SEC Comment Letter for Invesco Ltd. (IVZ) (CIK 0000914208) (IVZ) — Nov 9, 2007

Invesco Ltd. (IVZ) (CIK 0000914208)
Date: Nov. 9, 2007 · CIK: 0000914208 · Accession: 0000000000-07-055255

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Date

November 9, 2007

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Company

Invesco Ltd. (IVZ) (CIK 0000914208)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE VIA FACSIMILE AND U.S. MAIL November 9, 2007 Loren M. Starr Chief Financial Officer Invesco PLC 1360 Peach Tree Street N.E. Atlanta, Georgia 30309 RE: Invesco PLC Form 20-F for Fiscal Year Ended December 31, 2006 File No. 1-13908

Dear Mr. Starr:

We have completed our review of your Fo rm 20-F and related filings and have no further comments at this time. If you have any further questions regard ing our review of your filings, please direct them to Ernest Greene, Staff Accountan t, at (202) 551-3733 or in his absence, to the undersigned at (202) 551-3689.

S i n c e r e l y , John Hartz Senior Assistant Chief Accountant

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

VIA FACSIMILE AND U.S. MAIL

                                                      November 9, 2007
Loren M. Starr
Chief Financial Officer Invesco PLC 1360 Peach Tree Street N.E. Atlanta, Georgia 30309
 RE: Invesco PLC
Form 20-F for Fiscal Year  Ended December 31, 2006
File No. 1-13908

Dear Mr. Starr:

We have completed our review of your Fo rm 20-F and related filings and have no
further comments at this time.
If you have any further questions regard ing our review of your filings, please
direct them to Ernest Greene, Staff Accountan t, at (202) 551-3733 or in his absence, to
the undersigned at (202) 551-3689.

       S i n c e r e l y ,           John Hartz
      Senior Assistant Chief Accountant

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