Mail Stop 4561

December 2, 2005

Walter Bayly
Chief Financial and Accounting Officer
Credicorp Ltd.
Calle Centenario 156
La Molina
Lima 12, Peru

RE:	Credicorp Ltd.
Form 20-F for Fiscal Year Ended December 31, 2004
Filed June 30, 2005
File No. 1-14014

Dear Mr. Bayly,

	We have reviewed your letter filed on October 21, 2005 and
the
above referenced filing and have the following comments.  We note
your confirmation that you will amend your Form 20-F based on our
comments.  Where indicated, we think you should revise your
proposed
revisions in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable.
Please be as detailed as necessary in your explanation.  We
welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Loan Portfolio, page 65

1. We note your proposed disclosure in response to comment 2 of
our
letter dated September 22, 2005.  Please expand the proposed
disclosure to clarify that you do not track loan write-offs and
recoveries of write-offs by loan category and therefore are unable
to
provide all of the disclosures required by Item IV.A of Industry
Guide 3.  If in the future you do track write-offs and recoveries
of
write-offs by loan category, please make the disclosures required
by
Industry Guide 3.

2. In your proposed disclosure in response to comment 4 of our
letter
dated September 22, 2005, you state that you have recognized
interest
income on past due loans of US$11.0 million in 2003 and US$6.2
million in 2004. We further note that these amounts differ from
those
disclosed in the first paragraph on page 74 of your filing.
Please
revise your proposed disclosure to reconcile the different amounts
or
advise us.

Contractual Obligations, page 98

3. We note your proposed disclosure in response to comment 5 of
our
letter dated September 22, 2005.  Please revise your proposed
contractual obligations table in Appendix D of your response to
also
include all long term debt obligations and long term time
deposits.
We note that Note 11 discloses long term time deposits and Note 14
discloses long term bonds.

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  Please furnish a cover letter with your
amendment
that keys your responses to our comments and provides any
requested
information.  Detailed cover letters greatly facilitate our
review.
Please file your letter on EDGAR.  Please understand that we may
have
additional comments after reviewing your responses to our
comments.

	You may contact Michael Volley, Staff Accountant, at (202)
551-
3437 or me at (202) 551-3423 if you have questions regarding our
comments.

Sincerely,



Amit Pande
Assistant Chief Accountant

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Walter Bayly
Credicorp Ltd.
December 2, 2005
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