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      March 12,
2009

      VIA EDGAR SUBMISSION AND
FACSIMILE

      Mr.
Michael R. Clampitt

      Staff
Attorney

      Securities
and Exchange Commission

      Division
of Corporation Finance

      100 F
Street, N.E.

      Washington,
D.C. 20549

                  Re:

                  BBVA
      Banco Frances S.A.

                Form
      20-F for the year ended December 31,
2007

                Filed
      March 31, 2007

                File
      No. 001-12568

      Dear Mr.
Clampitt:

      By letter dated February 26, 2009, you
provided comments on behalf of the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “SEC”) with respect to the Company’s annual report
on Form 20-F for the fiscal year ended December 31, 2007 (“Form 20-F”). In
response to your comments and on behalf of the Company, we have duly noted those
comments as indicated below. The text set forth in bold-faced type, immediately
following each paragraph number, is a verbatim reproduction of the comments
included in your letter and appears in the order set forth therein.

      BBVA
Banco Francés S.A. Form 20-F for the year ended December 31, 2007

      Item 7 Major Shareholders
and Related Party Transactions

      Related Party
Transactions

                1.

                We
      note that the company has not identified the names of the key management
      personnel included in the related party transactions table on page
      134.  In future filings,
please

                      Mr.
      Michael R. Clampitt

                      U.S.
      Securities and Exchange Commission

                      March
      12, 2009

                    identify
      the director, senior management member or other related party required to
      be described by Item 7.B of Form 20-F who received the loan. In the
      alternative, please confirm that the company will comply with
      Instruction  2 or 3 to Item 7.B of Form 20-F, if
      applicable.

      Response:

      We duly note the Staff’s comment and we
confirm that the company will comply with Instruction 2 to Item 7.B of Form
20-F, as applicable.  To this effect  the following text
will be added as a reference to the table captioned “Transactions Between
Related Parties”:

      Key
Management Personnel (*)

      (*)
includes directors, senior managers, members of the audit committee and managers
with relevant authority.

      The
transactions included in this section (a) were made in the ordinary course of
business, (b) were made on substantially the same terms, including interest
rates and collateral, as those prevailing at the time for comparable
transactions with other persons, and (c) did not involve more than the normal
risk of collectability or present other unfavorable features.

      Exhibit 12.1 and
12.2

      Section
302—Certifications

                2.

                We
      note that paragraphs 2, 3, 4 and 5 of your certifications included as
      Exhibit 12.1 and 12.2 to the Form 20-F contain modifications of the exact
      form of certification as set forth in the instructions to the exhibits in
      Form 20-F.  For example, the certifications include a reference
      to the “Annual Report” rather than referring only to the “report” and use
      the word “registrant” instead of “company”.  In future filings,
      please ensure that the certifications are in the exact form as set forth
      in the instructions to the exhibits in Form 20-F, except
  as

          2

                    Mr.
      Michael R. Clampitt

                    U.S.
      Securities and Exchange Commission

                    March
      12, 2009

                    otherwise
      indicated in Commission statements or staff
    interpretations.

      Response:

      We duly note the Staff’s
comment.

      * * *
*

      In addition, as requested, the company
acknowledges that:

                ·

                the
      company is responsible for the adequacy and accuracy of the disclosure in
      the filings;

                ·

                staff
      comments or changes to disclosure in response to staff comments do not
      foreclose the Commission from taking any action with respect to the
      filings; 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.

      If you have any questions regarding
this matter, please feel free to call me at 011-54-11-4341-5083 or Andrés V. Gil
of Davis Polk & Wardwell, our U.S. legal counsel, at
212-450-4779.

                Yours sincerely,

              /s/
      Martin Ezequiel Zarich

                Martin Ezequiel Zarich

                Chief Financial Officer

                BBVA
      Banco Frances S.A.

                cc

                Mr.
      Andrés V. Gil, Esquire, Davis Polk &
  Wardwell.

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