United States securities and exchange commission logo
April 5, 2024
Anna Cross
Group Finance Director
Barclays PLC
1 Churchill Place
London E14 5HP, England
Re: Barclays PLC
Form 20-F for the
fiscal year ended December 31, 2023
Filed February 20,
2024
File No. 001-09246
Dear Anna Cross:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 20-F for the fiscal year ended December 31, 2023
Financial Review, page 300
1. We note your disclosure
on pages 304, 308 and 315 related to the material impact of gross
and net structural
hedge contributions on net interest income. Please revise future filings
to provide a separately
captioned section discussing the structural hedge and the impact on
financial results. In
your disclosure, please address the following bullet points and provide
any other appropriate
information:
the specific
interest rate risk being hedged (e.g., decrease in net interest income from
decreasing interest
rates) during each period presented and a description of the
underlying causes
of the specific risk (e.g., net assets with variable interest rates);
the type of
financial instruments and derivatives you used to hedge this risk (e.g.,
receive fixed/pay
variable swaps) during each period presented and in what interest
rate scenarios the
hedges result in gains or losses;
clarify if the
derivatives used are settled daily and reconcile the notional amount of
Anna Cross
Barclays PLC
April 5, 2024
Page 2
246bn disclosed on page 315 to the table on page 355 in Note
14;
clearly describe how you account for the structural hedges;
if you use hedge accounting, please provide us an accounting
analysis detailing how
your policies are consistent with the guidance in IFRS 9;
for each period presented, quantify in a tabular format any
material gains or losses
recognized by line item in the statement of comprehensive income
from the structural
hedges and reconcile these amounts to the amount disclosed on
page 360 related to
the amount of cash flow hedges of interest rate risk recycled to
net interest income;
for each period presented, provide a discussion of the
underlying economic drivers
that resulted in the gains or losses detailed in the prior bullet
point and to the extent
needed, discuss how the accounting impacts the amounts recognized
in each line item
in the statement of comprehensive income;
clarify the extent that economic risk management objectives and
strategies changed
during each period presented, the impact of these changes on the
structural hedges,
the impact of these changes on the accounting (e.g.,
de-designation and new
designations) and the impact of these changes on gains and/or
losses recognized;
clearly discuss how gross and net contributions from the
structural hedges are
measured and presented in the statement of comprehensive income;
and
reconcile the gross and net structural hedge contributions
disclosed on page 315 to
the amounts presented in the tabular format in response to the
prior bullet point above
if not apparent.
Please provide us your proposed revised disclosure based on financial
results and the
structural hedges in place during 2023.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact Benjamin Phippen at 202-551-3697 or Michael Volley at
202-551-3437
with any questions.
FirstName LastNameAnna Cross Sincerely,
Comapany NameBarclays PLC
Division of
Corporation Finance
April 5, 2024 Page 2 Office of
Finance
FirstName LastName