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Correspondence Filing

 Barclays PLC

 One Churchill Place

 London E14 5HP

 Kevin W Vaughan

Branch Chief

 Securities and Exchange
Commission

 Washington DC 20549

USA

 28 October 2011

 Dear Mr Vaughan,

 Barclays PLC and Barclays Bank PLC

 Form 20-F for the Fiscal Year Ended
December 31, 2010

 Filed 21 March 2011

 Form 6-K

 Filed 2 August 2011

File No. 001-09246

 This letter
responds to the comment letter (the “Comment Letter”) from the Staff (“the Staff”) of the Securities and Exchange Commission (the “Commission”), dated 28 September 2011, concerning the Annual Report on
Form 20-F for the fiscal year ended 31 December 2010 (the “Form 20-F”) of Barclays PLC and Barclays Bank PLC (collectively, “Barclays”) and the Report on Form 6-K relating to the Interim Results Announcement for
the 6 months ended 30 June 2011 (the “Form 6-K”).

 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 indicates that it will provide disclosures in our Annual Report on Form 20-F for 2011 and other future filings that may differ from or supplement the corresponding
disclosure in the 2010 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.

 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 defence in any proceeding initiated by the Commission or any person under the Federal securities laws of
the United States.

 1

 Our responses to your comments are set out in Appendix 1 to this letter.

Yours sincerely,

 /s/ C.G. Lucas

Group Finance Director

Cc
Rebekah Lindsay

 (Securities and
Exchange Commission)

 George H White

 John O’Connor

 (Sullivan & Cromwell LLP)

Andrew Ratcliffe

(PricewaterhouseCoopers LLP)

 2

 Kevin W Vaughan

 Securities and Exchange Commission

 Appendix 1

 Form 20-F for Fiscal Year Ended December 31, 2010

Business Review

 Analysis of
results by business

 Barclaycard, page 23

1
You indicate that you experienced an increase in risk weighted assets, which reflected securitization redemptions. Please revise future filings to clarify why
securitization redemptions would increase risk weighted assets. In your disclosure, please clarify whether you are repurchasing loans from your securitization vehicles and explain the reasons why you have taken such actions. Clarify if the
securitizations of these assets were previously recognized as a sale or a secured financing in your financial statements. Additionally, please tell us how you considered these redemptions in your analysis that the assets should continue to be
derecognized.

 In October 2010, several credit card securitisation debt tranches matured and consequently were redeemed.
There were no early redemptions or calls not related to the maturity of the securities, nor did we repurchase loans from the securitisation vehicles. The debt tranches were issued during 2005 and 2006, when senior and mezzanine tranches of
debt issued in a securitisation generated a regulatory capital benefit through a reduction in risk weighted assets. On the redemption of these tranches, risk weighted assets increased. No eligible securities remain outstanding, and existing and
future debt securities issued under the credit card securitisation program no longer give rise to regulatory capital benefits.

 All credit
card securitisations are recognised as secured financings in the financial statements and we have not derecognised the underlying financial assets.

 We will revise our future filings to state that, where applicable:

•

 The securitisation of credit card loans has in all cases been treated as a secured financing;

•

 Securitisations in comparative accounting periods led to a regulatory capital benefit due to risk sharing with investors; and

•

 Redemption of the issued debt securities results in the withdrawal of the regulatory capital benefit resulting in an increase in risk weighted assets.

 Western Europe Retail Banking, page 25

2
In 2009, you completed the purchase of Citigroup’s cards business in Portugal, which consisted of 400,000 customers and loans and advances to customers of
£550 million. In 2010, you completed the purchase of Citigroup’s Italian card business, which consisted of 200,000 customers and loans and advances of £0.2 billion. You recognized a relatively similar gain on both transactions of
£26 million related to the purchase of the cards business in Portugal and £29 million related to the purchase of the card business in Italy. Please tell us the factors considered in determining a purchase price that resulted in
a gain on these two transactions. Discuss the similarities between these two portfolios in credit trends and the associated purchase discount recorded on them. Tell us how these portfolios have been performing since acquisition and whether this
performance is consistent with your expectations upon purchase.

 The acquisition prices for these businesses reflected the
motivation of the seller and the weak market for such businesses in these countries at the time.

 The acquisitions were dealt with as business
combinations in accordance with IFRS 3 Business Combinations. The fair values of the net assets acquired were derived using a discounted cash flow approach and were corroborated by Ernst & Young LLP. Net assets

 3

 Kevin W Vaughan

 Securities and Exchange Commission

 Appendix 1

acquired included credit card receivable portfolios, associated customer relationships and property, plant and equipment. Additionally, we acquired rights under a co-branding contract with
Vodafone as part of the Italian business.

 The fair value of the acquired net assets of the Italian business was determined in the valuation
exercise to be €194m, which was €32m (£29m) in excess of the purchase price paid. The fair value of the acquired net assets of the Portugal business was determined to be €38m which was €29m (£26m) in excess
of the price paid. While the gains on the two acquisitions were similar, they were separately and independently calculated – the lower net assets of the Portuguese business mainly reflects funding liabilities acquired.

In arriving at the fair value of the loan portfolios, we took into account:

•

 the expected cash flows from the portfolios including the expected loss rate; and

•

 a market rate of interest for the portfolios.

 The credit performance of the portfolios was better than expected in the period from acquisition date to 31 December 2010 in terms of credit strength. Portfolio 30+ days delinquency rates improved
from 9.2% to 6.9% for Portugal and 8.5% to 5.6% for Italy. The annualised charge-off rate improved from 13.0% to 9.6% for Portugal, and 11.4% to 9.9% for Italy. These trends have continued in 2011.

Absa, page 29

3
Your disclosure indicates that the increase in the asset margin of Absa was due, in part, to a change in the product mix as higher margin products grew faster than
low margin products. Please revise your future filings to disclose what types of products you are referring to. If these products include loans and advances with higher risk characteristics, please include a discussion of how this change in your
business mix and the related assumption of risk related to higher margin loans and advances was considered in your determination of the appropriate allowance for loan losses.

Absa made a strategic decision to reduce concentration in home loans and increase product concentration in unsecured products with higher margins, such
as personal and micro loans. This resulted in the change in business mix referred to by the Staff. Specific impairment and capital models are used to calculate the appropriate risk parameters for the higher margin, higher risk products and the risk
parameters and impairment ratios are within the risk appetite approved by Absa’s board. It should be noted that, although there has been a change in business mix, this change is not material relative to the size of the home loans portfolio and
given the fact that the higher risk products are relatively short-term in nature.

 We will revise our future filings to disclose, by material
loan portfolio, changes in exposures, impairment and other key credit risk data (which will vary by portfolio), to allow an understanding of the impact of material changes in the business mix and the risk associated with new business from higher
margin loans and advances.

4
We note your disclosure that risk weighted assets for this segment increased 42% due in part to enhancements to the retail model. Please revise your future filings
to expand your disclosure regarding the types of enhancements to the retail model. Discuss if the enhancements caused you to identify certain assets as having a higher risk weighting than you originally assigned and discuss the impact the change in
your model had on your capital ratios. Clearly identify how much of the increase in risk weighted assets was due to the growth in higher margin products noted above.

 4

 Kevin W Vaughan

 Securities and Exchange Commission

 Appendix 1

 Absa Retail made extensive changes to a number of regulatory credit models in 2010 encompassing nearly
all portfolios and all risk parameters, i.e., probability of default, loss given default and exposure at default models. The total impact of this exercise on the retail portfolio was a net increase of R28bn (£2.7bn) in total RWAs of
R303bn, (£28bn) which reduced capital ratios. The major increase in the risk weightings in Absa Retail was due to the credit model rebuild adjustments. The increase as a result of the higher risk products was immaterial due to the
short-term nature of the portfolio and its smaller relative size.

 We will revise our future filings to expand our disclosure regarding the
types of enhancements to the retail model. We will also identify how much of any material increase in RWAs has been due to the growth in higher margin products.

 Barclays Capital, page 31

5
We note your disclosure regarding the 35% decline in the top line income of Fixed Income, Currency and Commodities. Please respond to the following:

•

 Please tell us in greater detail the types of commodities in which you invest specifically identifying the commodities in which you take physical
possession, the activities that go into making a market in these commodities, and the types of revenue streams earned as a result of these activities.

•

 Tell us how you obtained your ownership of the various commodities you own, and tell us whether this is an area where you are considering further
investments.

•

 Tell us whether you hold concentrated positions in or take physical possession of commodities that constitute a significant or influential share of
the market for that commodity. If so, revise your future filings to discuss that fact and your activities in that area.

As part of the Commodities trading business, Barclays trades physically settling derivatives and holds physical inventory of crude oil, refined products,
precious metals, base metals in the form of London Metals Exchange (LME) warrants, natural gas, natural gas liquids and carbon emissions certificates. Barclays makes markets on both a spot and forward basis for each of these physical commodities
through brokers and directly to clients. Through trading physically settling commodities, Barclays offers clients tailored risk management and hedging solutions specific to physical market participants in a range of different products. The ability
to hold physical inventory also allows Barclays to offer financing and monetisation structures, secured by physical inventories. In addition to this, by holding storage and transportation contracts, Barclays is able to access a range of physical
markets and locations. Barclays recognises revenues from these activities through net trading income.

 Physical inventories are purchased both
directly from producers, utilities and mid-stream clients and also from the interbank market. Barclays expects to make additional investments in the normal course of business, depending on market conditions.

On occasion, Barclays will hold dominant positions in base metals on the LME (as per their definition). On these occasions, we comply fully with the
requirements of the LME under their Lending Guidance. Lending Guidance is the LME’s mechanism for limiting the impact of dominant positions on the market by prescribing the amount and level at which positions must be lent. We will revise future
filings to discuss this fact.

 5

 Kevin W Vaughan

 Securities and Exchange Commission

 Appendix 1

 Credit Risk Management Impairment allowances, page 73

6
You indicate on page 175 that the “other personal loans” category includes second lien loans, along with other types of personal loans. Please tell us and
revise future filings to disclose the balance of second lien loans held by you at the end of the reporting period. If delinquency and other credit trends for second lien loans differ from other types of personal loans in this category, please
consider reporting that information separately for second lien loans. Otherwise, tell us how you determined such delinquency and credit quality trends were substantially the same. Please also address the following:

Our portfolio of second lien loans (UK Secured Lending) had a balance of £3.8bn as at 31 December 2010 (£3.5bn as at 30 June 2011).
This portfolio was closed to new business in August 2008 and has been running off since then. All loans are on a full repayment basis with no further drawdown facilities.

 This portfolio on 31 December 2010 was 1.6% of our total retail loan book of £235.3bn and whilst credit quality (of loans that are neither past due or impaired), delinquency (loans that are
past due but not individually impaired) and impaired loans are disclosed as part of, and therefore have an influence on, our overall Other personal lending category, they are not disclosed separately. IFRS 7 Financial Instruments:
Disclosures permits entities to aggregate balances to prevent the inclusion of excessive detail provided they have the same measurement attribute. The balances have been presented within loans that are not normally collateralised as our
experience is that their risk characteristics have more in common with these loans than mortgage loans with a first lien. We have determined that this is the case by reference to our experience and a number of risk measures, such as 90 days arrears
balances, recoveries stock and charge-off rates. As at 31 December 2010, these measures for UK Secured Lending, UK Unsecured Personal Loans and UK Home Finance Loans were as follows:

 Metric

UK
Secured
Lending

UK
Unsecured
Personal
Loans

UK
Home
Finance
Loans

 Total Gross Loans

£bn

3.8

6.5

101.3

 90 Day arrears balances1

£m

97

121

331

 Recoveries stock

£m

461

1,063

713

 90 Day arrears2

%

3.0
%

2.6
%

0.3
%

 Balances in recovery

%

12.6
%

18.5
%

0.7
%

 Charge-off rates

%

3.5
%

7.9
%

0.5
%

1.
Excluding balances in recovery book

2.
Balances greater than 90 days in arrears but not charged off to recoveries, expressed as a percentage of outstanding balances excluding balances in recoveries.
Percentages include accounts on forbearance programmes.

 The table compa