SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

                                                                      September 13, 2010
 Mr. Loren M. Starr Chief Financial Officer Invesco Ltd. 1555 Peachtree Street N.E., Suite 1800 Atlanta, Georgia 30309
 RE: Invesco Ltd.
Form 10-K for the Year Ended December 31, 2009
Forms 10-Q for the Periods Ended March 31, 2010 and
June 30, 2010
Definitive Proxy Statement on  Schedule 14A filed on
March 29, 2010 Prospectus Supplement filed on May 20, 2009 File No. 1-13908

Dear Mr. Starr:

We have reviewed your response letter dated August 20, 2010 and have the
following comment.
Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your
response.     After reviewing the information you provide  in response to this comment, we may
have additional comments.
Form 10-Q for the Period Ended June 30, 2010

 Condensed Consolidated Statement of Changes in Equity, page 6

 1. We have read your response to comment  15 from our letter dated June 11, 2010 and
reviewed your Condensed Consolidated Stat ement of Changes in Equity.  In future
filings, please revise your C ondensed Consolidated Statement of Changes in Equity
to include the following:
• A “total column” immediat ely prior to your “noncontrolling interest column”
that adds your equity attribut able to common shareholders;

Mr. Loren M. Starr
Invesco Ltd. September 13, 2010 Page 2
• Your line item “Net income, including gains and losses attributable to
noncontrolling interest” shoul d appropriately allocate the “(Gains)losses
attributable to noncontrolling interests in consolidated entities, net”  and “Net
income attributable to common shareholde rs” so that they agree to the amounts
presented on your stat ements of income;
• Please include your $37.1 of currency tran slation difference on investments in
overseas subsidiaries under your noncontrolling interest column;
• Please present total comprehensive inco me for the parent and noncontrolling
interest in consolidated entities in  accordance with ASC 810-10-50-1A; and
• Please show the allocation of $277.4 million and $37.1 million to Retained
Earnings Appropriated for Investors in  Consolidated Investments Products
below the total comprehensive income line item.  This could be achieved in two separate adjustments or one adjustment  as long as the description clearly
describes what each adjustment represents.
Please supplementally show us what your revised disclosure will look like.

You may contact Ernest Greene, Staff Accountant at (202) 551-3733 or Jeanne
Baker, Assistant Chief Accountant at (202)  551-3691 if you have questions regarding
comments on the financial statements and rela ted matters.  Please contact Hagen Ganem,
Staff Attorney at (202) 551- 3330 or Dietrich Kin g, Staff Attorney at (202) 551-3338 with
any other questions.         Sincerely,            R u f u s  D e c k e r
       Accounting Branch Chief