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Correspondence

 Barclays PLC

 One Churchill Place

London E14 5HP

 Stephanie J. Ciboroski

 Senior Assistant Chief Accountant

 Securities and Exchange Commission

Washington DC 20549

 USA

8 October 2012

 Dear Ms Ciboroski,

Barclays PLC and Barclays Bank PLC

Form 20-F for the fiscal year ended December 31, 2011

 Filed 30 March 2012

 Form 6-K

Filed 27 July 2012

 Files
No. 001-09246 and 001-10257

 This letter responds to the comment letter (the “Comment Letter”) from the Staff (“the
Staff”) of the Securities and Exchange Commission (the “Commission”), dated 10 September 2012, concerning the Annual Report on Form 20-F for the fiscal year ended 31 December 2011 (the “2011 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 2012 (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 2012 (the “2012 Form 20-F”) and other future filings that may differ from or supplement the corresponding disclosure in the 2011 Form 20-F or the Form 6-K. 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 a number of responses, in response to the Staff’s
comment, we have provided a form of disclosure for our 2012 Form 20-F. Changes in facts and circumstances at the time of the filing of the 2012 Form 20-F may result in changes in some or all of these forms of disclosure (in addition to changes to
reflect the availability of full year 2012 financial information).

 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.

We hope this letter provides satisfactory answers to the Staff’s comments, but if you require further clarification or have further comments, please
let us know.

 Yours sincerely,

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

 Stephanie J Ciboroski

 Securities and Exchange Commission

 Appendix 1

 Form 20-F for Fiscal Year Ended December 31, 2011

Board Corporate Governance and Nominations Committee Report, page 9

1
We note from your disclosure on page 10 that in 2011 you concluded that the Committee’s performance could be improved and that you implemented an action plan as
a result. In future filings, please expand your disclosure to explain the action plan and how it changed Committee processes.

Our annual Board Effectiveness Review, conducted in the fourth quarter (Q4) of 2011, found the performance of the Committee to be fully effective;
however, the Committee concluded in Q1 2012, when considering the outcomes of the Review, that there were two areas where minor enhancements could be made. These were described in the 2011 Committee Chairman’s report. No other actions were
identified and no material changes were made to the Committee’s processes.

 In response to the Staff’s comment, set out below is a
draft of the form of disclosure which we propose to include in the 2012 Form 20-F, which will be updated as appropriate to reflect the Committee’s 2012 annual review, the relative significance of the particular actions to be implemented, if
any, and related changes to the Committee’s processes:

 “Following the 2011 annual effectiveness review of the Committee, we
improved the induction process for new Committee members by committing to implement a bespoke induction for any new Committee member, to be agreed by the Company Secretary with the Chairman and the new Committee member. We also provided more
opportunities for members to bring items onto the Committee agenda, including distributing the draft agenda to all Committee members for comment ahead of meetings and including the Committee’s annual forward agenda with the papers for each
meeting.”

 Board Audit Committee Chairman’s Report, page 12

 Internal Controls, page 13

2
Please expand your disclosure in future filings to describe the material components of the remediation program that was implemented following the fine imposed on
Barclays Capital for breaches of client asset segregation rules and your compliance with the program.

 In response to the
Staff’s comment, we propose to add disclosure to the following effect, in the “Risk management – Supervision & regulation” section, in the 2012 Form 20-F and future Form 20-F filings, updated to reflect material facts
and circumstances at the time of the filing, if any:

 “In January 2011, Barclays Capital Securities Limited (BCSL) was subject to an FSA
fine for breaches of the client money and assets (CASS) segregation rules. Specifically, BCSL failed to segregate client monies placed on GBP money market deposits intra-day in a segregated trust account. Throughout the relevant period the
funds were segregated overnight but on an intra-day basis client money was co-mingled with firm money for between five and seven hours each day. Upon discovery of the intra-day segregation issue BCSL corrected the situation promptly.

BCSL also undertook a wider CASS Review in 2010 and implemented a remediation plan to address the issues identified in that review which included:

•

 Enhancements to the client document and static data control framework.

Enhancements were made to the contractual and static data control framework to provide for systemic and centralised capture of the
relevant contractual client money and custody terms and alignment to downstream calculation, segregation and reconciliation processes.

 3

 Stephanie J Ciboroski

 Securities and Exchange Commission

 Appendix 1

 An exercise was undertaken to align the client money contractual terms within the Terms
of Business with the operational segregation practices and where required enter into supplemental or amended contracts with clients to clarify the basis upon which the monies and/or assets that they place with Barclays are held.

•

 Increased automation of the client money calculation and reconciliation practices.

BCSL has introduced an automated client money system which has significantly reduced the level of manual processing involved in the client
money calculation and segregation procedures and enhanced the available audit trail to inform the daily assurance processes.

•

 Increased clarity and transparency of CASS Policies, Procedures and Roles and Responsibilities.

A CASS oversight officer has been appointed and a formal organisational structure (including roles and responsibilities) covering CASS
requirements has been agreed and implemented across relevant business and infrastructure areas. Awareness of CASS and the application to the firm’s business activities has been enhanced through the introduction of a mandatory structured
training course for those involved in CASS Processing and the development of detailed operational policies and procedures.

•

 Enhanced Governance and Oversight Controls.

 A formal Governance, Control and Oversight committee structure with formal reporting obligations into the firm’s central governance framework has been established.

A CASS specialist team has been established within the Operational Regulatory Control team and ongoing CASS quality assurance and
incident management and reporting processes have been established and implemented.”

3
Please describe your compliance with the undertakings contained in the Deferred Prosecution Agreement related to US sanctions and US dollar payment practices.

 In response to the Staff’s comment, we propose to include the following disclosure (in the “Risk management
– Supervision & regulation” section) in our 2012 Form 20-F filing, updated if appropriate to reflect the status of the dismissal by the United States of the criminal Information described below:

“On August 16, 2010, the United States filed in the United States District Court for the District of Columbia a criminal Information against
Barclays, which alleged violations of U.S. sanctions laws. The United States and Barclays simultaneously entered into a Deferred Prosecution Agreement (DPA), pursuant to which the United States agreed to defer prosecution for a period of
two years, provided that Barclays complied with various undertakings, including undertakings relating to cooperation and remediation. The DPA provided that if Barclays complied with those undertakings, the United States would move to dismiss
the Information. On August 31, 2012, the United States moved the Court to dismiss the Information with prejudice on the ground that Barclays had ‘fully cooperated with the United States, complied with all of its obligations under the
DPA, and not otherwise violated the DPA’.”

 4

 Stephanie J Ciboroski

 Securities and Exchange Commission

 Appendix 1

 Key Risk Issues, page 15

4
In future filings, please provide expanded disclosure that addresses the resolution of the key risk issues presented in this section. With respect to risks relating
to your risk management framework, please also expand your disclosure in the “Risk management” section to explain the results of the Committee’s consideration of these issues, including whether changes to risk management occurred as a
result of such review.

 The Board Risk Committee Chairman’s report describes the work of that Committee during the year
in question. In future Form 20-F filings, we will include in this section of the Committee Chairman’s report appropriate cross-references to other areas of the Form 20-F where disclosure is relevant to the specific key risk issues considered by
the Committee or which describe specific actions taken by Executive Management as a consequence of the Committee’s consideration of such key risk issues.

 To the extent that the Committee’s assessment of key risk issues in any given year results in changes to our risk management framework, in future Form 20-F filings we will expand the disclosure in
our “Risk management” section to describe those changes.

 Risk Management, page 40

Credit Risk, page 52

 F. Identifying
Credit Risk Loans, page 62

5
Please revise your disclosure in future filings to describe how you determine the emergence period for purposes of determining the appropriate amount of allowance
for loan losses. If this varies by loan type, please provide this disclosure by loan type. Additionally, to the extent that the emergence periods vary over time, please discuss the drivers that result in the shortening or lengthening of the
emergence periods.

 Unidentified impairment uses the concept of emergence periods to estimate losses which are estimated to
have been incurred but not yet specifically identified in portfolios of loans at the balance sheet date in accordance with IAS 39, Financial Instruments: Recognition and Measurement, AG90. As at 30 June 2012, the unidentified impairment
allowance for the Group totalled £306m, or 3.1% of the Group’s total impairment allowance of £9,946m.

 In response to the
Staff’s comment, we propose to include the following information in our disclosure in future Form 20-F filings:

 “For wholesale
portfolios, in the Corporate Banking and Investment Bank divisions, the emergence period is portfolio specific and is based on the time taken from receiving a default indicator to an identified impairment being incurred.

For portfolios in Corporate Banking, based on this rationale, a three month emergence period is generally used.

For Investment Bank portfolios, a six month period is appropriate. The longer emergence period is appropriate because counterparties are larger and loan
balances are individually material, and are as a result, subject to individual monitoring for early signs of default.

 For Retail Bank
portfolios, minimum emergence periods are defined at a product level.

 5

 Stephanie J Ciboroski

 Securities and Exchange Commission

 Appendix 1

 Emergence periods at 31 December 2011 for the main retail products were as follows:

 Product

Emergence
Period
(months)

 Credit Cards

1

 Mortgages

6

 Vehicle Finance

3

 Personal Loans

3

 Overdrafts

3

 Retail SME

3

 Emergence periods are periodically (at least annually) tested against the actual time elapsing from the initial
indication of potential default to the loss event. When necessary, the emergence period is adjusted to reflect our most up-to-date experience of customer behaviour.”

 I. Forbearance, page 64

6
We note your disclosure that you utilize a management overlay as the only practical means of factoring certain recent conditions into impairment calculations for
your retail accounts until your models can be recalibrated. Please revise your disclosure in future filings to discuss the factors considered in determining the amount of overlay related to these loans and discuss the differences between this
process and that used for your regular retail loan portfolio.

 In response to the Staff’s comment, we will revise our
disclosure in future Form 20-F filings, where appropriate and subject to consideration of the materiality of the adjustments in respect of the manual overlays in 2012, to describe the factors considered in determining the management overlay. Such
disclosures will include the following information:

 “Management overlays for impairment in Retail portfolios are applied in order to
factor in certain conditions or recent changes in policy that are not incorporated into the relevant impairment models, to ensure that the impairment allowance reflects all known facts and circumstances at the period end. The main factors in
management overlays are recent changes to forbearance policy, collections and charge-off processes, or data availability issues relating to new portfolios or data not captured by existing processes. Overlays typically increase the model derived
impairment allowance.

 6

 Stephanie J Ciboroski

 Securities and Exchange Commission

 Appendix 1

 Management overlays for impairing our retail balances in 2011 and 2010 for the principal home loan
portfolios are presented below:

 31 December 2010 Portfolio

Total Management
Overlay,
including forbearance
£m

Management
Overlay as
proportion of total
impairment
allowance
%

 UK Home Loans

27.9

39.4

 Spain Home Loans

47.5

50.5

 Italy Home Loans

0.7

1.0

 31 December 2011 Portfolio

Total
Management
Overlay, including forbearance
£m

Management
Overlay as
proportion of total
impairment
allowance
%

 UK Home Loans

58.1

55.1

 Spain Home Loans

3.9

4.2

 Italy Home Loans

—

—  ”

 The high level of management overlay for Spain Home Loans in 2010 reflected a requirement to increase coverage to take
into account higher repossession rates and the impact of reductions in house prices on the impairment allowance on loans in charge-off. In UK Home Loans, approximately £30m of the management overlay in 2011 reflected an increase in coverage on
Forbearance and high risk accounts.

 Retail Credit Risk, page 69

7
Please revise your disclos