SecProbe.io

CORRESP
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        VIA EDGAR

        July 5, 2013

        .

Michael Clampitt

Senior Attorney

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re. Banco Macro S.A.

  Form 20-F for Fiscal Year Ended December 31, 2012

  Filed April 26, 2013

  File No. 001-32827

Dear Mr. Clampitt:

By letter dated June 10, 2013, the staff
of the Securities and Exchange Commission (the “Staff”) provided certain comments related to the annual report
on Form 20-F for the fiscal year ended December 31, 2012 (the “2012 Form 20-F”) filed by Banco Macro S.A. (Macro
Bank, Inc.) (the “Company”) with the Securities and Exchange Commission (the “Commission”)
on April 26, 2013. In response to the Staff’s comments, the Company submits the responses below.

For your convenience, the Company
has reproduced below in italics the Staff’s comments and has provided responses immediately below the comments.

Comment No. 1

General

  1. We note that you filed an 8-A12B for the Class B ordinary shares on March 3, 2006. Therefore,
it appears that you should be listing such shares on the Form 20-F as “Securities registered or to be registered pursuant
to Section 12(b) of the Act.” Please explain why you have not done so. In addition, please tell us how you concluded that
there is a reporting obligation pursuant to Section 15(d) of the Act for the 9.75% junior subordinated bonds.

Response to Comment No. 1

The Company respectfully notes that it has listed
its Class B ordinary shares as “Securities registered or to be registered pursuant to Section 12(b) of the Act” on
the cover of the 2012 Form 20-F.

The Company’s 9.75% junior subordinated bonds
(the “9.75% Bonds”) were offered pursuant to a registration statement on Form F-4 under the Securities Act of
1933, as amended (the “Securities Act”), that became effective on August 16, 2007.  Although the Company’s
reporting obligation pursuant to Section 15(d) of the Act in connection with its 9.75% Bonds is suspended because other securities
of the Company registered pursuant to Section 12(b) of the Act are outstanding, the Company has included specific disclosure referring
to the 9.75% Bonds in its annual reports on Form 20-F, under “Item 3—Risk Factors” and “Item 9—The
Offer and Listing,” among others.  For these reasons, the Company has elected to list the 9.75% Bonds as “Securities
for which there is a reporting obligation pursuant to Section 15(d) of the Act,” notwithstanding the fact that such obligation
is currently suspended.

Comment No. 2

Item 4. Information on the Bank

B. Business Overview

Banking Regulation and Supervision

Limits for affiliated individuals, page 42

2. We note your disclosure on page 43 that
the Central Bank has placed certain restrictions on financial institutions whose notes are rated below “BB” by a local
rating agency. Please tell us whether your notes are currently rated above or below this threshold, and explain whether the restrictions
apply to you. If they do, please revise future filings to note this fact, and include a discussion of how such restrictions impact
your financial assistance granted to related parties. If applicable, please include a draft of your revised disclosures to be made
in future filings in response to this comment.

Response to Comment No. 2

We respectfully note that the restrictions referred to in the
Staff’s comment apply when financial institutions seek to refinance, extend or renew financial assistance granted to “related
parties,” as such term is defined on page 93 of the 2012 Form 20-F, and such related parties have a credit rating that is
not “normal” or their notes are rated below "BB" by a local rating agency. These restrictions are determined
by reference to the ratings of the related parties rather than the ratings of the financial institutions and, therefore, the "BB"
threshold does not apply to the Company.

As requested, please note that the 9.75% Bonds are currently rated "A(Arg)+" by Fitch Argentina Calificadora de Riesgo
S.A. and "(CCC+)= Caa1.ar” by Moody’s Latin America Calificadora de Riesgo S.A. and the Company’s 8.50%
Notes due 2017 are currently rated “AA (Arg)” by Fitch Argentina Calificadora de Riesgo S.A. and “(A)=A2.ar”
by Moody’s Latin America Calificadora de Riesgo S.A.

Comment No. 3

Financial Statements

Note 33.2. Exposure
to Argentine Public Sector and Private Securities

(a) Loans – Non-financial
federal government sector, pages F-65-F-66

3. Please tell us and expand the note in
future filings to provide all the disclosures required by ASC 310-30-50 with regard to loans and debts acquired with deteriorated
credit quality.

Response to Comment No. 3

The Company has reviewed the disclosure requirements of ASC
310-30-50 on loans and debts acquired with deteriorated credit quality.

Taking into account the terms of loans to the non-financial
federal government sector acquired with deteriorated credit quality and considering that, historically, the government has not
prepaid them, the Company does not expect prepayments to occur and, therefore, has concluded that under ASC 310-30-50-1 such prepayments
need not be considered in the determination of contractual cash flows and cash flows expected to be collected.

The following table (prepared in accordance with ASC 310-30-50-2
(a.1)) presents the outstanding balance of loans to the non-financial federal government sector acquired with deteriorated credit
quality and related carrying amount at the beginning and end of each year:

    Outstanding balance (*)
    Carrying amount

    Year ended
December 31,
    Year ended

December 31,

    2012
    2011
    2012
    2011

     (in thousands of pesos)

    Beginning of the year
      308,966
      280,629
      112,602
      104,656

    End of year
      325,548
      308,966
      119,883
      112,602

(*) includes the undiscounted sum of all amounts, including
principal, interest, fees and CER adjustments (benchmark stabilization coefficient) under the loans owed at the reporting date.

The following table reconciles the amounts of accretable yield
of loans to the non-financial federal government sector acquired with deteriorated credit quality at the beginning and end of each
year, as required by ASC 310-30-50-2 (a.2):

    Year ended
December 31,

    2012
    2011
    2010

    (in thousands of pesos)

    Accretable yield at the beginning
      26,629
      35,757
      22,330

    Accretion
      (23,677 )
      (25,502 )
      (19,420 )

    Disposals
      (2,010 )
      -
      (385 )

    Reclassification from nonaccretable yield
      37,564
      16,374
      33,232

    Accretable yield at the end
      38,506
      26,629
      35,757

With respect to ASC 310-30-50-2 (a.3), the Company has not acquired
loans or debt securities with deteriorated credit quality during 2012, 2011 and 2010.

The Company notes that it applies the income recognition model
required by ASC 310-30. Therefore, the disclosures required by ASC 310-30-50-2 (a.4) do not apply to the Company.

In addition, the following table presents the activity in the
allowances required by ASC 310-30-50-2 (b) in connection with loans to the non-financial federal government sector acquired with
deteriorated credit quality:

    Allowances for Loans acquired with Deteriorated Credit Quality

    Year ended
December 31,

    2012
    2011
     2010

    (in thousands of pesos)

    Beginning balance
      -
      20
      147

    Provision for loan losses
      4,294
      -
      20

    Recoveries
      -
      (20 )
      (147 )

    Ending balance
      4,294
      -
      20

The Company takes note of the Staff´s comment and will
expand the relevant note in future filings to include the applicable disclosures described in the previous paragraphs.

Comment No. 4

Financial Statements

Note 33.2. Exposure
to Argentine Public Sector and Private Securities

(b) Government Securities, (c) Instruments
issued by Central Bank of Argentina and (d) Securities in financial trust, pages F-66-F-69

4. Please tell
us and expand the note in future filings to provide the disclosures required by ASC 320-10-50-6-8 with regard to investments in
an unrealized loss position at 12/31/12 and 12/31/11. In addition, state the basis on which the cost of a security sold was determined
pursuant to ASC 320-10-50-9 (b).

Response to Comment No. 4

The Company has reviewed the disclosure requirements of ASC
320-10-50-6-8.

The following table (prepared in accordance with ASC 320-10-50-6
(a.1) and (a.2) and ASC 320-10-50-7), presents the gross unrealized losses and fair value of securities classified as available
for sale by length of time for each category of securities that have been in a continuous loss position:

    Less than 12 months
    12 months or more
    Total

    Gross Unrealized losses
    Fair Value
    Gross Unrealized losses
    Fair

Value
    Gross Unrealized losses
    Fair

Value

    (in thousands of pesos)

    December 31, 2012

    Government securities
      (21 )
      42,760
      (173 )
      47,233
      (194 )
      89,993

    Instruments issued by Central Bank of Argentina
      (31 )
      50,781
      -
      -
      (31 )
      50,781

    Securities in financial trust and other
      (3,856 )
      130,260
      (3,734 )
      60,789
      (7,590 )
      191,049

    Total
      (3,908 )
      223,801
      (3,907 )
      108,022
      (7,815 )
      331,823

    December 31, 2011

    Government securities
      (2,042 )
      46,247
      -
      -
      (2,042 )
      46,247

    Instruments issued by Central Bank of Argentina
      (41 )
      4,078
      -
      -
      (41 )
      4,078

    Securities in financial trust and other
      (12,474 )
      276,485
      (2,603 )
      46,101
      (15,077 )
      322,586

    Total
      (14,557 )
      326,810
      (2,603 )
      46,101
      (17,160 )
      372,911

For purposes of determining whether the decline in fair value
for these categories of securities qualifies as “other than temporary impairment,” the Company has considered the following
factors:

 · The decline in fair value is not attributable to credit quality. It solely derives from adverse interest rate fluctuations
of observable inputs of similar instruments according to their fair value hierarchy.

 · Future principal payments will be sufficient to recover the current amortized cost of these investments.

 · The Company has the intention to hold these securities at least until their fair value recovers to a level that exceeds their
amortized cost.

 · The extent to which the fair value has been less than the amortized cost is not relevant for these
categories of securities.

The Company has concluded that the decline in fair value for
these securities does not qualify as “other than temporary impairment.” Consequently, the disclosure requirements of
ASC 320-10-50-8 do not apply.

Pursuant to ASC 320-10-50-9 (b), the Company notes that the
specific identification method was used in order to determine the cost of securities sold.

The Company takes note of the Staff´s comment and will
expand the relevant note in future filings to include the applicable
disclosures described in the previous paragraphs.

Comment No. 5

Financial Statements

Note 33.4 Allowance for Loan Losses, pages F-69-F-78

5. Please tell
us and expand the note in future filings to provide the following information:

 · The basis of accounting for loans pursuant to ASC 310-10-50-2 (a)

 · The accounting policies for off balance sheet credit exposures pursuant to ASC 310-10-50-9
&10

 · The amount of foreclosed and repossessed assets pursuant to ASC 310-10-50-11

 · A discussion of the risk characteristics relevant to each portfolio segment pursuant to ASC 310-10-50-11B (a) (2)

 · A description of the policy for charging off uncollectible financing receivables pursuant to ASC 310-20-50-11B (b)

 · By portfolio segment, qualitative information about how modifications/defaults are factored into the determination of the
allowance for credit losses pursuant to ASC 310-10-50-33 and 34 (b)

Response to Comment No. 5

In response to your comments regarding disclosures relating
to allowances for loan losses, the Company has reviewed the relevant ASC requirements.

 · The basis of accounting for loans pursuant to ASC 310-10-50-2 (a)

According to ASC-310-10-50-2 (a), loans are measured
at their amortized cost using the effective interest rate, after deduction of any allowance for loan losses.

 · The accounting policies for off balance sheet credit exposures pursuant to ASC 310-10-50-9 & 10

In the normal course of business, the Company enters
into transactions involving off balance sheet financial instruments to handle risk management and meet trading and financing needs
of its customers and for the Company’s proprietary trading and assets and liabilities management purposes.

In determining whether to enter
into transactions involving off balance sheet financial instruments, the Company follows the credit policies it uses to grant loans.

The management of the Company believes
that the outstanding off balance sheet items do not represent an unusual credit risk.

The Company’s exposure to credit loss in the event
of the counterparties’ failure to fulfill their commitments to extend credit or their obligations under guarantees granted
and foreign trade acceptances is represented by the contractual notional amount of these instruments. For further information see
Note 33.12 to the Company’s audited consolidated financial statements as of and for the three years ended December 31, 2012.

The process to determine allowances for off balance
sheet credit exposures is similar to the methodology used for loans (see Note 33.4 to the Company’s audited consolidated
financial statements as of and for the three years ended December 31, 2012). The provision charged to expense is determined by
management based upon client classification, actual loss experience, current and expected economic conditions, delinquency aging
and evaluation of probable losses in the current credit portfolio. Any probable loss amounts are recognized as allowances in the
consolidated balance sheet.

 · The amount of foreclosed and repossessed assets pursuant to ASC 310-10-50-11

The Company had foreclosed assets, for an amount of
6,064 and 10,489 (in thousands of pesos) as of December 31, 2012 and 2011, respectively, as described in Note 24.2 to the Company´s
audited consolidated financial statements as of and for the three years ended December 31, 2012.

The Company did not hold any repossessed assets as of
December 31, 2012 and 2011.

 · A discussion of the risk characteristics relevant to each portfolio segment pursuant to ASC 310-10-50-11B (a) (2)

The Company’s retail portfolio consists principally
of personal loans and credit card loans. Personal loans include mainly financing granted to clients under the “Plan Sueldo”
payroll services. Clients enrolled in this type of services receive their wages directly through their accounts at the Company.
Payments on such loans are debited directly from the clients’ wages on the due date. The most significant factors affecting
the Company’s retail portfolio’s credit risk are employment rates and real wages.

The Company’s commercial portfolio is currently
diversified among clients of different size (small, medium-sized businesses and corporations) and who are active in different economic
sectors (mainly the agricultural, food, services and construction sectors - see Note 22 to the Company’s audited consolidated
financial statements as of and for the three years ended December 31, 2012). The risks associated with this portfolio are principally
related to the specific economic performance of each individual client and to economic factors, such as the price and demand of
products and services and competitiveness, among others.

The Company implements monitoring, control and risk-m