UNITED STATES
SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-K

(Mark One)

Commission File Number of issuing entity: 333-182087-01, 333-197848, 333-200980, 333-205943, 333-228394
Central Index Key Number of issuing entity: 0001552111

BARCLAYS DRYROCK ISSUANCE TRUST

(Exact Name of Issuing Entity as Specified in Its Charter)
(Issuer of the Notes)

Central Index Key Number of depositor: 0001551964

BARCLAYS DRYROCK FUNDING LLC

(Exact Name of Depositor as Specified in Its Charter)

Central Index Key Number of sponsor: 0001551423

BARCLAYS BANK DELAWARE

(Exact Name of Sponsor as Specified in Its Charter)

Delaware

(State or Other Jurisdiction of Incorporation
or Organization of the Issuing Entity)

c/o Wilmington Trust, National Association
Rodney Square North
1100 North Market Street
Wilmington, DE 19890

(Address of Principal Executive Offices
of Issuing Entity)

(302) 651-1000

(Telephone number, including area code)

30-6324196

(I.R.S. Employer Identification No.)

Not Applicable
(Former name, former address, if changed since last report)

Securities registered pursuant to Section 12(b) of the Act: None

Securities registered pursuant to Section 12(g) of the Act: None

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. [_] Yes [X] No

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. [_] Yes [X] No

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.
[X] Yes [_] No

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§ 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files). [X] Yes [_] No

Indicate by check mark if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K (§ 232.405 of this chapter) is not contained herein, and will not be contained, to the best of registrant’s knowledge, in definitive proxy or information statements incorporated by reference in Part III of this Form 10-K or any amendment to this Form 10-K. [X]

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

Large accelerated filer [_]
Accelerated filer [_]
Non-accelerated filer [X]
Smaller reporting company [_]
Emerging growth company [_]

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. [_]

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act).
[_] Yes [X] No

State the aggregate market value of the voting and non-voting common equity held by non-affiliates computed by reference to the price at which the common equity was last sold, or the average bid and asked price of such common equity, as of the last business day of the registrant’s most recently completed second fiscal quarter.

PART I

The following Items have been omitted in accordance with General Instruction J to Form 10–K:

Item 1B. Unresolved Staff Comments.

Not Applicable.

Item 4: Mine Safety Disclosures.

Not Applicable.

PART II

The following Items have been omitted in accordance with General Instruction J to Form 10–K:

Item 9B: Other Information.

None.

PART III

The following Items have been omitted in accordance with General Instruction J to Form 10–K:

PART IV

Item 15. Exhibits, Financial Statement Schedules.

(a)(1)       Not Applicable.

(a)(2)       Not Applicable.

(a)(3)       

(b)       Exhibit list.

Item 16. Form 10-K Summary.

Not applicable.

Substitute information provided in accordance with General Instruction J to Form 10–K:

Item 1112(b) of Regulation AB. Significant Obligors of Pool Assets (Financial Information).

Not applicable.

Item 1114(b)(2) of Regulation AB: Credit Enhancement and Other Support, Except for Certain Derivatives Instruments (Financial Information).

Not applicable.

Item 1115(b) of Regulation AB: Certain Derivatives Instruments (Financial Information).

Not applicable.

Item 1117 of Regulation AB: Legal Proceedings.

There are no legal proceedings pending (or proceedings known to be contemplated by governmental authorities) against any of Barclays Bank Delaware, Barclays Dryrock Funding LLC, U.S. Bank National Association, Wilmington Trust, National Association or Barclays Dryrock Issuance Trust, or of which any property of the foregoing is subject, that are material to holders of the notes.

Item 1119 of Regulation AB: Affiliations and Certain Relationships and Related Transactions.

Information required by Item 1119 of Regulation AB has been omitted from this report on Form 10-K in reliance on the Instruction to Item 1119.

Item 1122 of Regulation AB: Compliance with Applicable Servicing Criteria.

Each of BBD, Barclays Bank PLC (“BBPLC”), REMITCO LLC and U.S. Bank National Association (each, a “Servicing Participant”) has been identified by the registrant as a party participating in the servicing

function with respect to the pool assets held by the Trust. Each Servicing Participant has completed a report on an assessment of compliance with the servicing criteria applicable to such Servicing Participant (each, a “Report on Assessment”) as of, and for the period from January 1, 2018 to December 31, 2018, which Reports on Assessment are included as exhibits to this Form 10-K. In addition, each Servicing Participant has provided an attestation report (each, an “Attestation Report”) by a registered independent public accounting firm regarding its related Report on Assessment. Each Attestation Report is attached as an exhibit to this Form 10-K. No Report on Assessment or related Attestation Report has identified: (i) any material instance of noncompliance with the servicing criteria identified in such Report on Assessment as applicable to the related Servicing Participant or (ii) any material deficiency in such Servicing Participant’s policies and procedures to monitor vendor compliance.

Item 1123 of Regulation AB: Servicer Compliance Statement.

Each of BBD and BBPLC has been identified by the registrant as a servicer meeting the criteria of Item 1108(a)(2)(i), (ii) or (iii) of Regulation AB with respect to the pool assets held by the Trust. Each of these servicers has provided a statement of compliance (a “Compliance Statement”), which has been signed by an authorized officer of such related servicer. Each Compliance Statement is attached as an exhibit to this Form 10-K.

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Date: April 1, 2019

Supplemental Information to be Furnished With Reports Filed Pursuant to Section 15(d) of the Act by Registrants Which Have Not Registered Securities Pursuant to Section 12 of the Act.

No annual report or proxy materials have been sent to security holders and no such report or proxy materials are to be furnished to security holders subject to the filing of this Annual Report on Form 10-K.

Exhibit 31.1

Rule 13a-14(d)/15d-14(d) under the Securities Exchange Act of 1934 Certification
(Section 302 of the Sarbanes-Oxley Act of 2002 Certification).

CERTIFICATION

I, Sean Sievers, certify that:

1. I have reviewed this report on Form 10-K and all reports on Form 10-D required to be filed in respect of the period covered by this report on Form 10-K of Barclays Dryrock Issuance Trust (the “Exchange Act periodic reports”);

2. Based on my knowledge, the Exchange Act periodic reports, taken as a whole, do not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, all of the distribution, servicing and other information required to be provided under Form 10-D for the period covered by this report is included in the Exchange Act periodic reports;

4. I am responsible for reviewing the activities performed by the servicers and based on my knowledge and the compliance reviews conducted in preparing the servicer compliance statements required in this report under Item 1123 of Regulation AB, and except as disclosed in the Exchange Act periodic reports, the servicers have fulfilled their obligations under the servicing agreements in all material respects; and

5. All of the reports on assessment of compliance with servicing criteria for asset-backed securities and their related attestation reports on assessment of compliance with servicing criteria for asset-backed securities required to be included in this report in accordance with Item 1122 of Regulation AB and Exchange Act Rules 13a-18 and 15d-18 have been included as an exhibit to this report, except as otherwise disclosed in this report. Any material instances of noncompliance described in such reports have been disclosed in this report on Form 10-K.

In giving the certifications above, I have reasonably relied on information provided to me by the following unaffiliated parties: U.S. Bank National Association and REMITCO, LLC.

Date: March 29, 2019

Exhibit 33.1

Barclays Bank Delaware
Report on Assessment of Compliance with Servicing Criteria

1. Barclays Bank Delaware (the “Asserting Party”) is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of Regulation AB, as of and for the period from January 1, 2018 to December 31, 2018 (the “Reporting Period”), as set forth in Appendix A hereto. The transactions covered by this report include asset-backed securities transactions backed by credit card receivables, for which transactions the Asserting Party acted as servicer, that were registered with the Securities and Exchange Commission pursuant to the Securities Act of 1933, as amended, where the related asset-backed securities were outstanding during the Reporting Period (the “Platform”), as listed in Appendix B hereto;

2. The Asserting Party has engaged certain vendors, who are not considered a “servicer” as defined in Item 1101(j) of Regulation AB, to perform specific, limited or scripted activities, and the Asserting Party elects to take responsibility for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such vendor’s activities as set forth in Appendix A hereto, as permitted by Section 200.06 of the SEC Division of Corporation Finance Compliance and Disclosure Interpretations. The Asserting Party has policies and procedures in place designed to provide reasonable assurance that the vendor activities comply in all material respects with the servicing criteria applicable to such vendor.

3. Except as set forth in paragraph 4 below, the Asserting Party used the criteria set forth in paragraph (d) of Item 1122 of Regulation AB to assess the compliance by the Asserting Party, with the applicable servicing criteria;

4. The criteria listed in the column titled “Inapplicable Servicing Criteria” on Appendix A hereto are inapplicable to the Asserting Party based on the activities the Asserting Party performs, directly or through its vendors, with respect to the Platform;

5. The Asserting Party has complied, in all material respects, with the applicable servicing criteria as of December 31, 2018 and for the Reporting Period with respect to the Platform taken as a whole; and

6. KPMG LLP, a registered public accounting firm, has issued an attestation report on the Asserting Party’s assessment of compliance with the applicable servicing criteria as of December 31, 2018 and for the Reporting Period.

March 29, 2019

APPENDIX A

^{____________________________________________}

^{____________________________________________}

^{____________________________________________}

APPENDIX B

Barclays Dryrock Issuance Trust

Series 2014-3

Series 2015-1

Series 2015-2

Series 2015-4

Series 2016-1

Series 2017-1

Series 2017-2

Series 2018-1

Series 2018-VFN1

Series 2018-VFN2

Exhibit 33.2

Barclays Bank PLC

Report on Assessment of Compliance with Servicing Criteria

APPENDIX A

1Servicing criterion 1122(d)(3)(i) is applicable to the activities performed by Barclays Bank PLC with respect to the Platform; however, Barclays Bank Delaware is responsible for the signing of investor reports prepared by Barclays Bank PLC and monitors performance of Barclays Bank PLC’s preparation and filing of investor reports.

2Servicing criterion 1122(d)(3)(ii) is applicable to the activities performed by Barclays Bank PLC with respect to the Platform; however, Barclays Bank Delaware is responsible for the forwarding of allocation and remittance instructions prepared by Barclays Bank PLC to the Trustee.

APPENDIX B

Barclays Dryrock Issuance Trust

Series 2014-3

Series 2015-1

Series 2015-2

Series 2015-4

Series 2016-1

Series 2017-1

Series 2017-2

Series 2018-1

Series 2018-VFN1

Series 2018-VFN2

Exhibit 33.3

First Data.

Report of Management on Assessment of Compliance with the Securities and Exchange
Commission Regulation AB Servicing Criteria

January 18, 2019

Exhibit 33.4

Deluxe Corporation 400 Westwood Drive, Suite 100 - Wausau, Wl 54401 P.O. Box 119 • Wausau, Wl 54402-0119 715-359-0427

Management’s Report on Assessment of Compliance with SEC Regulation AB Servicing Criteria

Appendix A

Exhibit 33.5

Management's Assertion

Report on Assessment of Compliance with Applicable Servicing Criteria

U.S. Bank National Association (“U.S. Bank”) is responsible for assessing compliance as of and for the year ended December 31, 2018 with the servicing criteria set forth in Item 1122 (d) of Regulation AB applicable to it as set forth on Exhibit A hereto. This report covers asset backed securities transactions within the U.S. Bank Corporate Trust Asset-Backed Securities Platform¹ (the “Platform”)

U.S. Bank hereby provides the following report on its assessment of compliance with the servicing criteria set forth in Item 1122 of Regulation AB applicable to it and as described on Exhibit A hereto:

Date: February 28, 2010

EXHIBIT A to Management’s Assertion

² No servicing activities were performed by the Company that required the servicing criteria to be complied with.

³.No servicing activities were performed by the Company that required the servicing criteria to be complied with.

⁴ No servicing activities were performed by the Company that required the servicing criteria to be complied with.

Exhibit 34.1

Report of Independent Registered Public Accounting Firm

The Board of Directors

Barclays Bank Delaware:

We have examined management’s assertion, included in the accompanying Report on Assessment of Compliance with Servicing Criteria, that Barclays Bank Delaware (the Company or the Asserting Party) complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB (the Servicing Criteria) for the asset-backed securities transactions backed by credit card receivables, for which transactions the Asserting Party acted as servicer as of and for the year ended December 31, 2018 (the Reporting Period), that were registered with the Securities and Exchange Commission pursuant to the Securities Act of 1933, as amended, where the related asset-backed securities were outstanding during the Reporting Period (the Platform), except for servicing criteria 1122(d)(1)(iii), 1122(d)(1)(iv), 1122(d)(2)(ii), 1122(d)(2)(iii), 1122(d)(2v), 1122(d)(2)(vi), 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), and 1122(d)(4)(xv), which the Company has determined are not applicable to the activities it performs with respect to the Platform. The Company has determined that servicing criterion 1122(d)(3)(i) is applicable to the activities performed by the Company with respect to the Platform only as it relates to clauses (A) and (C), the monitoring the preparation and filing of investor reports and the signing of investor reports. The Company has determined that servicing criterion 1122(d)(3)(ii) is applicable to the activities performed by the Company with respect to the Platform only as it relates to the forwarding of allocation and remittance instructions to the trustee. Appendix B to management's Report on Assessment of Compliance with Servicing Criteria identifies the individual asset-backed transactions and securities defined by management as constituting the Platform. Management is responsible for the Company’s compliance with the Servicing Criteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliance with the Servicing Criteria based on our examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants to obtain reasonable assurance and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the Servicing Criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included testing selected asset-backed transactions and securities that comprise the Platform, testing selected servicing activities related to the Platform, and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the Servicing Criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the Servicing Criteria.

As described in the accompanying Report on Assessment of Compliance with Servicing Criteria, for servicing criteria 1122(d)(2)(i), the Company has engaged various vendors to perform the activities required by these servicing criteria. The Company has determined that none of these vendors is considered a "servicer" as defined in Item 1101(j) of Regulation AB, and the Company has elected to take responsibility for assessing compliance with the servicing criteria applicable to each vendor as permitted by the SEC's Compliance and Disclosure Interpretation (C&DI) 200.06, Vendors Engaged by Servicers (C&DI 200.06). As permitted by C&DI 200.06, the Company has asserted that it has policies and procedures in place designed to provide reasonable assurance that the vendors' activities comply in all material respects with the servicing criteria applicable to each vendor. The Company is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendors and related servicing criteria as

described in its assertion, and we performed no procedures with respect to the Company's eligibility to apply C&DI 200.06.

In our opinion, management’s assertion that Barclays Bank Delaware complied with the aforementioned Servicing Criteria, including servicing criteria 1122(d)(2)(i) for which compliance is determined based on C&DI 200.06 as described above, as of and for the year ended December 31, 2018 is fairly stated, in all material respects.

/s/ KPMG LLP

Philadelphia, Pennsylvania

March 29, 2019

Exhibit 34.2

Report of Independent Registered Public Accounting Firm

The Board of Directors

Barclays Bank plc:

We have examined management’s assertion, included in the accompanying Report on Assessment of Compliance with Servicing Criteria, that Barclays Bank plc (the Company or the Asserting Party) complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB (the Servicing Criteria) for the asset-backed securities transactions backed by credit card receivables, for which transactions the Asserting Party acted as servicer as of and for the year ended December 31, 2018 (the Reporting Period), that were registered with the Securities and Exchange Commission pursuant to the Securities Act of 1933, as amended, where the related asset-backed securities were outstanding during the Reporting Period (the Platform), except for servicing criteria 1122(d)(1)(ii), 1122(d)(1)(iii), 1122(d)(1)(iv), 1122(d)(2)(i), 1122(d)(2)(ii), 1122(d)(2)(iii), 1122(d)(2)(iv), 1122(d)(2(v), 1122(d)(2)(vi), 1122(d)(2)(vii) 1122(d)(3)(iii), 1122(d)(3)(iv), 1122(d)(4)(i), 1122(d)(4)(ii), 1122(d)(4)(iii), 1122(d)(4)(iv), 1122(d)(4)(v), 1122(d)(4)(vi), 1122(d)(4)(vii), 1122(d)(4)(viii), 1122(d)(4)(ix), 1122(d)(4x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), 1122(d)(4)(xiv), and 1122(d)(4)(xv), which the Company has determined are not applicable to the activities it performs with respect to the Platform. The Company has determined that servicing criterion 1122(d)(3)(i) is applicable to the activities performed by the Company with respect to the Platform only as it relates to the calculation of information contained in reports to investors. The Company has determined that servicing criterion 1122(d)(3)(ii) is applicable to the activities performed by the Company with respect to the Platform only as it relates to the calculation of information contained in reports to investors. Appendix B to management's Report on Assessment of Compliance with Servicing Criteria identifies the individual asset-backed transactions and securities defined by management as constituting the Platform. Management is responsible for the Company’s compliance with the Servicing Criteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliance with the Servicing Criteria based on our examination.

Our examination was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants to obtain reasonable assurance and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the Servicing Criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included testing selected asset-backed transactions and securities that comprise the Platform, testing selected servicing activities related to the Platform, and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the Servicing Criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. We believe that our examination provides a reasonable basis for our opinion. Our examination does not provide a legal determination on the Company’s compliance with the Servicing Criteria.

In our opinion, management’s assertion that Barclays Bank plc complied with the aforementioned Servicing Criteria as of and for the year ended December 31, 2018 is fairly stated, in all material respects.

/s/ KPMG LLP

Philadelphia, Pennsylvania

March 29, 2019

Exhibit 34.3

Report of Independent Registered Public Accounting Firm

First Data Resources, LLC and REMITCO, LLC

We have examined management's assertion, included in the accompanying Report of Management on Assessment of Compliance with the Securities and Exchange Commission Regulation AB Servicing Criteria, that First Data Resources LLC, and its affiliate, REMITCO LLC (jointly, "First Data" or the "Company") complied with the servicing criteria set forth in Item 1122(d)(2)(i) for the remittance processing services First Data provides in connection with loan and/or receivables portfolios that include pool assets for asset backed securities issued by Barclays Dryrock Issuance Trust that were processed at the First Data Newark and Monterey Park facilities (the "Platform"), such services being limited to the opening, listing, and depositing of remittance payments mailed to post office boxes serviced by First Data pursuant to the agreements between First Data and Wells Fargo Bank, N.A. and between Wells Fargo Bank, N.A. and Barclays Bank Delaware, for the period January 1,2018 through August 15,2018. Management is responsible for the Company's compliance with those servicing criteria. Our responsibility is to express an opinion on management's assertion about the Company's compliance with the servicing criteria based on our examination. The Company has determined the remainder of the servicing criteria set forth in Items 1122(d)(1)(i)-(v), 1122 (d)(2)(ii)-(vii), 1122(d)(3)(i)-(iv), and 1122(d)(4)(i)-(xv) are not applicable to the activities it performs with respect to the servicing platform covered by this report.

Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company's compliance with the applicable servicing criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included testing of less than all of the individual asset backed transactions and securities that comprise the platform, testing of less than all of the servicing activities related to the Platform and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the servicing criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. We believe that the evidence we obtained is sufficient and appropriate to provide a reasonable basis for our opinion.

Our examination does not provide a legal determination on the Company's compliance with the servicing criteria.

A member firm of Ernst & Young Global Limited

Building a better working world

In our opinion, management's assertion that the Company complied with the aforementioned servicing criteria for the period January 1, 2018 through August 15, 2018 for the Platform is fairly stated, in all material respects.

January 18, 2019

A member firm of Ernst & Young Global Limited

Exhibit 34.4

Exhibit 34.5

Report of Independent Registered Public Accounting Firm

The Board of Directors

U.S. Bank National Association

We have examined management’s assertion, included in the accompanying Report on Assessment of Compliance with Applicable Servicing Criteria, that U.S. Bank National Association (the “Company”) complied with the servicing criteria set forth in Item 1122(d) of the Securities and Exchange Commission’s Regulation AB for the U.S. Bank Corporate Trust Asset-Backed Securities Platform (the “Platform”), for which the Company provides trustee, securities administration, registrar and paying agent services, as of and for the year ended December 31, 2018, except for servicing criteria Items 1122(d)(1)(iii), 1122(d)(4)(i)-(ii), and 1122(d)(4)(iv)-(xiv), which the Company has determined are not applicable to the activities it performs with respect to the servicing platform covered by this report. Management is responsible for the Company’s compliance with those servicing criteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliance with the servicing criteria based on our examination.

Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants, as adopted by the Public Company Accounting Oversight Board (United States) and, accordingly, included examining, on a test basis, evidence about the Company’s compliance with the applicable servicing criteria and performing such other procedures as we considered necessary in the circumstances. Our examination included testing of less than all of the individual asset-backed transactions and securities that comprise the Platform, testing of less than all of the servicing activities related to the Platform, and determining whether the Company processed those selected transactions and performed those selected activities in compliance with the servicing criteria. Furthermore, our procedures were limited to the selected transactions and servicing activities performed by the Company during the period covered by this report. Our procedures were not designed to determine whether errors may have occurred either prior to or subsequent to our tests that may have affected the balances or amounts calculated or reported by the Company during the period covered by this report for the selected transactions or any other transactions. Although the Company is responsible for assessing compliance with Items 1122(d)(1)(ii), 1122(d)(1)(v), and 1122(d)(2)(iii) of Regulation AB, there were no servicing activities performed by the Company during the year ended December 31, 2018 that required these servicing criteria to be complied with. We believe that the evidence we obtained is sufficient and appropriate to provide a reasonable basis for our opinion.

Our examination does not provide a legal determination on the Company’s compliance with the servicing criteria.

In our opinion, management’s assertion that the Company complied with the aforementioned servicing criteria as of and for the year ended December 31, 2018, for the U.S. Bank Corporate Trust Asset-Backed Securities Platform is fairly stated, in all material respects.

/s/Ernst & Young LLP

Minneapolis, Minnesota

February 28, 2019

Exhibit 35.1

SERVICER COMPLIANCE STATEMENT
BARCLAYS BANK DELAWARE
BARCLAYS DRYROCK ISSUANCE TRUST

In connection with the Annual Report on Form 10-K of Barclays Dryrock Issuance Trust for the fiscal year ending December 31, 2018 (the “Report”), the undersigned, a duly authorized officer of Barclays Bank Delaware (the “Servicer”), does hereby certify and represent that:

1.       A review of the activities and performance of the Servicer under the Amended and Restated Servicing Agreement dated as of August 1, 2012, as amended and restated as of December 17, 2013, by and among Barclays Dryrock Funding LLC, the Servicer, Barclays Dryrock Issuance Trust and U.S. Bank National Association (the “Agreement”) during the period that is the subject of the Report has been made under my supervision.

2.       To the best of my knowledge, based on such review, the Servicer has fulfilled all of its obligations under the Agreement in all material respects throughout the period that is the subject of the Report.

IN WITNESS WHEREOF, the undersigned has duly executed this Servicer Compliance Statement this 29th of March 2019.

Exhibit 35.2

SERVICER COMPLIANCE STATEMENT
BARCLAYS BANK PLC
BARCLAYS DRYROCK ISSUANCE TRUST

In connection with the Annual Report on Form 10-K of Barclays Dryrock Issuance Trust for the fiscal year ending December 31, 2018 (the “Report”), the undersigned, a duly authorized officer of Barclays Bank PLC (the “Servicer”), does hereby certify and represent that:

1.       A review of the activities and performance of the Servicer under the Services Agreement, dated as of July 31, 2012, by and between Barclays Bank Delaware and the Servicer (the “Agreement”) during the period that is the subject of the Report has been made under my supervision.

2.       To the best of my knowledge, based on such review, the Servicer has fulfilled all of its obligations under the Agreement in all material respects throughout the period that is the subject of the Report.

IN WITNESS WHEREOF, the undersigned has duly executed this Servicer Compliance Statement this 29th of March 2019.