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[Letterhead of Bancolombia]

January 3, 2020

Via EDGAR

U.S. Securities and Exchange Commission

Office of Financial Services

100 F Street, N.E.

Washington, D.C. 20549, U.S.A.

Attn: Mr. David Irving

 Re: Bancolombia S.A.

Form 20-F for the Fiscal Year Ended December 31, 2018

Filed April 25, 2019

File No. 001-32535

Dear Mr. Irving,

By letter dated December 20, 2019, the staff
of the Securities and Exchange Commission (the “Staff” and the “Commission,” respectively) provided  comments
on Bancolombia S.A.’s Annual Report on Form 20-F for the fiscal year ended December 31, 2018. In response to the Staff’s
comments, and on behalf of Bancolombia S.A. and its consolidated subsidiaries (collectively, “Bancolombia”), we hereby
submit the responses below.

For your convenience, the Staff’s comments
have been repeated below in their entirety, with Bancolombia’s responses set out immediately underneath.

Form 20-F for the Fiscal Year Ended December 31, 2018

Liquidity
and Capital Resources, page 121

 1. Please
disclose in future filings, the contractual interest rates for borrowings from other financial institutions, including if you
have any Libor exposure and the potential impact to your financial statements from the expected discontinuation of Libor. Please
also include a risk factor concerning your Libor exposure, as appropriate.

Response: Bancolombia
will include the requested contractual interest rates in future filings, including, to the extent material, a risk factor concerning
Bancolombia’s LIBOR exposure.

Notes
to Consolidated Financial Statements

Note
6. Loans and Advances to Customers and Financial Institutions, net, page F-87

 2. We
note your disclosure on page F-88 in footnote (2) that, the provision for loan losses, net COP 4,311,485 differs from the COP
3,851,625 presented in the income statement due to the recovery of charged-off loans of COP 459,860. In future filings, please
disclose the nature of charged-off loans of COP 459,860 and why they are not included in the allowance for loan loss rollforward.

Mr. David Irving

Response: In future
filings Bancolombia will include the nature of charged-off loans as to which there was a recovery during the financial year for
which information is presented and, as appropriate, will either reflect such amounts in the allowance for loan loss rollforward
or disclosure why such amounts are not so included.

 3. In future filings, please disaggregate the “significant
changes in the provision in accordance with IFRS 9” table presented on page F-89 by portfolio type (i.e. commercial, consumer,
etc.). Additionally, please disaggregate “net remeasurement of loss allowance” between remeasurement due to changes
in economic factors and model inputs as well as model changes. Refer to IFRS 7.35(B) and (F), 7.B.8 and 7.35I.

Response: In future
filings Bancolombia will disaggregate the “significant changes in the provision in accordance with IFRS 9” table by portfolio
type. Additionally, Bancolombia will disaggregate “net remeasurement of loss allowance” between remeasurement due to
changes in economic factors and model inputs as well as model changes.

Bancolombia is grateful for your assistance
in this matter. Bancolombia trusts that its response adequately address the Staff’s comments. If the Staff has any questions
concerning this letter or requires further assistance, please do not hesitate to contact me at joacosta@bancolombia.com.co or Alejandro
Mejía Jaramillo at almejia@bancolombia.com.co.

    Sincerely,

    /s/ José Humberto Acosta

    Name: José Humberto Acosta

    Title: Chief Financial Officer

 cc: Robert S. Risoleo

(Sullivan & Cromwell LLP)

Joaquin Molina

(PricewaterhouseCoopers Ltda.)

Michelle Miller

(Securities and Exchange Commission)