December 20, 2019

Juan Carlos Mora Uribe
Chief Executive Officer
Bancolombia SA
Carrera 48 # 26-85, Avenida Los Industriales
Medellin, Colombia

       Re: Bancolombia SA
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Filed April 25, 2019
           File No. 001-32535

Dear Mr. Uribe:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 20-F for the Fiscal Year Ended December 31, 2018

Liquidity and Capital Resources, page 121

1.    Please disclose in future filings, the contractual interest rates for
borrowings from other
      financial institutions, including if you have any Libor exposure and the
potential impact to
      your financial statements from the expected discontinuation of Libor.
Please also include
      a risk factor concerning your Libor exposure, as appropriate.
Notes to Consolidated Financial Statements
Note 6. Loans and Advances to Customers and Financial Institutions, net, page
F-87

2.    We note your disclosure on page F-88 in footnote (2) that, the provision
for loan losses,
      net COP 4,311,485 differs from the COP 3,851,625 presented in the income
statement due
      to the recovery of charged-off loans of COP 459,860. In future filings,
please disclose the
      nature of charged-off loans of COP 459,860 and why they are not included
in the
      allowance for loan loss rollforward.
 Juan Carlos Mora Uribe
Bancolombia SA
December 20, 2019
Page 2




3.       In future filings, please disaggregate the "significant changes in the
provision in
         accordance with IFRS 9" table presented on page F-89 by portfolio type
(i.e. commercial,
         consumer, etc.). Additionally, please disaggregate "net remeasurement
of loss allowance"
         between remeasurement due to changes in economic factors and model
inputs as well as
         model changes. Refer to IFRS 7.35(B) and (F), 7.B.8 and 7.35I.
       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.

       You may contact Michelle Miller at 202-551-3368 or Dave Irving at
202-551-3321 with
any questions.



FirstName LastNameJuan Carlos Mora Uribe                     Sincerely,
Comapany NameBancolombia SA
                                                             Division of
Corporation Finance
December 20, 2019 Page 2                                     Office of Finance
FirstName LastName