TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo April 13, 2023 L. Allison Dukes Senior Managing Director and Chief Financial Officer Invesco Ltd. 1555 Peachtree Street, N.E., Suite 1800 Atlanta, GA 30309 Re: Invesco Ltd. Form 10-K for the Fiscal Year Ended December 31, 2022 Filed February 23, 2023 File No. 001-13908 Dear L. Allison Dukes: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Finance