June 10, 2019

Katie Murray
Chief Financial Officer
Royal Bank of Scotland Group plc
RBS Gogarburn, PO Box 1000
Edinburgh EH12 1HQ, United Kingdom

       Re: Royal Bank of Scotland Group plc
           Form 20-F Filed February 28, 2019
           Response Dated June 6, 2019
           File No. 001-10306

Dear Ms. Murray:

        We have reviewed your June 6, 2019 response to our comment letter and
have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

      After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
May 22, 2019 letter.

Form 20-F filed February 28, 2019

Non-GAAP financial information, page 2

1.    We note your response to prior comment 1. It is unclear how your proposed
revised
      disclosure for certain non-GAAP measures meets the disclosure
requirements in Item
      10(e)(1)(i)(B) of Regulation S-K. Please note that the most directly
comparable GAAP
      measure should be quantified and the reconciliation should clearly
identify and quantify
      the differences between the non-GAAP measure and the most directly
comparable GAAP
      measure. This typically is presented as a reconciling schedule starting
with the most
      directly comparable GAAP amount, listing in appropriate detail the
differences, and
      ending with the non-GAAP amount. Therefore, please revise future filings
accordingly.
      Please refer to Item 10(e)(1)(i)(B) of Regulation S-K for guidance.
 Katie Murray
Royal Bank of Scotland Group plc
June 10, 2019
Page 2

       You may contact Michael Volley, Staff Accountant, at 202-551-3437 or
John Nolan,
Senior Assistant Chief Accountant, at 202-551-3492 with any questions.



FirstName LastNameKatie Murray                          Sincerely,
Comapany NameRoyal Bank of Scotland Group plc
                                                        Division of Corporation
Finance
June 10, 2019 Page 2                                    Office of Financial
Services
FirstName LastName