CORRESP 1 filename1.htm Request for Extension - Part 2


                            

September 5, 2013
                                    

VIA EDGAR

Ms. Sasha Pechenik
Division of Corporation Finance
Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549


Invesco Ltd.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2012
FILE NUMBER: 1-13908

Dear Ms. Pechenik;

This letter sets forth the request of Invesco Ltd. (the “Company”) for an extension of the deadline for our response to your comment letter, dated July 31, 2013, relating to the Annual Report on Form 10-K of the Company for the fiscal year ended December 31, 2012, filed with the Securities and Exchange Commission (the “Commission”) on February 22, 2013.

The Company would like to respond to the Commission's comment letter by September 13, 2013. We believe that this additional time is needed to internally discuss and review the Company's responses to your comments.

If you have any questions regarding this letter, please do not hesitate to call me, Rod Ellis, at (404) 479-2919.
    
Very truly yours,

 
/s/ Roderick Ellis
 
     Roderick Ellis, Group Controller and Chief Accounting Officer
 
 

cc:
Martin L. Flanagan, CEO and President
Loren Starr, CFO