SecProbe.io

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	June 20, 2005
Mail Stop 0408

By: International mail and facsimile to 011-353-1-6603063

Mr. Michael Buckley
Chief Executive Officer
Allied Irish Banks, PLC
Bankcentre
Ballsbridge,
Dublin 4, Ireland

Re:	Allied Irish Banks, PLC
      Form 20-F for Fiscal Year Ended December 31, 2004
	File No.  001-10284

Dear Mr. Buckley:

      We have limited our review of your filing to those issues we
have addressed in our comments. Where indicated, please provide us
with the supplemental documentation we requested in response to
these
comments.  Please be as detailed as necessary in your explanation.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 20-F

Item 8: Financial Information

Basis of Consolidation

Employee Benefits, page 66

1. Please provide a summary of subsidized loans and deposits with
preferential rates provided to employees including, but not
limited
to:
* The total number of loans to employees;
* The total principle amount outstanding for employee loans and
deposits;
* The monetary value of employee loans or deposits concentrated
with
individual employees;
* Average or range of interest rate discounts/premiums for loans
and
deposits respectively;
* Treatment of interest income/expense during consolidation and
the
reconciliation to U.S. GAAP;
* The guidelines, limitations and oversight for employee loans and
deposits.
Please review paragraphs 2 and 24 of SFAS No. 57 and Rule 4-08(k)
of
Regulation S-X to ensure that you are in compliance.  Discuss why
you
continue to believe your presentation is appropriate and/or
explain
what additional disclosures or other actions you plan to undertake
in
future filings to ensure full compliance.

Item 18 and 19 Financial Statements and Exhibits

Notes to Consolidated Financial Statements

50. Summary of Significant Differences between Irish and United
States Accounting Principles, page 164

Accounting for Investment in M&T Bank, page 164

2. Please tell us specifically the differences in accounting
treatment between Irish and United States GAAP as applied to your
investment in M&T and the Group`s share of profits of M&T.  Your
discussion should include but not be limited to:
* The accounting treatment for the consolidated statement of
income
and consolidated balance sheet items existing at the time of the
sales transaction and for the current financial period;
* The nature of the investment in M&T and the criteria you use to
apply the equity or cost methods.  Specifically discuss the amount
of
control AIB can enact on M&T policy and management decisions and
the
resulting impact on your accounting determinations for both Irish
and
US GAAP. Please refer to paragraph 6 APB Opinion 18 paragraph 6
for
US GAAP;
* Explanations of how these differences relate to the Adjustments
to
Net Income table on page 165, the Consolidated Ordinary
Stockholders`
Equity table on page 166, and the Consolidated Total Assets table
and
Consolidated Total Liabilities and Ordinary Stockholders` Equity
table on page 167.

Statement of Changes in Ordinary Stockholders` Equity, page 166

3. Please tell us what acquisition or acquisitions the Goodwill
Written Back in 2003 relates to and quantify individually, if
necessary.  As a related matter, please tell us how frequently you
review goodwill for impairment on a US GAAP basis and revise your
US
GAAP policy in future filings.  We note paragraph 17 of SFAS No.
142
and supporting guidance.

4. Please  reconcile the issue of shares caption and respective
quantifications in  your US GAAP Statement of Changes in Ordinary
Stockholders` Equity table to your Irish GAAP Consolidated
Statements
of Changes in Stockholders` Equity on page 106 for the periods
presented.

Debt and Equity Securities, page 168 to 170

5. Please provide, in tabular format, a summary of your gross
unrealized gain and gross unrealized loss positions for your
available-for-sale and held-to-maturity securities.  Categorize
the
gains and losses by "less than 12 months" and "12 months and
greater".  Please review Emerging Issues Task Force Abstract # 03-
1,
paragraph 21(a) and SFAS No. 115 paragraph 17-22 to ensure that
you
are in compliance and discuss why you continue to believe your
presentation is appropriate.

* * * * *

       As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information required under the
Securities Exchange Act of 1934 and that they have provided all
information investors require for an informed investment decision.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company 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

* the company 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Paula Smith (Staff Accountant) at (202) 551-
3696
or me at (202) 551-3492 if you have any questions regarding
comments
on the financial statements and related matters.

Sincerely,

							John P. Nolan
							Accounting Branch Chief
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Mr. Michael Buckley, Chief Executive Officer
Allied Irish Banks, PLC.
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