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                              November 28, 2023

       Jose Humberto Acosta Martin
       Chief Financial Officer
       Bancolombia S.A.
       Carrera 48 # 26-85, Avenida Los Industriales
       Medellin, Colombia

                                                        Re: Bancolombia S.A.
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2022
                                                            Filed April 3, 2023
                                                            File No. 001-32535

       Dear Jose Humberto Acosta Martin:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments.

              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, 2022

       Table of Contents, page 3

   1.                                                   We note your reference
to a section for the general discussion of changes in results of
                                                        2020 versus 2019.
Please revise your future filings to identify the correct periods.
       Allowance for credit losses to total loans, page 84

   2.                                                   We note your table
presenting allowance for credit losses to total loans ratios of 5.73%
                                                        and 7.20% for the years
ending December 31, 2022 and 2021, respectively. Please
                                                        enhance your
disclosures, in future filings, to provide a more fulsome discussion of
                                                        changes in the ratio
between the periods presented. For example, include a discussion,
                                                        with accompanying
quantitative and qualitative details, describing trends, indicators and
                                                        directional changes in
credit quality and other economic factors in order to explain the
                                                        reasons for the
increase or decrease in the ratios between the periods presented.
 Jose Humberto Acosta Martin
Bancolombia S.A.
November 28, 2023
Page 2
Fees and commission income, net, page 91

3.       We note your discussion of changes in your net fees and commission
income between the
         years ended December 31, 2022 and 2021. Please enhance your
discussion, in future
         filings, for the following:
             Discuss separately changes in your gross fee and commission income
and expense
              line items, rather than only on a net basis.
             Describe and quantify the extent to which such changes are
attributable to changes in
              rates (e.g., the interbank rate) versus changes in volume of
activity. Refer to Item
              303(b)(2)(iii) of Regulation S-K.
             To the extent applicable, provide quantitative and qualitative
discussion of any fees
              or costs to which you are unable or it is more difficult to pass
onto the end customer.
              In this regard, we note that the fee and commission expenses
appear to have increased
              at a faster rate than the fee and commission income from 2021 to
2022.
Critical Accounting Policies and Estimates, page 112

4.       We note your disclosure of critical accounting policies and estimates
only cross-references
         to your summary of significant accounting policies disclosures within
the financial
         statement footnotes. In future filings, please enhance your disclosure
to provide qualitative
         and quantitative information necessary to understand the estimation
uncertainty and the
         impact your critical accounting estimates have had or are reasonably
likely to have on
         your financial condition and results of operations. In addition,
discuss how much each
         estimate and/or assumption has changed over a relevant period and the
sensitivity of
         reported amounts to the underlying methods, assumptions and estimates
used. The
         disclosures should supplement, not duplicate, the description of
accounting policies or
         other disclosures in the notes to the financial statements. Refer to
Item 303(b)(3) of
         Regulation S-K and SEC Release No. 33-8350.
       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 Sarmad Makhdoom at 202-551-5776 or Robert Klein at
202-551-3847
with any questions.



FirstName LastNameJose Humberto Acosta Martin                  Sincerely,
Comapany NameBancolombia S.A.
                                                               Division of
Corporation Finance
November 28, 2023 Page 2                                       Office of
Finance
FirstName LastName