SecProbe.io

UNITED STATES
SECURITIES  AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE

September 13, 2010

Via U.S. Mail and Facsimile

Jorge Scarinci Financial and Investor Relations Manager Macro Bank, Inc. 401 Sarmiento, 4th Floor Buenos Aires—C1041AAI, Argentina
Re: Macro Bank, Inc.
 Form 20-F for Fiscal Year Ended December 31, 2009
Filed June 1, 2010 File No. 001-32827

Dear Mr. Scarinci:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 20-F for Fiscal Year Ended December 31, 2009

 Item 4.  Information on the Bank

 Allocation of the Allowance for Loan Losses, page 53

1. Please revise future filings to present this information for five years as required by
Industry Guide 3.

Jorge Scarinci
Macro Bank, Inc. September 13, 2010 Page 2  Item 7.  Major Shareholders and Related Party Transactions

 B.  Related Party Tr ansactions, page 87

2. Please provide to the staff the informati on required by Item 7.B.2 of Form 20-F and
revise future filings ac cordingly.  Alternatively, confirm, if accurate, that Instruction 2 to
Item 7.B is applicable and revise future filings accordingly

Item 10.  Additional Information
 C.  Material Contracts, page 94

3. Please provide us with a detailed explanati on of the analysis you undertook to conclude
that you have no material contracts.
 Item 18.  Financial Statements

 31.  Consolidated Income Statements and Balance Sheet, page F-62

4. The Consolidated Income Statement on page  53 indicates it is presented under the
measurement methods provided by the Centra l Bank but under the US SEC disclosure
requirements.  Please tell us and revise future filings to clarify the specific nature of the
organization and development expenses you ar e amortizing and the provision for losses
other receivables and other allowance that you present in  the Consolidated Income
Statement.  Clarify the US GAAP guidance th at you relied on for your reconciliation to
US GAAP and the associated US GAAP accounting policies.
 35.  Summary of Significant Differences …, page F-68

 General

5. Please tell us and revise future filings to  provide a discussion of your accounting policy
for repurchase agreements and how it comp lies with US GAAP.  Discuss whether you
record these transactions as sale or as secured financings and, in each case, how you
determined the appropriateness of your accounting.
 35.1.  Income Taxes, page F-68

6. Please tell us and revise future filings to disc lose why it is more likely than not that you
will not realize a portion of your  deferred tax assets such that a valuation allowance is

Jorge Scarinci
Macro Bank, Inc. September 13, 2010 Page 3
required.  Clearly disclose how you determin ed the amount of the valuation allowance
that was required at each balance sheet date.
 35.2.  Exposure to Argentine Public Sect or and Private Secu rities, page F-70

7. Please provide us with a schedul e that presents securities avai lable for sale in a tabular
format that reconciles them to the balan ce sheet in footnote 31 and that includes the
disclosure requirements of ASC 320-10-50-2.  Similarly, please addr ess the disclosure
requirements of ASC 320-10-50 s ub paragraphs 6 and 7.  Revise  future filings to include
this information.  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact Paul Cline,  Staff Accountant, at (202)  551-3851 or Kevin W. Vaughn,
Accounting Branch Chief, at (202) 551-3494 if you have questions regarding comments on the
financial statements and related matters.  Plea se contact Matt McNair, Attorney-Adviser, at
(202) 551-3583 or me at (202) 551- 3366 with any other questions.

Sincerely,

Michael Seaman Special Counsel