 and July 31, 2010 and the
corresponding periods of the prior year.

 BARCLAYS HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS

OF THIS LETTER IN ACCORDANCE WITH 17 C.F.R. 200.83

 Mr M Seaman

 Securities and Exchange Commission

Appendix

 As discussed in the response no. 2 above, the population of open-ended repurchase and reverse repurchase
agreements that are converted to date-certain contracts at the periods requested above are generally replaced by new open-ended transactions after the settlement of interest and the principal and collateral balances occurs. The combined arrangements
provide us with the legal right and ability to settle, what were open-ended agreements, on a net basis. While these steps are necessary to settle interest exposures, the timing is chosen by respective business areas so as to optimize their balance
sheet position by reference to the limits set by the Barclays Capital Balance Sheet Steering Committee.

 The following table outlines the
amount of open-ended repurchase and reverse repurchase agreements converted and settled that were replaced with new open-ended transactions commencing on the first business day of the following month.

Reverse Repos

2010

2009

May
$m

June
$m

July
$m

May
$m

June
$m

July
$m

 Consolidated

—

13,001

23

3

5,493

—

 Comprised of:

 BB PLC

—

9,350

23

3

3,138

—

 BCI

—

3,651

—

—

2,355

—

 Repos

2010

2009

May
$m

June
$m

July
$m

May
$m

June
$m

July
$m

 Consolidated

4

9,400

25

88

5,329

—

 Comprised of:

 BB PLC

—

6,104

25

88

3,281

—

 BCI

4

3,296

—

—

2,048

—

5
Describe the accounting applied for repurchase agreements and reverse repurchase agreements that are converted to overnight or date-certain agreements at or near the
balance sheet under IAS 32. Please ensure your response specifically addresses the criteria that you have the intention to settle on a net basis or to realize the asset and settle the liability simultaneously. Also, to the extent your accounting
conclusion differs depending on whether the converted repurchase agreement or reverse repurchase agreement are later converted back to open-ended agreements, please discuss that fact and provide information supporting the different accounting
conclusions.

 BARCLAYS HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS

OF THIS LETTER IN ACCORDANCE WITH 17 C.F.R. 200.83

 Mr M Seaman

 Securities and Exchange Commission

Appendix

 We account for repurchase agreements and reverse repurchase agreements on a gross basis, unless the
requirements of IAS 32 are satisfied. IAS 32.42 provides:

 “That a financial asset and a financial liability shall be offset and the net
amount presented in the statement of financial position when and only when, an entity:

 (a) currently has a legally enforceable right to set
off the recognised