June 14, 2019

Loren Starr
Senior Managing Director and Chief Financial Officer
Invesco Ltd.
1555 Peachtree Street, N.E.
Suite 1800
Atlanta, GA 30309

       Re: Invesco Ltd.
           Form 10-Q for the Quarterly Period Ended March 31, 2019
           Filed April 25, 2019
           File No. 001-13908

Dear Mr. Starr:

      We have reviewed your filing 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.

Form 10-Q for the Quarterly Period Ended March 31, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Schedule of Non-GAAP Information
Reconciliation of Operating revenues to Net revenues, page 45

1.    We note that you deduct third party distribution, service and advisory
expenses to arrive at
      an adjusted measure of net revenues, which is then used to calculate an
adjusted operating
      margin and net revenue yield on AUM. Considering that you are required to
present
      revenue and related costs on a gross basis in accordance with GAAP,
presenting them
      otherwise may violate Rule 100(b) of Regulation G by substituting
individually tailored
      recognition and measurement methods for those of GAAP. Please explain to
us how you
      considered whether your current presentation complies with Regulation G
and Question
      100.04 of the Compliance and Disclosure Interpretations on Non-GAAP
Financial
      Measures or revise your future filings to exclude this adjustment.
 Loren Starr
Invesco Ltd.
June 14, 2019
Page 2

        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 Lory Empie, Staff Accountant, at (202) 551-3714 or Robert
Klein, Staff
Accountant, at (202) 551-3847 with any questions.



FirstName LastNameLoren Starr                             Sincerely,
Comapany NameInvesco Ltd.
                                                          Division of
Corporation Finance
June 14, 2019 Page 2                                      Office of Financial
Services
FirstName LastName