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Correspondence Letter

 Barclays PLC

 One Churchill Place

 London E14 5HP

 Stephanie J. Ciboroski

Senior Assistant Chief Accountant

 Securities and Exchange
Commission

 Washington DC 20549

 USA

 5 March 2013

 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

 Form 6-K

 Filed October 31, 2012

 Files No. 001-09246 and 001-10257

 This letter responds to the comment letter (the
“Comment Letter”) from the staff of the Securities and Exchange Commission (“the Staff”), dated 1 February 2013, 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, and the Report on Form 6-K relating to
the Interim Management Statement for the quarter ended 30 September 2012.

 Our responses to your comments are set out in Appendix 1
to this letter. To facilitate the Staff’s review, Barclays has included in its responses the captions and numbered comments included in the Comment Letter in bold text and has provided its responses immediately following each numbered comment.

 Yours
sincerely,

C.G. Lucas

 Group Finance Director

Cc
 Celia Soehner

(Securities and Exchange Commission)

 George H. White

 John O’Connor

(Sullivan & Cromwell LLP)

 Andrew Ratcliffe

 (PricewaterhouseCoopers LLP)

 1

 Stephanie J Ciboroski

 Securities and Exchange Commission

 Appendix 1

1.
 We note from your response to prior comment 4 that in future filings you intend to include cross-references from this section to “other areas of the
Form 20-F where disclosure is relevant to the specific key risk issues…or which describe specific actions taken [as a result] of such key risk issues.” However, it is unclear from your response and existing disclosure what other areas of
your 2011 Form 20-F specifically relate to the bulleted key risk issues that are presented on page 15. Please advise, or describe further how you will expand your disclosure in future filings to comply with prior comment 4.

 In light of the Staff’s further comment, in our 2012 Annual Report on Form 20-F (the
“2012 20-F”) we will clarify the resolution of the “Key Risk Issues” reported in the Board Risk Committee (BRC) Chairman’s report in the Corporate Governance Report. We will also disclose details of any changes to risk
management that occurred as a result of the BRC’s review of such issues.

 “Key Risk Issues” reported to
the BRC are issues proposed by management so that the BRC can assess their current and future impact and ensure that any risks are being managed appropriately. There are three potential outcomes from the BRC’s review of such issues:
(i) the BRC may be satisfied that either no management action is required or that existing actions being taken by management are appropriate; (ii) it may, after discussion with management, satisfy itself that actions to be taken by
management following the discussion are appropriate; or (iii) it may, following discussion with management, elevate situations to the Board where it is not satisfied that the appropriate actions are being taken by management.

The 2012 20-F will clarify in the Corporate Governance Report which of these outcomes the BRC resolved in respect of each such
issue and, where any items have been referred to management for action or have been elevated to the Board, we will cross refer to disclosure elsewhere in the financial report where the resulting actions are described.

No changes to risk management have occurred as a result of the BRC’s review of any one specific key risk issue in
2012. However, following discussions on liquidity risk appetite and the liquidity risk management framework, and taking into account the external environment and potential stresses on Barclays following the announcement of the fines in relation
to the Bank’s misconduct in relation to LIBOR and EURIBOR, BRC asked that management implement a temporary reduction to liquidity risk appetite for a time over the summer period in 2012. We will disclose this temporary reduction in the
“Funding Risk” sub-section in the “Risk Management” section with a cross reference in the BRC Chairman’s report in the Corporate Governance Report to this Funding Risk section.

2.
 Please refer to prior comment 5. We note your response and your proposed disclosure regarding the emergence period for various portfolios. You define the
emergence period as the timeframe in which losses have been incurred but not yet specifically identified in portfolios of loans at the balance sheet date. Further, your disclosure on page 63 of the December 31, 2011 20-F states that “[t]he
incurred but not yet reported calculation is based on the asset’s probability of moving from the performing portfolio to being specifically identified as impaired within the given emergence period and then on to default within a specified
period.” Please address the following:

—

 Please clarify what you mean by “specifically identified as impaired.” For example, clarify if this is when a loan becomes past due, you
receive notice of bankruptcy, etc., or at some other point. To the extent this varies among your portfolios, please explain how.

 Barclays holds impairment in three categories:

 1.   Specific or
Individual Identified Impairment

 2.   Collective Identified Impairment

3.   Collective Unidentified Impairment

 2

 Stephanie J Ciboroski

 Securities and Exchange Commission

 Appendix 1

 The reference to “specifically identified as impaired” refers to the
category of specific or individual identified impairment whereby there is objective evidence of impairment within the meaning of IAS 39 Financial Assets: Recognition and measurement, regarding the individual asset resulting in an impairment
allowance against the individual asset.

 Objective evidence of individual impairment is defined within the Group
Impairment and Provisioning Policy and is fully aligned with IAS 39. This policy will be described within the “Credit impairment charges and impairment on available for sale assets” note to the financial statements in the 2012 20-F as
follows:

 “An impairment loss is recognised if there is objective evidence of impairment as a result of events that
have occurred and these have adversely impacted the estimated future cash flows from the assets. These events include:

-

 becoming aware of significant financial difficulty of the issuer or obligor;

-

 a breach of contract, such as a default or delinquency in interest or principal payments;

-

 the Group, for economic or legal reasons relating to the borrower’s financial difficulty, grants a concession that it would not otherwise consider;

-

 it becomes probable that the borrower will enter bankruptcy or other financial reorganisation;

-

 the disappearance of an active market for that financial asset because of financial difficulties; and

-

 observable data at a portfolio level indicating that there is a measurable decrease in the estimated future cash flows, although the decrease cannot yet be
ascribed to individual financial assets in the portfolio – such as adverse changes in the payment status of borrowers in the portfolio or national or local economic conditions that correlate with defaults on the assets in the portfolio.”

 Collective Identified Impairment is where there is IAS 39 objective evidence of impairment against
individual assets, but impairment is held at a collective level against a pool of similar assets. This is generally applied to pools of retail assets that are individually insignificant. Wholesale assets on Early Warning list 3 (EWL3) categories are
also collectively assessed for impairment. EWL 3 assets are assets for which concern exists and if the obligor’s financial position deteriorates default could occur and the Group would be at risk of loss.

Unidentified Impairment is calculated using statistical analysis with suitable management oversight; all parameters used within
this analysis are frequently monitored and assessed for their reasonableness (e.g. emergence period).

—

 Please clarify why you define the emergence period based on the time taken from “receiving a default indicator” to an identified
impairment being incurred for your wholesale portfolios in the Corporate Banking and Investment Banking divisions. In this regard, the period of “receiving a default indicator” appears to be potentially different than the point that the
loss was incurred. Additionally, clarify the types of things you would consider to be a “default indicator” for these portfolios.

In light of the Staff’s further comments, we consider that the use of the term “Default indicators”, which has a
specific meaning under Basel III, may not be sufficiently clear and we will remove it from our proposed disclosures. In place of the disclosure suggested in our previous response, we propose to include the following in future Form 20-F filings:

 “For wholesale portfolios, in Corporate Banking and Investment Bank, the emergence period is portfolio specific
and is based on the anticipated length of time from the occurrence of a loss event to identified impairment being incurred.”

 3

 Stephanie J Ciboroski

 Securities and Exchange Commission

 Appendix 1

 To clarify, for wholesale portfolios, the emergence period is the average time
that we estimate elapses from the occurrence of a loss event to a point where identified impairment is incurred.

—

 Expand your disclosure to specifically discuss how you test these periods against the actual time elapsing from the initial indication of potential
default to the loss event. In this regard, it appears that the emergence period is only a portion of this timeframe, but your response indicates that you use the whole period to validate that the emergence period is reasonable.

 In the Corporate Bank the emergence period is tested against the actual time elapsing from the
occurrence of a loss event to the point where impairment is identified by way of individual case file review. In the 2012 20-F, we will expand our disclosures to state that:

“The emergence period in the Corporate Bank is derived from actual case file review. This has also been benchmarked against
the time taken to move between risk grades in our internal watch lists, from EWL1 or 2 into EWL3 which is the level of risk that will attract a collective impairment allowance. Both methodologies produce similar results for the emergence period,
which is currently 3 months.”

 Unidentified impairment in the Investment Bank is calculated for all exposures held
at amortised cost where an identified impairment is not held, using a 6 month emergence period. When we periodically review the Unidentified Impairment methodology, this emergence period is checked against past experience.

—

 Tell us in more detail why a longer (six-month period) would be used for larger counterparties and large loan balances that are subject to
individual monitoring for early signs of default, as compared to retail banks portfolios where individual monitoring would not be occurring.

Larger corporate clients have greater resources such that it typically takes a longer period of time from a loss event, such as the
significant financial difficulty of the obligor, to objective evidence of impairment being observed. Financial information may also be updated less frequently than for retail borrowers (where past due status is key) and consequently the emergence
period is longer.

 Retail portfolios are subject to a shorter emergence period as a loss event will quickly result in
objective evidence of impairment being observed. For example in the event of a retail customer becoming unemployed, this quickly results in non-payment of a credit card bill. However we believe that the same customer would attempt to make mortgage
payments for a longer period and hence a longer emergence period is appropriate.

—

 Clarify how this period relates to the “write-off” period and “charge-off” periods discussed in response to our prior comment 7.

 In Barclays Retail Credit Risk terminology, “emergence period” refers to the time it
takes for an account that is impaired but not yet identified to move from the performing loan category to the impaired loan category. This is the period of time which we look at historically to derive a prediction for the level of Unidentified
Impairment present on the performing loan book. Unidentified Impairment is applied to loans that do not yet exhibit signs of potential loss but a loss event has already occurred. A lengthening of this period will generally lead to higher levels of
Unidentified Impairment.

 As the emergence period only has an effect in the calculation of Unidentified Impairment, it
does not have a direct relationship with the ‘write-off’ and ‘charge-off’ periods. By definition it needs to address events which have occurred, but as these events cannot be identified, this must be done in a probabilistic
manner.

 4

 Stephanie J Ciboroski

 Securities and Exchange Commission

 Appendix 1

3.
 Please refer to prior comment 9 and address the following:

We note your response that you were unable to identify whether customers were experiencing financial difficulty at the time the
loans were extended. We further note that you subsequently determined that the loans should not be classified as forbearance, in part because they met minimum age and term requirements and you did not lower the interest rate. Tell us whether you
evaluated if they would have access to alternative funding at the same rate, or whether the rate at which the loan was extended was commensurate with the market rate for a loan of similar credit quality at the time of extension. If so, tell us how
and if not, tell us why not.

 We did not evaluate if these customers would have had access to alternative funding at
the same rate, but were able to continue to lend to these customers because they met our underwriting criteria at the date that the loans were extended. Under Barclays terms and conditions, for this portfolio, the mortgage interest rate was set for
the life of the product at a fixed percentage above the Bank of England base interest rate which was maintained when the loan was extended.

—

 Clarify how long the interest-only period for these loans was typically extended. To the extent it was for one year or more, discuss how you
consider the impact on your 30 day and 90 day arrear numbers in your response. For example, given that the borrower is only required to make the interest payment, it appears this could positively impact the delinquency trends noted.

 These mortgages were interest-only from origination and not switched from capital repayment
products. Analysis shows that the average extension of the mortgage term was approximately 6.5 years. The term extension did not result in reduction of monthly payments for these loans, and therefore we would not expect any impact to delinquency as
a result of this action.

—

 Clarify whether the loans convert to amortizing after the interest-only period ends, and if so, discuss the typical percentage impact to the monthly
payment upon conversion to an amortizing loan. Also, discuss the periods when the vast majority of these loans convert to amortizing (if applicable), and discuss any trends in delinquency statistics upon the conversion to an amortizing loan, to the
extent they are different from the statistics in your response.

 These loans were interest-only
mortgages that have had their maturity date extended and as such do not convert to amortising within the term of the mortgage. The entire principal amount of the mortgage is repayable on maturity.

The original loan tenor plus the term of extension would not ha