Contents

Introduction 4

Background and Overview 5

About Barclays 8

Barclays’ Resolution Strategy 14

Global Resolution Strategy 14

US-Specific Resolution Strategy 14

US Resolution Planning Capabilities 18

Financial Capabilities 19

Capital 19

Liquidity 20

Derivatives and Trading Activities 22

Operational Capabilities 24

Payment, Clearing and Settlement 24

Collateral 25

Management Information Systems 25

Shared and Outsourced Services 26

Structural Capabilities 27

Governance Mechanisms 27

US Legal Entity Rationalization 28

Separability 29

US Resolution Planning Governance 30

Additional Resolution Planning Supporting Information 31

Description of Core Business Lines 32

Material Entities and Their Operational

and Financial Interconnectedness 34

Summary Financial Information 41

Description of Derivatives and Hedging Activities 46

Memberships in Material Payment, Clearing and 

Settlement Systems 47

Material Supervisory Authorities 48

Principal Officers 49

Barclays’ Corporate Governance 50

Management Information Systems 50

Glossary of Key Terms 52
The information, statements and opinions contained in this 

presentation do not constitute a public offer under any applicable 

legislation, an offer to sell or solicitation of any offer to buy any 

securities or financial instruments, or any advice or recommendation 

with respect to such securities or other financial instruments. 

This document contains certain forward-looking statements within 

the meaning of Section 21E of the US Securities Exchange Act of 1934, 

as amended, and Section 27A of the US Securities Act of 1933, as 

amended, with respect to the Group. Barclays cautions readers that 

no forward-looking statement is a guarantee of future performance 

and that actual results or other financial condition or performance 

measures could differ materially from those contained in the forwardlooking statements. These forward-looking statements can be 

identified by the fact that they do not relate only to historical or 

current facts. Forward-looking statements sometimes use words such 

as ‘may’, ‘will’, ‘seek’, ‘continue’, ‘aim’, ‘anticipate’, ‘target’, ‘projected’, 

‘expect’, ‘estimate’, ‘intend’, ‘plan’, ‘goal’, ‘believe’, ‘achieve’ or other 

words of similar meaning. Forward-looking statements can be made 

in writing but also may be made verbally by members of the 

management of the Group (including, without limitation, during 

management presentations to financial analysts) in connection with 

this document. Examples of forward-looking statements include, 

among others, statements or guidance regarding or relating to the 

Group’s future financial position, income growth, assets, impairment 

charges, provisions, business strategy, capital, leverage and other 

regulatory ratios, payment of dividends (including dividend payout 

ratios and expected payment strategies), projected levels of growth in 

the banking and financial markets, projected costs or savings, any 

commitments and targets, estimates of capital expenditures, plans 

and objectives for future operations, projected employee numbers, 

IFRS impacts and other statements that are not historical fact. By their 

nature, forward-looking statements involve risk and uncertainty 

because they relate to future events and circumstances. The forwardlooking statements speak only as at the date on which they are made 

and such statements may be affected by changes in legislation, the 

development of standards and interpretations under IFRS, including 

evolving practices with regard to the interpretation and application of 

accounting and regulatory standards, the outcome of current and 

future legal proceedings and regulatory investigations, future levels of 

conduct provisions, the policies and actions of governmental and 

regulatory authorities, geopolitical risks and the impact of 

competition. In addition, factors including (but not limited to) the 

following may have an effect: capital, leverage and other regulatory 

rules applicable to past, current and future periods UK, US, Eurozone 

and global macroeconomic and business conditions the effects of 

any volatility in credit markets market related risks such as changes in 

interest rates and foreign exchange rates effects of changes in 

valuation of credit market exposures changes in valuation of issued 

securities volatility in capital markets changes in credit ratings of any 

entity within the Group or any securities issued by such entities the 

potential for one or more countries exiting the Eurozone instability as 

a result of the exit by the UK from the European Union and the 

disruption that may subsequently result in the UK and globally and 

the success of future acquisitions, disposals and other strategic 

transactions. A number of these influences and factors are beyond 

the Group’s control. As a result, the Group’s actual financial position, 

future results, dividend payments, capital, leverage or other 

regulatory ratios or other financial and non-financial metrics or 

performance measures may differ materially from the statements or 

guidance set forth in the Group’s forward-looking statements. 

Additional risks and factors which may impact the Group’s future 

financial condition and performance are identified in our filings with 

the SEC (including, without limitation, our Annual Report on Form 

20-F for the fiscal year ended 31 December 2019), which are available 

on the SEC’s website at www.sec.gov.

Subject to our obligations under the applicable laws and regulations 

of any relevant jurisdiction, (including, without limitation, the UK and 

the US), in relation to disclosure and ongoing information, we 

undertake no obligation to update publicly or revise any forwardlooking statements, whether as a result of new information, future 

events or otherwise.

Important notice and forward-looking statements
Introduction

An overview of Barclays and Our US Operations
5 | Barclays PLC 2020 US Resolution Plan – Public Section

Introduction

Background and Overview

Barclays1 submits this Public Section (the Public Section) as 

part of Barclays’ 2020 US2

 Limited Resolution Plan (the 2020 

Plan) pursuant to the Dodd-Frank Wall Street Reform and 

Consumer Protection Act (the Dodd-Frank Act) and the Final 

Rule (the Final Rule or Section 165(d))3

 pursuant thereto by 

the Federal Reserve Board of Governors (FRB) and the Federal 

Deposit Insurance Corporation (FDIC), together the Agencies. 

Barclays operates under a US Intermediate Holding 

Company (IHC) and has implemented stringent standards 

to ensure the safety and soundness of the US Operations 

pursuant to Regulation YY.4

 This is Barclays’ sixth US 

resolution plan submission. 

Since submitting our initial US Resolution Plan in 2012, 

Barclays has undergone a multiyear effort to make our firm 

more resolvable on a global basis driven by both regulatory 

and business requirements. Barclays has a strong capital and 

funding profile, as well as a diversified asset base, which helps 

ensure our resiliency. 

Barclays is committed to maintaining a US Resolution Plan for 

its US Operations5

 that would facilitate an orderly resolution of 

Barclays’ US Operations under the US Bankruptcy Code within 

the meaning of the Dodd-Frank Act and the Final Rule, which 

aims to, in the unlikely event of Barclays’ failure, permit the rapid 

and orderly resolution of Barclays’ US Operations without an 

adverse systemic impact on the financial system or US economy. 

Barclays has taken numerous actions to improve its resolvability 

and develop coordinated global resolution strategies, while at the 

same time adhering to local resolution planning requirements. 

This has been accomplished through substantial dialogue with 

the Agencies and other regulatory authorities in the US, the UK 

and other key jurisdictions where Barclays operates. 

In the UK, it is the Resolution Authority’s responsibility to 

“develop feasible and credible resolution strategies for all 

firms”.6

 Barclays’ Global Preferred Resolution Strategy, which 

has been developed by its home Resolution Authority, the Bank 

of England (BoE), is a Single Point of Entry (SPOE) resolution 

involving bail-in at Barclays’ holding company (BPLC). Barclays 

has worked extensively with the BoE to develop capabilities 

that further bolster Barclays’ resolvability under its Global 

Preferred Resolution Strategy. 

While Barclays’ Global Preferred Resolution Strategy would 

preempt the need to employ the US-Specific Resolution 

Strategy outlined in Barclays’ US Resolution Plan, Barclays has 

developed a viable US-Specific Resolution Strategy that is not 

dependent on Barclays’ Global Preferred Resolution Strategy.

US resolution planning has been an iterative process starting 

from when the Agencies issued the initial Final Rule in 2011. 

The Agencies issued a new Final Rule for Resolution Plans 

on November 1, 2019 and have issued both public guidance 

and confidential feedback over the course of nine years, 

during which Barclays has been responsive and addressed the 

Agencies’ guidance and feedback. Barclays has built upon each 

previous plan submission to further enhance our resolvability 

and resolution preparedness; strengthen our financial, 

structural and operational resiliency; and develop capabilities 

to support an orderly resolution. 

1. “Barclays”, “Group” and “Barclays Group” are terms which are used to refer to Barclays PLC together with its subsidiaries and/or Barclays Bank PLC together with its subsidiaries. 

The term “Parent”, “Covered Company” or “BPLC” refers to Barclays PLC and the term “Bank” or “BBPLC” refers to Barclays Bank PLC.

2. Throughout this Section: “US” means the United States as defined in the Final Rule; “UK” means the United Kingdom and the territories under its jurisdictions; “$” or “USD” means 

the US Dollar; “£” or “GBP” means the UK pound sterling; and “€” or “EUR” means the official currency of the European Union.

3. “Final Rule or 165(d)” means 12 CFR Parts 243 and 381, Resolution Plans Required, issued by the Agencies and effective November 30, 2011. The final rule was updated on 

December 31, 2019 to reflect improvements identified since the agencies finalized their joint resolution plan rule in November 2011 and to address amendments to the Dodd-Frank 

Act made by the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA).

4. 12 CFR Part 252, Regulation YY, Enhanced Prudential Standards for Bank Holding Companies and Foreign Banking Organizations, Final Rule, effective June 1, 2014 (Regulation YY).

5. US Operations is defined collectively as the US Intermediate Holding Company (IHC), its IHC subsidiaries and US Branches, Agencies, and Representative Offices of BBPLC.

6. The Bank of England’s Approach to Resolution, October 2017, https://www.bankofengland.co.uk/-/media/boe/files/news/2017/october/the-bank-of-england-approach-toresolution.pdf 

7 | Barclays PLC 2020 US Resolution Plan – Public Section

Liquidity 

• Performing internal liquidity stress tests for the IHC and 

BBPLC’s US branch and maintenance of US-based 

liquidity buffers

• Maintaining sufficient liquidity to meet projected net 

stressed cash-flow needs over the 30-day planning horizon 

for the IHC and over the first 14 days over the 30-day 

planning horizon for BBPLC’s US branch network

• Maintaining an independent risk function to review and 

evaluate the adequacy and effectiveness of the liquidity risk 

management practices of Barclays’ combined US Operations

• Maintenance of an IHC and Barclays Bank Delaware (BBDE) 

Liquidity Coverage Ratio (LCR) in excess of the required 100% 

minimum for compliance since the April 2017 effective date

Risk Management and Governance

• Oversight by a US IHC Board of Directors and a US 

Risk Committee

• Retaining a US Chief Risk Officer 

Barclays’ primary US operating entities are Barclays Capital Inc 

(BCI), Barclays Bank Delaware (BBDE) and Barclays Bank PLC 

New York Branch (NYBR) as a Branch of BBPLC.

In the US, reduced systemic impact and complexity has been 

achieved through:

• Actively reducing BCI’s total assets from $330bn as of year 

end (YE) 2010 to approximately $99bn at YE 2019

• Materially improving the IHC’s capital ratios:

– Common Equity Tier 1 (CET1) ratios improved from 13.1% 

as of Q4 2017 to 16.3% as of Q4 2019

– Tier 1 leverage ratio improved from 8.2% as of Q4 2017 to 

9.4% as of Q4 2019

• Producing and monitoring multiple liquidity stress tests for 

the US IHC, its subsidiaries, and US branches

• Monitoring asset maintenance ratio (AMR) levels on NYBR

• Establishing dedicated liquidity buffers for BCI, BBDE and 

NYBR that are held in lien-free segregated accounts and at 

the Federal Reserve Bank. Liquidity buffers are monitored 

and sized daily based on liquidity stress test results

• Actively reduced secured funding and reliance on creditsensitive 2a7 money markets funds by reducing exposure by 

approximately 50% since 2013

• Eliminating reliance on intraday liquidity usage for less liquid 

collateral and reduced less liquid tri-party intraday exposure 

by 99%

• Simplifying our US Operations and US legal entity structure 

by reducing the US legal entity footprint by over 350 entities 

since 2012

• Developing a Combined US Operations (CUSO) Contingency 

Framework that provides governance and oversight of how 

Barclays would manage a liquidity or capital stress event

• Continuing to invest in technology enhancements to improve 

technology applications and infrastructure to ensure that 

both BCI and BBDE have the ability to produce reporting

• Enhancing processes and controls through automation and 

reduction in duplication

• Reducing BBDE’s borrowing from its parent; BBDE is selffunded with a diversified liability portfolio

• Increasing the credit quality of BBDE’s credit card receivables

At the Group level, Barclays has:

• Continued to strengthen the capital position of the Group; as 

of YE 2019 Barclays had a CET1 ratio of 13.8% (from 13.3% 

for YE 2017). BPLC (the parent company) issued £8.6bn of 

minimum requirement for own funds and eligible liabilities 

(MREL) instruments to maintain compliance with indicative 

MREL requirements and maintain a stable and diverse 

funding base by type, currency and market

• Worked collaboratively with UK authorities to develop a 

confidential executable global Recovery Plan that enhances 

Barclays’ ability to endure a severely adverse stress scenario 

with minimal disruption to the global markets or its customers

• Enhanced arrangements to ensure operational resilience 

in line with the UK Prudential Regulation Authority (PRA) 

Operational Continuity in Resolution (OCIR) rules. Barclays 

has ensured that its operational structures facilitate effective 

recovery and resolution planning and the continued provision 

of functions critical to the economy in a resolution scenario

• Developed inter-affiliate and third-party vendor terms and 

conditions that are resolution friendly and ensure continued 

access to critical services during a Material Financial Distress 

event or failure of Barclays or one or more of its affiliates, 

including its US affiliates

9 | Barclays PLC 2020 US Resolution Plan – Public Section

Barclays’ US Operations

The US is Barclays’ second home market 

and is fundamental to Barclays’ strategy. 

The US accounts for a significant portion 

of Barclays’ employees, revenue and profit 

Barclays’ offerings in the US are operated out of the Barclays 

International business division. Business offerings operating 

in the US are: 

• Consumer, Cards and Payments

• Corporate and Investment Bank

Consumer, Cards and Payments

Our US Consumer Bank, the US division of Consumer, Cards 

and Payments, offers co-branded credit cards in the US, along 

with online retail deposits. We have maintained our ranking in 

the top ten of US credit card issuers, collaborating with over 25 

top companies to deliver co-branded credit card programs. 

Barclays conducts this business in the US through its Insured 

Depository Institution (IDI), BBDE.

Corporate and Investment Bank

Our Markets businesses provide execution, prime brokerage 

and risk management services across the full range of asset 

classes including equities, credit and macro products. We are 

highly focused on investments in technology to drive increased 

client flows and improved returns. Barclays is focused on the 

standardization and simplification of post-trade technologies 

supported by a strong regulatory and controls environment.

Our Banking business provides long-term strategic advice 

on mergers and acquisitions, corporate finance and strategic 

risk management solutions, and equity and credit origination 

capabilities. In the US, Barclays had a 5.7% share of overall 

investment banking revenue, placing it fifth overall – the 

highest ranked non-domestic bank.7

Bolstered by strong mergers and acquisitions activity, we 

advised on numerous landmark deals to deliver for our clients, 

and ranked sixth for US mergers and acquisitions advisory 

revenue in 2019. In the capital markets, Barclays is one of 

the world’s leading underwriters of both debt and equity 

securities. In the US in 2019, Barclays had a 6.2% share of all 

equity underwriting, ranking sixth overall, and a 7.1% share of 

all investment grade debt underwriting, ranking fifth overall.

Our Leveraged Finance business ranks fifth in the US with a 

6.2% market share. IFR magazine named Barclays as its US 

Issuers Bond House.

Corporate Banking in the Americas focuses on providing 

loans, cash management, trade finance, foreign exchange, 

and working capital products to large American multinational 

companies and Financial Institutions for execution in the UK, 

Europe, India and the United Arab Emirates.

Finally, our Research business delivers independent, thoughtleading content across equities, credit, macro and quantitative 

portfolio strategy. Our research business is committed to 

providing clients with differentiated market insights, actionable 

trade ideas and thematic views delivered through publications, 

one-to-one analyst interactions, conferences and events.

Principal legal entities in the US

The IHC key operating subsidiaries include:

• BCI, our Securities and Exchange Commission (SEC) 

registered securities broker-dealer and Commodity Futures 

Trading Commission (CFTC) registered Futures Commission 

Merchant (FCM), operates key investment banking and 

capital markets businesses within Barclays’ Corporate and 

Investment Bank Business Offering

• BBDE, our US IDI, operates our US Consumer Bank 

business within Barclays’ Consumer, Cards and Payments 

Business Offering

NYBR is a branch of BBPLC in the US and operates corporate 

banking activities within Barclays’ Corporate and Investment 

Bank Business Offering. Branches of foreign banks are not part 

of the IHC, but are subject to a subset of the requirements of 

Regulation YY.

In the context of US Resolution Planning, Barclays’ 2020 Plan 

focuses on US business and operations which are conducted 

out of Barclays International.

7. Unless otherwise noted, all investment banking market share and league table data are from Dealogic.



Resolution Strategy and Capabilities

An overview of our Global and US-Specific Resolution 

Strategy and a focus on our capabilities that support 

an orderly resolution
Barclays PLC 2020 US Resolution Plan – Public Section | 14

Barclays’ Resolution Strategy

Our US-Specific Resolution Strategy, based on a hypothetical failure, 

facilitates an orderly wind down of Barclays US Operations.

Global Resolution Strategy

As a Global Systemically Important Bank (G-SIB), Barclays 

is proactively working to improve its Group recoverability 

and resolvability. Barclays is committed to implementing the 

Key Attributes of Effective Resolution Regimes for Financial 

Institutions and relevant consultative papers and annexes as 

set forth by the Financial Stability Board (FSB). 

Barclays’ Preferred Resolution Strategy which is developed by 

its home Resolution Authority, the BoE, is an SPOE resolution 

involving Bail-in at Barclays’ holding company (i.e., BPLC).

The SPOE Resolution Strategy involving Bail-in, consistent with 

the requirements for resolution strategies under the Final Rule, 

is not reliant on any government funding but is dependent on 

the holding company having issued sufficient loss absorbing 

capacity to effect the Bail-in and recapitalize the Group.

If a loss were to arise at the subsidiary level, these losses 

could be passed up to the holding company through 

write-down of the intra-group capital and recapitalization 

of subsidiaries via the conversion of pre-positioned loss 

absorbing capacity. The Bail-in itself would occur at the 

holding company level (i.e., BPLC), with external creditors of 

BPLC holding certain instruments then exposed to losses in 

order of the creditor hierarchy.

Bail-in at the holding company aims to ensure that individual 

entities, including the US Material Entities, continue to remain 

operational during the Group Resolution proceedings.

Barclays and the BoE are working to remove any barriers to the 

Preferred Resolution Strategy and assess Barclays’ resolvability 

with respect to this strategy. By ensuring the continuity of 

services and operations of the subsidiaries, the Preferred 

Resolution Strategy should ensure an orderly resolution that 

can be accomplished within a reasonable period of time, in a 

manner that substantially mitigates the risk that the failure of 

Barclays would have on the financial stability of a jurisdiction 

in which it operates, including the US.

US-Specific Resolution Strategy

The proposed failure scenario and 

associated assumptions of the 2020 Plan 

are hypothetical and do not necessarily 

reflect an event or events to which the 

firm is or may become subject 

With the increased capital and liquidity position of the firm, 

the high quality liquid assets that comprise our balance sheet 

and the focused governance and management of Barclays’ 

capital and liquidity position and risk management practices, 

it is highly unlikely that BCI, BBDE or any of its US entities 

would fail due to an idiosyncratic Barclays event. Barclays 

believes that in the event of market-wide stress, BCI and BBDE 

would most likely be a ‘flight to safety’ option for customers 

and clients.

The analysis provided in the 2020 Plan with respect to the 

bankruptcy of the IHC is hypothetical. Barclays appreciates 

and supports the importance of resolution planning and is 

committed to fully analyzing and taking measures to ensure a 

rapid and orderly resolution of its US Operations without the 

need for extraordinary government support should such an 

event occur. We have found the resolution planning process 

to be beneficial for Barclays in that it has allowed us to further 

develop capabilities for the unlikely failure of the IHC.

Summary of Barclays’ US-Specific Resolution Strategy

Barclays assessed a number of possible strategies to resolve 

our US Operations and determined that the US Strategy, to 

meet the US Title I Requirements of the Dodd-Frank Act, is a 

SPOE at the US IHC.

Barclays PLC 2020 US Resolution Plan – Public Section | 16

Key details regarding our US-Specific Resolution Strategy

As required by the Agencies, Barclays is required to develop 

a hypothetical Material Financial Distress (MFD) event (i.e., 

an idiosyncratic event that only impacts Barclays) that would 

result in capital and/or liquidity losses so severe that the IHC 

would have to file for bankruptcy under Chapter 11 of the US 

Bankruptcy Code.

The IHC would be reorganized pursuant to a Chapter 11 plan of 

reorganization that would be negotiated and voted on prior to 

bankruptcy and could be approved by the Bankruptcy Court in 

as little as 30 days post filing.

Barclays understands that the events and situations that may 

be presented are not predictable, and often do not unfold as 

planned. However, Barclays’ resolution planning capabilities 

support a number of different scenarios which may occur.

An actual resolution of Barclays, if one were to occur, may be 

significantly different from the scenarios depicted in the 2020 

Plan. For the purposes of Title I and our 2020 Plan we envision 

the following series of events.12

Early stages of Severe Stress Conditions

Barclays is operating in a period of financial stress with 

macroeconomic conditions consistent with the CCAR/DFAST 

Severely Adverse scenario with capital and liquidity metrics 

being monitored consistent with our CUSO Contingency 

Framework. Barclays’ US senior management, Boards, and 

regulators are engaged in monitoring Barclays’ US Operations 

including the capital and liquidity positions of each of the US 

Material Operating Entities.

Material Financial Distress Event

Barclays’ US Operations experience an idiosyncratic MFD 

event. In response to the MFD event, Barclays’ US Operations 

request financial support from Group. As required by the 

Agencies, it is assumed that parental financial support 

is denied. The market becomes aware and Barclays’ US 

Operations experience increased outflows. Barclays continues 

to monitor its liquidity and capital against its resolution 

liquidity and capital execution needs and positioning.

Runway

Liquidity and/or capital outflows result in a breach of a 

trigger that signifies that BUSLLC should begin to prepare 

for bankruptcy. Below outlines key events that are expected 

to occur during runway to execute Barclays’ US-Specific 

Resolution Strategy:

• While preparing for the bankruptcy of BUSLLC, no 

active actions are taken to materially reduce our size, 

interconnectedness or mitigate risks of failure of our 

US Operations

• Barclays continues to monitor our Resolution Liquidity 

Execution Need and Resolution Capital Execution Need

• US Material Entity Boards and senior management will 

monitor the financial health of Barclays’ US Operations as 

clients and counterparties take action and capital/liquidity 

outflows continue

• The BUSLLC Board takes necessary actions as outlined in 

our Bankruptcy Playbook, including engaging bankruptcy 

counsel, authorizing the filing for Chapter 11 and having 

bankruptcy counsel prepare the relevant motions and plan of 

reorganization in the bankruptcy case

• US Non-Branch Material Entity Boards and senior 

management coordinate with relevant governance bodies 

and take actions as outlined in our Governance Playbooks

• We will utilize our Communication Playbook which outlines 

the approach and strategy to communicate with both 

internal and external stakeholders (e.g., employees, 

clients, regulators)

Point of Non-Viability

Barclays retains the discretion to enter into Resolution which 

includes whether or not to file for bankruptcy based on the 

circumstances presented at the point of time. It is at the Point 

of Non-Viability (PONV) that the appropriate Boards will take 

final actions to enter into Resolution. For purpose of Title I and 

Section 165(d) requirements, it is at the PONV that Barclays 

will authorize the bankruptcy of BUSLLC.

Under our US-Specific Resolution Strategy, in the extremely 

unlikely event that our firm experiences losses so severe that 

Barclays reaches the PONV, BUSLLC will file for Chapter 11 

bankruptcy while also ensuring our Material Operating Entities 

maintain enough capital and liquidity to remain outside of 

insolvency proceedings.

• Pursuant to the SSA between BUSLLC and BGUS, BUSLLC 

will contribute remaining assets (less excess cash to pay for 

bankruptcy administration costs) to BGUS

• US Material Entities pursuant to the SSA will calculate monitor 

and report on their capital and/or liquidity needs to ensure 

capital and/or liquidity needs are not greater than the capital 

and/or liquidity positioned. To the extent capital and/or 

liquidity is needed, BGUS will provide capital and liquidity to US 

Material Entities pursuant to the SSA

Resolution

Barclays’ US-Specific Resolution Strategy and capabilities are 

designed to ensure Barclays’ US Operations are prepared for 

resolution. This entails ensuring that capital and liquidity are 

appropriately positioned at the US Material Operating Entities 

and US Material Holding Companies while ensuring that 

BUSLLC maintains enough liquidity to cover costs associated 

with the bankruptcy administration. Further, our US-Specific 

Resolution Strategy facilitates an orderly wind down without 

posing systemic risk to the US financial system. 

12. The 2020 Plan is not binding on a bankruptcy court or other resolution authority and the proposed failure scenario and associated assumptions are hypothetical and do not 

necessarily reflect an event or events to which the firm is or may become subject.
17 | Barclays PLC 2020 US Resolution Plan – Public Section

US-Specific Resolution Strategy

Material 

Operating Entity 

Remains outside 

of insolvency 

proceeding

US-Specific Resolution 

Strategy

BCI Yes Solvent wind down of 

Core Business Lines

BBDE Yes

Sale of Consolidated 

Entity and its service 

entity 

NYBR Yes

Placed under heightened 

supervision by NYBR’s 

state regulator, the New 

York State Department 

of Financial Services

Below outlines key events that are expected to occur during 

Resolution to execute Barclays’ US-Specific Resolution Strategy: 

• BGUS will continue to provide to subsidiary entities, 

pursuant to the SSA, capital and/or liquidity to execute 

the US-Specific Resolution Strategy outside of insolvency 

proceedings and stay above minimum liquidity and capital 

regulatory requirements

• BCI will undergo a solvent wind down which focuses on 

transferring customer accounts and closing out trading 

positions either consensually or by not rolling trades as 

they mature

• The consolidated BBDE entity and its associated Material 

Service Entity (i.e., BSLLC) have been identified for potential 

sale as part of the 2020 Plan due to BBDE’s high quality credit 

card portfolio

• Our New York Branch of BBPLC (i.e., NYBR) is expected to 

remain outside of any insolvency proceedings and may be 

put under heightened supervision by the New York State 

Department of Financial Services (NYSDFS), who may 

impose additional AMR requirements designed to ensure 

that third-party creditors of NYBR are paid in full. The 2020 

Plan provides supporting analysis to demonstrate NYBR will 

be able to repay its internal and external obligations while 

complying with the AMR requirement, due to NYBR’s strong 

liquidity position and stringent liquidity risk management

• Our Material Service Entities are both financially and 

operationally resilient and continue to provide services. 

Our Material Service Entities are contractually obligated 

through intra-group agreements to continue to provide 

services. Services required for Resolution have been 

identified and Material Entity interdependencies have been 

mapped. Our Material Service Entities maintain sufficient 

working capital to operate services and execute our USSpecific Resolution Strategy

• Employee retention mechanisms are in place to retain 

key employees required to execute our US-Specific 

Resolution Strategy

Conclusion

At the conclusion of the resolution process, only our 

consolidated IDI and the Material Service Entity that supports 

the IDI may have been sold to a third party and all of our other 

assets have been sold or wound down. Following the wind 

down and sale of our objects of sale, the value realized would 

be available to support remaining US Operations. Any residual 

value remaining after the wind down of US Operations would 

be returned to the IHC for distribution to its creditors and other 

stakeholders (i.e., BPLC/BBPLC).

Cessation of Branch Activity 

Although our US-Specific Resolution Strategy does not 

contemplate the cessation of NYBR or any NYBR activity 

significant to the activities of a Critical Operation, Barclays has 

conducted an analysis on the impact of the cessation of the 

NYBR. This analysis includes:

• Description of Critical Operations and shared services 

provided by NYBR to IHC subsidiaries

• Identification of potential obstacles, and associated 

mitigants, presented by the cessation of shared services 

that support Critical Operations
Barclays PLC 2020 US Resolution Plan – Public Section | 18

US Resolution Planning Capabilities

We maintain capabilities to support our US-Specific Resolution Strategy

Barclays has enhanced capabilities across ten key elements 

which support our financial, operational, and structural 

preparedness to support an effective US-Specific 

Resolution Strategy.

Resolution Planning Capabilities l i C i

Capital

Financial

Payment,

Clearing and 

Settlement

Operational

Governance

Mechanisms

Liquidity Collateral Legal Entity

Rationalization

Derivatives

and Trading

Activities

Management

Information

Systems

Shared and

Outsourced

Services

Separability

Structural

Financial Capabilities 

• Capital: Estimate and position each US non-branch Material 

Entity’s capital needs in resolution to ensure each US NonBranch Material Entity has sufficient capital to execute 

Barclays’ US-Specific Resolution Strategy

• Liquidity: Project and meet liquidity needs leading up to and 

during resolution. Pre-positioned liquidity also allows the 

US Material Entities to remain solvent and operate while the 

entities are being resolved

• Derivatives and Trading Activities: Articulate and 

substantiate how Barclays will wind down derivatives and 

trading activities of its Core Business Lines and transfer client 

accounts to alternative providers during resolution

Operational Capabilities

• Payment, Clearing and Settlement (PCS): Develop actions to 

maintain PCS activities (e.g., membership to FMUs) and have 

the ability to quantify PCS activities

• Collateral: Capabilities related to managing, identifying, and 

valuing the collateral that is received from, and posted to, 

external parties and affiliates

• Management Information Systems (MIS): Maintain 

management information systems that produce reliable data 

on financial resources and positions on a legal entity basis

• Shared and Outsourced Services: Support the continuity of 

critical shared and outsourced services through operationally 

and financially resilient Material Service Entities

Structural Capabilities

• Governance Mechanisms: Maintain a governance structure 

with triggers capable of identifying the onset and escalation 

of financial stress events in sufficient time to allow the US 

Non-Branch Material Entity Boards and senior management 

enough time to prepare for resolution and execute Barclays’ 

US-Specific Resolution Strategy

• US Legal Entity Rationalization (US LER): Organize Barclays’ 

US legal entity structure in a way to support an orderly 

resolution. Maintain a rational US legal entity structure 

through the development of US LER Criteria that are part 

of the firm’s day-to-day decision making process related 

to structure

• Separability: Develop actionable options to wind down, sell, 

or transfer discrete operations to facilitate the execution of 

our US-Specific Resolution Strategy

Each subsection to follow provides additional detail on the 

multiyear initiatives completed that support Barclays’ readiness 

and preparedness for US Resolution Planning.
19 | Barclays PLC 2020 US Resolution Plan – Public Section

Financial Capabilities 

Capital

IHC Capital Management Capabilities in BAU

Barclays’ objective is to maximize shareholder value by 

prudently optimizing the level, mix and distribution of capital 

resources while maintaining sufficient capital at the Holding 

Company as well as at each regulated legal entity level. This is 

to ensure that Barclays is well capitalized relative to minimum 

regulatory and stressed capital requirements, and to support 

Barclays’ risk appetite, growth, and strategic options while 

seeking to maintain a robust credit proposition for the Group 

and its subsidiaries.

Strong and sustainable capital position

The IHC has increasingly well-developed and established 

capital management practices and the organization continues 

to consistently accrete capital. As at December 31 2019, the 

CET1 ratio was 16.3% driven by consistently strong earnings 

performance and a simplified stable balance sheet. In 2019, the 

IHC’s capital improved by $1 billion, after paying a common 

dividend of $450 million to its parent and a return on tangible 

equity of 7.1%. 

Core Capabilities that the IHC has developed to maintain 

capital adequacy include:

• Maintaining a capital plan aligned with Barclays’ strategic 

objectives, balancing capital generation of the IHC with 

business growth and capital distributions

• Setting internal capital thresholds and Capital Risk Limits 

that ensure minimum regulatory capital requirements 

are met at all times in the US jurisdictions as required by 

respective regulatory authorities for the IHC and regulated 

legal entities within the IHC

• Performing IHC-wide internal and regulatory driven 

capital stress tests (e.g., CCAR, DFAST) as well as taking 

part in Group-wide internal and regulatory driven stress 

tests to ensure that the IHC holds sufficient capital under 

stressed conditions

Barclays has a Capital Contingency Plan (CCP) which sets 

out Barclays’ strategy for addressing its capital needs and 

requirements during capital stress events. The CCP identifies 

capital stress categories to facilitate the monitoring and 

identification of potential contingency events. It also defines 

the approach for the quantification and projection of capital 

requirements across the stress event.

Resolution capabilities

Barclays has an adequate amount of lossabsorbing capacity for US Non-Branch 

Material Operating Entities to be resolved 

in an orderly manner and for Barclays to 

execute its US-Specific Resolution Strategy

On December 15, 2016 the Federal Reserve Board adopted a 

Final Rule (TLAC Final Rule)13 to strengthen the ability for US 

government authorities to orderly resolve the largest domestic 

and foreign banks operating in the US without any taxpayer 

support. The TLAC Final Rule requires the largest US banks 

and foreign banks operating in the US to maintain a minimum 

amount of loss-absorbing instruments, including a minimum 

amount of unsecured long-term debt. Barclays US IHC is 

subject to the TLAC Final Rule, which became effective January 

1, 2019. In order to be fully compliant, Barclays executed 

required restructuring of debt instruments to convert them 

into TLAC eligible debt and obtained regulatory approval to 

increase its loss-absorbing capacity ahead of the compliance 

date of January 1, 2019. 

Key elements of our capital capabilities to support our 

resolution preparedness

• Resolution Capital Execution Need (RCEN) 

• Resolution Capital Adequacy and Positioning (RCAP) 

capabilities

• Resolution triggers framework 

In order for Barclays to execute its US-Specific Resolution 

Strategy, the IHC should have an adequate amount of lossabsorbing capital and eligible long-term debt. Barclays holds 

TLAC, including eligible long-term debt (eLTD), in excess 

of regulatory requirements. The IHC has calibrated internal 

targets and Early Warning Indicators (EWIs) for all TLAC and 

eLTD ratio requirements to continually monitor the actual and 

projected levels against these thresholds. 

TLAC is pre-positioned strategically within the IHC to provide 

flexibility depending on the specific stress event.

Barclays has a methodology for estimating the amount of 

capital that may be needed to support each US Non-Branch 

Material Operating Entity in resolution.

13. 12 CFR Part 252, Subpart P – Covered IHC Long-Term Debt Requirement, Covered IHC Total Loss absorbing Capacity Requirement and Buffer, and Restrictions on Corporate 

Holding Companies of Global Systemically Important Foreign Banking Organizations.



23 | Barclays PLC 2020 US Resolution Plan – Public Section

resolution of one of the parties and that restrictions on the 

transfer of credit support for the foregoing agreements must 

likewise be limited in certain circumstances.

Consistent with the requirements of the US Stay Regulations 

promulgated by the Agencies in 2017, Barclays has remediated 

QFCs, including through the use of the US Protocol proposed 

by ISDA. The US Protocol allows for the recognition of stays 

under the US Stay Regulations on the exercise of default and 

other rights under QFCs in connection with resolution, limit the 

exercise of cross-default provisions in QFCs and limit restrictions 

on the transfer of credit support that could be an impediment to 

the orderly resolution of Barclays.

Derivatives booking practices

Barclays has limited derivatives exposure booked in its IHC 

subsidaries. The majority of derivatives transactions are 

limited to forwards, highly liquid exchange traded options and 

futures contracts that have short dated maturities. Barclays’ 

derivative mark to market exposures are only a fraction of 

their notional values.

Barclays’ US derivatives exposure is de minimis compared 

to its US and FBO peers the wind down of the US derivative 

portfolio would not result in systemic risk in the US. Barclays’ 

OTC derivatives activities are largely booked in either BBPLC 

or Barclays Capital Securities Limited, both of which are UKdomiciled entities.

Wind down of derivative portfolio 

We have conducted analysis on how Barclays could take 

actions to wind down our broker-dealer’s (i.e., BCI) derivative 

inventory. 

We have incorporated the wind down analysis of our 

derivatives and trading activities into the resolution capital 

and liquidity execution needs for our US-Specific Resolution 

Strategy. Barclays has analyzed the risk profile of residual 

derivative portfolios that remain at the end of the active wind 

down period. Such analysis includes understanding size, 

composition, complexity, maturity profile, and counterparties.

Prime Brokerage unwind 

Barclays’ 2020 Plan includes an assessment on how, in the 

event of Resolution, Barclays would transfer prime brokerage 

accounts to peer prime brokers. Further we have analyzed 

potential risk such as operational challenges and asymmetric 

unwinding of positions and how such risks may be mitigated. 

The assessment is informed by assessing:

• Clients’ relationships with alternative providers

• Manual and/or automated processes 

• Client positions (i.e., long or short) 

For a summary of Barclays’ derivatives and hedging activities, 

please refer to the Additional Resolution Planning Supporting 

Information portion of the Public Section. 





29 | Barclays PLC 2020 US Resolution Plan – Public Section

Given the diversity of the items comprising of our US LER 

Criteria, individual functions throughout Barclays in the US are 

responsible for the ongoing application of the US LER Criteria. 

US LER Criteria are embedded into business as usual processes 

and day-to-day decision making. We have a governance 

process to ensure ongoing application of the US LER Criteria 

and, as part of the Resolution Planning process, to reevaluate 

our US LER Criteria and our compliance with the criteria.

Governance committees ensure that resolution considerations, 

along with other considerations such as capital and liquidity, 

are taken into account before decisions are made with respect 

to business operations, new product determinations, structural 

reform requirements, potential booking model changes or 

new legal entity creations. The US Recovery and Resolution 

Planning (US RRP) function is embedded into relevant 

governance committees.

Separability

Barclays analyzed its US Operations and 

identified objects that under a range of 

scenarios and market conditions could be 

sold or transferred in resolution

Barclays has carefully analyzed its US Operations and 

completed initiatives to ensure that Barclays is prepared to 

consider divesting discrete US Operations (i.e., objects of sale) 

under different market conditions. 

Key capabilities to support the divesture of potential 

objects of sale

• Conducted separability and buyer due diligence analysis 

• Limited financial and operational interconnectedness

• Simplified US legal entity and ownership structure

• Identified data necessary to facilitate potential 

buyer analysis

• Maintained financials and other financial, business and 

operational information

We have performed buyer due diligence on our objects of 

sale to identify potential buyers. As part of the analysis, we 

screened a number of foreign and domestic institutions 

of different sizes and footprints in the US. We evaluated 

potential buyers across different categories (e.g., strategic fit, 

regulatory impediments).

Barclays has assessed how objects of sale are operationally 

and financially interconnected with our affiliates (i.e., reliance 

on affiliates for funding, shared services) and third parties 

for outsourced services. Our objects of sale have limited 

operational and financial interconnectedness which reduces 

the complexity in the divesture/sale.

Further, we have identified potential legal risks which may 

occur based on the divesture of objects of sale and identified 

strategies on how risks would be mitigated.

Our US legal entity structure supports the divesture and 

separability with respect to our objects of sale. We believe our 

US legal entity structure is positioned to allow our strategic 

actions to be executed without impacting the solvent 

resolution of Barclays’ US Operations. 

Where Barclays has identified objects of sale, we have identified 

the data required to execute the sale which includes detailed 

financial, business and operational information. Ensuring data 

is available will assist in accelerating timelines associated with 

the divesture of our objects of sale and preserve the value of the 

business. Potential acquirers will have necessary information to 

begin the due diligence process quickly.
Barclays PLC 2020 US Resolution Plan – Public Section | 30

US Resolution Planning Governance

The 2020 Plan was approved by the US IHC Board on 

June 8, 2020 in accordance with a rigorous governance 

process. Barclays has a governance structure that leverages 

Barclays’ existing governance framework for the purpose of 

resolution planning.

Development of the US Resolution Plan involves multiple 

functions within the US Operations and Group including, 

but not limited to, Barclays Internal Audit (BIA), BX 

Management Office, Compliance, Controls Office, Corporate 

Communications, Corporate Real Estate (CRES), Corporate 

Secretariat, Front Office Business Managers, Finance, Global 

Payments, Global Technology and Infrastructure (GTIS), 

Group Recovery and Resolution Planning (Group RRP), 

Human Resources (HR), IHC Architecture, IHC Management, 

Investor Relations (IR), Independent Validation Unit (IVU), 

Legal, Marketing and Branding, Operations, Procurement, 

Quantitative Analytics (QA), Regulatory Relations, Risk, 

Security, Service Management, Tax, Technology, Treasury, US 

Consumer Bank and US RRP.

The US RRP function consolidates all materials and develops 

the plan throughout numerous editing and vetting cycles. 

Content in the US Resolution Plan is attested to by the 

Accountable Executives of each relevant business unit or 

function that contributed the input. The US RRP Steering 

Committee is comprised of senior executives from all aspects 

of the businesses and functions and is chaired by the Chief 

Administrative Officer (CAO) Americas. The US Resolution 

Plan is subject to approval by the US RRP Steering Committee 

and executive attestation by the RRP Americas Accountable 

Executive. The US Resolution Plan is approved by applicable 

Material Entity Boards and is ultimately approved by the 

IHC Board.

Barclays’ US Resolution Plan has historically been approved 

by the Board of Directors of Barclays PLC (BPLC), as the 

Covered Company, for previous plan submissions. In the case 

of non-US-based covered companies such as Barclays, the 

US Resolution Plan Rule permits a delegate acting under the 

express authority of such Board to approve the Resolution 

Plan. As Barclays PLC (BPLC) is the Covered Company, the 

BPLC Board has formally delegated the approval for the 2020 

Plan to the BUSLLC (IHC) Board. Based on this delegation, 

governance resides in the US. The US Governance includes:

• BUSLLC Board of Directors

• US ExCo

• Applicable Material Entity Boards 

• US RRP Steering Committee 

• Americas RRP Accountable Executive 

• Individual Accountable Executives
Additional Resolution Planning

Supporting Information

Additional information on Barclays, our US-Specific 

Resolution Strategy, the US IHC and our US Operations
Barclays PLC 2020 US Resolution Plan – Public Section | 32

Additional Resolution Planning 

Supporting Information

Description of Core Business Lines

For the 2020 Plan, Barclays identified six Core Business Lines in 

accordance with the Final Rule. 

The Core Business Lines and the Material Operating Entities 

where the Core Business Lines are conducted for the 2020 Plan 

are identified below.

In scope for the 2020 Plan

Barclays’ 

Business Line

Core Business Line 

(CBL)

Core Business 

Line mapped to 

Material Entity

Corporate and 

Investment Bank

FICC

Credit BCI and NYBR

Macro BCI

Fixed Income 

Financing BCI

Securitized 

Products BCI

Equities BCI

Consumer, Cards 

and Payments US Consumer Bank BBDE

The business activities that are in scope for the 2020 Plan are 

described as follows:

Fixed Income, Commodities and Currencies (FICC)

Credit

The Credit Core Business Line is comprised of two main 

products: Corporate Credit and Municipal Finance. From 

investment grade securities through distressed debt, we cover 

the full credit capital structure in multiple currencies.

• Corporate Credit provides market-making activities and 

liquidity through corporate bonds, preferred stock, loan 

products, and bankruptcy claims on a secondary basis for 

clients. It also facilitates the distribution of, and provides 

liquidity for, Barclays’ new issue corporate credit franchise, 

supporting the Capital Markets businesses within Banking. 

The client base for these products includes banks, insurance 

companies, pension plans, asset managers, money market 

funds, hedge funds, central banks, broker-dealers and large 

institutional investors.

• Municipal Finance is a business that distributes and trades 

high grade, taxable, spread flow and short-term municipal 

securities. As municipals are exclusively traded in US dollar 

(USD) currency, activity is primarily conducted through BCI and 

NYBR. Municipals Trading and Sales provides liquidity through 

market-making activities on a secondary basis for clients. 

The business also provides liquidity for Barclays’ new issue 

municipal finance business. Clients include banks, insurance 

companies, pension plans, asset managers, money market 

funds, hedge funds, central banks, broker-dealers and large 

institutional investors.

Macro

The Macro Core Business Line is a consolidated platform 

for trading interest rate and foreign exchange products in 

developed and emerging markets, streamlining our clients’ 

buying and trading activities across these products.

• Rates is a global business that performs market making 

activities and provides liquidity in government securities, 

agencies, commercial paper and supra sovereign bonds to 

institutional investors. The trading desk transacts as principal 

to buy and sell securities to facilitate customers’ flow 

orders, hedge for risk management purposes and provide 

liquidity for new-issue origination. The Rates business is a 

US government bond primary dealer. In the US, Rates cash 

products are traded in BCI.

• Foreign Exchange is a global business that performs market 

making activities and provides liquidity in all of the world’s 

major currencies. The trading desk transacts as principal to 

buy and sell securities to facilitate customers’ flow orders 

and hedging for risk management purposes. In the US, 

the business also works closely with the Capital Markets 

businesses within Banking to facilitate cross-currency swaps. 

Foreign Exchange products are traded in BCI.

Fixed Income Financing

• Fixed Income Financing is a business that participates 

in securities lending and borrowing activities, bi-lateral 

repurchase, and reverse repurchase transactions, and 

triparty repurchase transactions. Clients include securities 

lenders, central banks, global banks, financial institutions, 

money fund and asset managers. The business performs two 

basic functions: firm financing and matched book (client) 

financing. In the US, Barclays conducts its Fixed Income 

Financing business in BCI.
33 | Barclays PLC 2020 US Resolution Plan – Public Section

Securitized Products

• Securitized Products is a global, client-focused business 

that offers a multitude of products and solutions across 

origination, secondary market trading, structuring, 

distribution and financing, covering asset-backed securities 

and loans, commercial mortgage-backed securities and 

loans, agency and non-agency residential mortgage-backed 

securities and loans, and collateralized loan obligations. In 

the US, Securitized Products business is conducted in BCI.

Equities

The Equities Core Business Line is comprised of four main 

business lines: Cash Equities, Equity Derivatives, Equity 

Financing, and Agency Derivatives Services.

• Cash Equities provides full-service capabilities across 

content, issuance and execution for exchange traded and 

over-the-counter equities products. Cash equities includes, 

cash trading, program trading, and convertibles. All cash 

equities trading is conducted in BCI.

• Equity Derivatives incorporates Barclays’ client-facing 

business that provides full-service capabilities across 

execution and issuance of flow derivatives products, and 

options market making. It is a client-facing business that 

facilitates customer order flow, execution of principal 

hedging strategies, and makes markets, providing liquidity 

in a variety of equity options, ETFs (exchange-traded funds), 

ETNs (exchange-traded notes) and futures on both single 

names and indices. The desk transacts in listed options on 

all major US listed options exchanges. All US activity for the 

business is conducted through BCI.

• Equity Financing covers prime brokerage services, direct 

market access (DMA) execution services, and cash/synthetic 

financing of client equity and equity-linked positions, as well 

as the street-side securities lending and secured funding 

functions for equity and equity-linked securities. Barclays also 

provides securities lending and securities funding for internal 

Barclays businesses. In the US, Barclays conducts its Equity 

Financing business in BCI, with custody provided by BCI.

• Agency Derivatives Services (ADS) is a global business that 

provides execution, clearing, intermediation and settlement 

services to both internal trading desks and external 

customers. ADS includes futures and OTC clearing. BCI is 

the legal entity that faces US customers and clears all 

activity for its global clients on US futures exchanges and 

central counterparties.

US Consumer Bank

US Consumer Bank is the US division of the global Consumer, 

Cards and Payments business. The US Consumer Bank’s 

primary business is the issuance of credit cards to consumers 

via co-branded partnerships. It also offers online retail 

deposits. Consumer Bank operates out of BBDE.

35 | Barclays PLC 2020 US Resolution Plan – Public Section

Barclays US LLC

19. The 2020 Plan is not binding on a bankruptcy court or other resolution authority and that the proposed failure scenario and associated assumptions are hypothetical and do not 

necessarily reflect an event or events to which the firm is or may become subject.

20. The 2020 Plan is not binding on a bankruptcy court or other resolution authority and that the proposed failure scenario and associated assumptions are hypothetical and do not 

necessarily reflect an event or events to which the firm is or may become subject.

Characteristics Description

Regulatory Status Bank Holding Company; Intermediate Holding Company

Jurisdiction of Organization Organized under the laws of the State of Delaware 

Primary Regulators Federal Reserve Bank of New York

Ownership Wholly owned subsidiary of BBPLC and is ultimately owned by BPLC

Activities

BUSLLC, as a consolidated entity, is a diversified financial services company providing investment 

banking, brokerage, capital markets and consumer financial services to both institutional and 

consumer customers through its subsidiaries

Funding Sources The funding needs of BUSLLC are provided primarily through equity and TLAC eligible debt 

downstreamed from its immediate parent, BBPLC

Characteristics Description

Regulatory Status Bank Holding Company

Jurisdiction of Incorporation Incorporated under the laws of the State of Delaware

Primary Regulators Federal Reserve Bank of New York

Ownership Direct, wholly owned subsidiary of Barclays US LLC

Activities Holding company above Material US Entities 

Funding Sources BGUS is funded on an unsecured basis via unsecured funding facilities provided by BBPLC and 

subsidiaries of BBPLC. Equity is provided by BGUS’ immediate IHC parent, BUSLLC

Barclays Group US Inc

Summary of BGUS’ Resolution Strategy under Our 

US-Specific Resolution Strategy20

Prior to the bankruptcy filing of BUSLLC, BUSLLC will 

contribute its remaining assets (less excess cash to pay for 

bankruptcy administration costs) to BGUS upon the Final 

Contribution Event. To the extent capital and/or liquidity is 

needed by the US Non-Branch Material Entities, BGUS will 

provide capital and/or liquidity support pursuant to the SSA.

Throughout the resolution phase, the Material US Entity 

subsidiaries of BGUS will calculate, monitor and report on their 

capital and/or liquidity needs to ensure their needs are not 

greater than the capital and/or liquidity positioned.

BGUS will remain solvent and would not enter into insolvency 

proceedings; as a result, BGUS will have the flexibility to 

provide capital and/or liquidity support to Material US Entities.

Summary of BUSLLC’s Resolution Strategy under Our 

US-Specific Resolution Strategy19

With the formation of the IHC (BUSLLC) in July 2016, Barclays 

assessed a number of possible strategies to resolve our US 

Operations and has determined that the US Strategy, to meet 

the US Title I Requirements of the Dodd-Frank Act, is a SPOE at 

the US IHC. Our US-Specific Resolution Strategy is structured 

so that only the IHC (i.e., BUSLLC) enters into a bankruptcy 

proceeding and all Material US Operating Entities and Material 

Service Entities have sufficient capital and liquidity resources 

to continue operating outside of an insolvency proceeding. The 

BBPLC New York Branch will remain outside of any insolvency 

proceeding and may be placed under heightened supervision 

by its state regulator. Further, our US-Specific Resolution 

strategy is designed so that extraordinary government or 

taxpayer support is not required, fire sale of assets is avoided 

and the transfer of client accounts to alternative service 

providers is orderly. 
Barclays PLC 2020 US Resolution Plan – Public Section | 36

Barclays Capital Inc

21. The 2020 Plan is not binding on a bankruptcy court or other resolution authority and that the proposed failure scenario and associated assumptions are hypothetical and do not 

necessarily reflect an event or events to which the firm is or may become subject.

Characteristics Description

Regulatory Status • Securities Broker-Dealer

• Futures Commission Merchant

• Municipal Advisor

Jurisdiction of Organization Incorporated under the laws of the State of Connecticut 

Primary Regulators • Securities Exchange Commission

• Commodity Futures Trading Commission

• Municipal Securities Rulemaking Board

• Financial Industry Regulatory Authority (FINRA)

Ownership BCI’s direct parent and sole stockholder is BGUS

Activities BCI is a ‘4(k)(4)(E)’ securities subsidiary under the Bank Holding Company Act, which permits it 

to engage in securities underwriting, dealing, or market-making activities. BCI’s activities include 

transactions in asset-backed securities, agency mortgage-backed securities, debt securities, other 

corporate-related securities, equities, resale and repurchase agreements, securities lending and 

borrowing, and clearing derivative products. BCI is a primary dealer in US government securities.

BCI has investment banking and capital markets business in the US

Funding Sources The BCI balance sheet is funded primarily on a secured basis, via the repo market. Secured 

financing is performed by the Prime Financing business, which has both a fixed income repo 

desk and an equity financing desk within BCI. BCI’s unsecured funding is provided through 

intercompany debt facilities and equity received from its parent legal entities, primarily BGUS

Other BCI is headquartered in New York, with registered domestic branch offices in Atlanta, Boston, 

Charleston, Chicago, Houston, Los Angeles, Media, Menlo Park, New York, San Juan, San 

Francisco, Seattle, Washington D.C. and Whippany. BCI’s client base includes money managers, 

insurance companies, pension funds, hedge funds, depository institutions, corporations, trust 

banks, money market and mutual funds, domestic and international governmental agencies and 

central banks

Summary of BCI’s Resolution Strategy under Our 

US-Specific Resolution Strategy21

BCI is expected to remain solvent and stay above minimum 

liquidity and capital regulatory requirements. To the extent 

capital and/or liquidity is needed, post the bankruptcy of 

BUSLLC, BGUS will provide capital and/or liquidity to BCI, 

pursuant to the SSA.

Throughout the runway, while BUSLLC prepares for 

bankruptcy, Barclays will respond to client requests to transfer 

positions; however, BCI will not proactively reduce its size or 

interconnectedness. BCI would continue to retain access to 

shared services provided by affiliates as contractually entitled 

under IGAs; BCI would also retain access to FMUs throughout 

resolution. Prime brokerage and other clients of BCI will likely 

transfer their positions and accounts to alternative providers.

Post the bankruptcy of BUSLLC, BCI will not solicit new 

business and will commence a solvent wind down which 

focuses on reducing systemic risk by transferring customer 

accounts and closing out trading positions either consensually 

or by not rolling trades as they mature.
37 | Barclays PLC 2020 US Resolution Plan – Public Section

22. The 2020 Plan is not binding on a bankruptcy court or other resolution authority and that the proposed failure scenario and associated assumptions are hypothetical and do not 

necessarily reflect an event or events to which the firm is or may become subject. 

Summary of BBDE’s Resolution Strategy under Our 

US-Specific Resolution Strategy22

BBDE is expected to remain solvent and stay above minimum 

liquidity and capital regulatory requirements. To the extent 

capital and/or liquidity is needed, post the bankruptcy of 

BUSLLC, BGUS will provide capital and/or liquidity to BBDE, 

pursuant to the SSA.

Under our US-Specific Resolution Strategy, the consolidated 

BBDE entity and its associated service company (i.e., BSLLC) 

have been identified for potential sale due to BBDE’s high 

quality credit card portfolio. Our strategy is designed to protect 

our depositors while having no impact on the FDIC’s Deposit 

Insurance Fund.

BBDE will remain outside of insolvency proceedings. 

Throughout the runway, while BUSLLC prepares for 

bankruptcy, Barclays will respond to client requests; however, 

BBDE will not proactively reduce its size or interconnectedness. 

BBDE would continue to retain access to shared services 

provided by affiliates as contractually entitled under IGAs; 

BBDE would also retain access to FMUs throughout resolution.

BBDE will have sufficient liquidity to ensure depositors have 

access to their insured deposits. Barclays would have active 

communication with its customers to instill confidence that 

covered deposits are insured.

BBDE clients may request to transfer their positions and 

accounts to alternative providers. Post the bankruptcy of 

BUSLLC, leveraging our separability and data capabilities, 

BBDE will begin the due diligence and marketing processes 

associated with the sale of BBDE and identify a potential buyer 

for BBDE.

Characteristics Description

Regulatory Status Insured Depository Institution

Jurisdiction of Organization Delaware-chartered FDIC-insured non-member bank domiciled in Delaware

Primary Regulators • Federal Deposit Insurance Corporation 

• Consumer Financial Protection Bureau

• State Bank Commissioner of Delaware

Ownership BBDE is a wholly owned subsidiary of BGUS 

Activities BBDE’s primary business is the issuance of co-branded credit cards within the US Barclays brand. 

The US Consumer Bank business is the US portion of the global Consumer, Cards and Payments 

business. The US Consumer Bank business also has an online retail deposit business offering 

savings accounts and term certificate deposit products in the US

Funding Sources BBDE has a well-diversified mix of funding products consisting of retail deposits, brokered 

deposits, deposit sweeps, credit card securitization and intercompany funding including a small 

amount of subordinated debt from BUSLLC

Other BBDE is headquartered in Wilmington, Delaware

Barclays Bank Delaware
Barclays PLC 2020 US Resolution Plan – Public Section | 38

23. The 2020 Plan is not binding on a bankruptcy court or other resolution authority and that the proposed failure scenario and associated assumptions are hypothetical and do not 

necessarily reflect an event or events to which the firm is or may become subject.

Summary of NYBR’s Resolution Strategy under Our 

US-Specific Resolution Strategy23

Under our US-Specific Resolution Strategy, NYBR would remain 

outside of any insolvency proceedings and may be put under 

heightened supervision by the its state regulator, the NYSDFS, 

who may impose additional AMR requirements. Barclays has 

performed analysis to demonstrate NYBR will be able to repay 

its internal and external obligations while complying with the 

AMR requirement, due to NYBR’s strong liquidity position and 

stringent liquidity risk management. NYBR would continue to 

retain access to shared services provided by inter-affiliates as 

contractually required in IGAs; NYBR would also retain access 

to FMUs throughout resolution.

Although our US-Specific Resolution strategy does not 

contemplate the cessation of any US branch activities that are 

significant to the activities of a Critical Operation, Barclays’ has 

conducted analysis on the impact of the cessation of the NYBR. 

This analysis includes a description of Critical Operations and 

Shared Services provided by NYBR to IHC Subsidiaries and the 

identification of potential obstacles, and associated mitigants, 

presented by the cessation of shared services that support 

Critical Operations.

Characteristics Description

Regulatory Status/Licensing Licensed by the New York State Department of Financial Services as a branch of BBPLC, a bank 

organized under the laws of England and Wales

Primary Regulators NYSDFS and the Federal Reserve Bank of New York

Ownership As a branch, NYBR is a part of BBPLC and has no branches, subsidiaries, associates or joint 

ventures

Activities NYBR’s primary activities are deposit taking, lending, management of Barclays’ USD funding 

positions and US dollar clearing

Funding Sources NYBR’s balance sheet is funded via external unsecured financing markets and inter-branch 

funding received primarily from the BBPLC UK

Barclays Bank PLC New York Branch
39 | Barclays PLC 2020 US Resolution Plan – Public Section

Material Service Entities

Barclays has designated the following seven entities as Material 

Service Entities for the purposes of US Resolution Planning.

Barclays Services Corporation: BSC is a corporation domiciled 

in the US and incorporated in the state of Delaware and is a 

wholly owned subsidiary of BGUS. BSC provides infrastructure 

support services to Barclays’ affiliates, primarily BCI, NYBR and 

BBDE in the US.

Barclays Services LLC: BSLLC is a limited liability corporation 

domiciled in the US and incorporated in the state of Delaware 

and is a wholly owned subsidiary of BGUS. BSLLC provides 

customer service, infrastructure and operational support 

to BBDE.

Barclays Execution Services Limited: BXSL is a private limited 

company domiciled and incorporated in England and Wales 

in the United Kingdom. Effective September 1, 2017, BXSL 

became the group service company, providing infrastructure 

and employment services across Barclays International and 

Barclays UK.

Barclays Global Service Center Private Limited: BGSC is a 

private limited company incorporated in India and a direct 

subsidiary of BXSL. BGSC provides information technology 

(IT) and IT-enabled services like data processing, payment 

processing, call center, financial accounting, financial 

analytics services, and technology solutions across Barclays 

entities globally.

US Real Estate Holdings No. 1, 2, 3 Limited: US RE1, US RE2, 

and US RE3 are limited liability companies incorporated in the 

UK. US RE1, US RE2, and US RE3 are indirect wholly owned 

subsidiaries of BBPLC. US RE1, US RE2, and US RE3 own 

freehold and/or leasehold interests in properties in the US.

Material Service Entities Funding Sources 

Barclays manages its capital resources and requirements 

on a centralized and legal entity basis, across regulated and 

non-regulated entities. The Material Service Entities retain 

adequate capital for working capital needs and to support 

capital expenditure as required. Excess capital is returned to 

the Group in the form of dividends or capital repatriations. 

The Group and Americas Finance and Treasury functions 

collectively manage the appropriate capital requirements of the 

entities. BSC, BSLLC, BXSL, BGSC, US RE1, US RE2, and US RE3 

are not individually regulated and, therefore, are not required 

to maintain any regulatory capital or to manage prescribed 

regulatory capital ratios on an ongoing basis. In the event that 

timing differences occur in managing their working capital, 

each of the Material Service Entities has access to backup 

funding facilities provided by BBPLC and BGUS.

Summary of Material Service Entities’ US-Specific 

Resolution Strategy24

Under our US-Specific Resolution Strategy, our Material 

Service Entities remain solvent and outside of any insolvency 

proceedings. Our Material Service Entities are both financially 

and operationally resilient and continue to provide services. Our 

Material Service Entities are contractually obligated through 

intra-group agreements to continue to provide services.

Our Material Service Entities maintain sufficient working capital 

to operate services and execute our US-Specific Resolution 

Strategy. While our US Material Service Entities are not 

expected to require additional capital and/or liquidity upon the 

bankruptcy of BUSLLC, US Material Service Entities, pursuant to 

the SSA, would have the ability to receive capital and/or liquidity 

support from BGUS in the event support was required. 

24. The 2020 Plan is not binding on a bankruptcy court or other resolution authority and that the proposed failure scenario and associated assumptions are hypothetical and do not 

necessarily reflect an event or events to which the firm is or may become subject. 

41 | Barclays PLC 2020 US Resolution Plan – Public Section

Summary Financial Information 

BPLC – Covered Company

Below summarizes the consolidated balance sheet and capital 

position of BPLC as of December 31, 2019 in accordance with 

International Financial Reporting Standards (IFRS) as reported

in Barclays PLC’s Annual Report. Please refer to the 2019 

Barclays PLC annual report for additional detail and disclosures.

As at December 31, 2019 £mm

Assets 

Cash balances at central banks 150,258

Cash collateral and settlement balances 83,256

Loans and advances at amortized cost 339,115

Reverse repurchase agreements and other similar secured lending 3,379

Trading portfolio assets 114,195

Financial assets designated at fair value through the income statement 133,086

Derivative financial instruments 229,236

Financial assets at fair value through other comprehensive income 65,750

Other assets 21,954

Total Assets 1,140,229

Liabilities 

Deposits at amortized cost 415,787

Cash collateral and settlement balances 67,341

Repurchase agreements and other similar secured borrowing 14,517

Debt securities in issue 76,369

Subordinated liabilities 18,156

Trading portfolio liabilities 36,916

Financial liabilities designated at fair value 204,326

Derivative financial instruments 229,204

Other liabilities 11,943

Total Liabilities 1,074,569

Equity 

Called up share capital and share premium 4,594

Other equity instruments 10,871

Other reserves 4,760

Retained earnings 44,204

Total equity excluding non-controlling interests 64,429

Non-controlling interests 1,231

Total Equity 65,660

Total Liabilities and Equity 1,140,229
Barclays PLC 2020 US Resolution Plan – Public Section | 42

Barclays USLLC

BUSLLC’s consolidated balance sheet as of December 31, 

2019 was comprised of $149bn in total assets, of which 

$61bn (41%) were collateralized agreements which includes 

securities purchased under agreements to resell and securities 

borrowed. $21bn (14%) of total assets consist of trading assets. 

Approximately 99% of these assets are classified as Level 1 

(quoted market prices in active market) or Level 2 (internal 

models with significant observable market parameters), 

predominantly government, agency, and equity securities. $27bn 

(18%) of total assets were credit card loans. The remaining $40bn 

(26%) of assets include cash and cash equivalents including those 

segregated for regulatory and other purposes, receivables from 

brokers, dealers, clearing organizations, and customers, loans to 

affiliates, and deferred tax assets.

BUSLLC’s total consolidated liabilities as of December 31, 2019 

were $132bn, of which $45bn (34%) were collateralized financing 

agreements through securities sold under agreements to 

repurchase and securities loaned. $27bn (20%) of liabilities were 

payable to customers, which primarily includes margin payable. 

$5bn (4%) of liabilities consists of trading liabilities. $26bn 

(20%) of liabilities were borrowings which consists of unsecured 

loans from affiliates and borrowings securitized by credit card 

receivables. $24bn (18%) of the liabilities were deposits including 

both retail and brokered deposits. Majority of the deposits are 

FDIC insured. The remaining $6bn (3%) of liabilities primarily 

includes subordinated debt issued to BBPLC, payables to brokers, 

dealers and clearing organizations, and other accrued liabilities.

BUSLLC’s consolidated capital base as of December 31, 2019 was 

comprised of $3bn of preferred stock and $14bn of common 

equity. The BUSLLC consolidated group is subject to the Board 

of Governors of the Federal Reserve System (FRB)’s capital and 

leverage standards, and Comprehensive Capital Analysis and 

Review assessments.

Barclays Capital Inc

BCI’s balance sheet as of December 31, 2019 was comprised of 

$99bn in total assets, of which $58bn (59%) were collateralized 

agreements which consists of securities purchased under 

agreements to resell and securities borrowed. $21bn (21%) 

of total assets were financial instruments owned at fair value. 

Approximately 99% of these assets are classified as Level 1 

(quoted market prices in active market) or Level 2 (internal 

models with significant observable market parameters), 

predominantly government, agency, and equity securities. 

The remaining $20bn (20%) of assets are primarily cash and 

cash equivalents segregated for regulatory purposes, and 

receivables from customers, broker-dealers and clearing 

organizations, which consists of margin, fails-to-receive, and 

settlement related balances.

BCI’s total liabilities as of December 31, 2019 were $92bn, 

of which $46bn (50%) of total liabilities were collateralized 

agreements through securities sold under agreements to 

repurchase and securities loaned. $27bn (29%) of liabilities

were payable to customers, which is primarily margin payable. 

The remaining $19bn (21%) of liabilities are primarily financial 

instruments sold, but not yet purchased, at fair value and 

borrowings and subordinated debt from affiliates.

BCI’s capital base as of December 31, 2019 was comprised of 

$7.4bn of common equity. BCI is subject to regulatory capital 

requirements25 and maintains capital well in excess of its 

regulatory minimum, in terms of both tentative net capital 

(TNC) and net capital (NC), both of which are available to 

absorb losses under going concern and gone concern events. 

BCI’s regulatory capital includes its common equity and 

subordinated debt.

Barclays Bank Delaware

BBDE’s balance sheet as of December 31, 2019 was comprised 

of $34bn in total assets, of which $26bn (77%) were loans 

receivable, which includes credit card loans, consumer loans, 

and other loan receivables held for sale, net of loan loss 

25. As a registered Broker-Dealer and FCM, BCI’s regulatory capital minimums are subject to Rule 15c3-1 of the Securities and Exchange Act and CFTC Regulation 1.17.

As at December 31, 2019 £mm

Average UK leverage ratio 4.5%

CET1 ratio 13.8%

UK leverage ratio 5.1%

Tangible net asset value per ordinary share 262p

Number of ordinary shares of BPLC (in millions) 17,322

Year-end United States Dollar exchange rate 1.32

Year-end Euro exchange rate 1.18

Barclays PLC 2020 US Resolution Plan – Public Section | 44

Barclays’ Capital and Liquidity Management and 

Funding Sources 

Barclays manages capital and liquidity through a centralized 

management structure in the Treasury function. Barclays 

Treasury manages treasury and capital risk on a day-to-day 

basis with the Treasury Committee acting as the principal 

management body. To enforce effective oversight and 

segregation of duties and in line with the Enterprise Risk 

Management Framework, the Treasury and Capital risk function 

is responsible for oversight of key capital and liquidity risk 

management activities. Capital and liquidity management is 

underpinned by a control framework and appropriate policies.

Capital Management

Barclays is committed to maintaining strong capital levels 

consistent with regulators’ expectations. Barclays’ capital 

management objectives are to maintain sufficient capital 

resources and ensure that Barclays is well capitalized relative 

to the minimum regulatory capital requirements set by the 

PRA in the UK and the FRB in the US. These objectives ensure 

that locally regulated subsidiaries can meet their minimum 

regulatory capital requirements to support Barclays’ risk 

appetite, economic capital requirements and credit rating.

Barclays monitors its capital management plan through a 

Capital Management Framework, which includes policies and 

practices that are approved by the Barclays Capital Committee, 

implemented consistently and aimed at delivering on the 

objectives. Barclays’ Treasury Committee and the BPLC Board 

approve Barclays’ stress plan and capital plan. The impact of 

regulatory changes is therefore assessed and monitored by 

Barclays Treasury and Barclays Risk and that impact is also 

factored into the capital planning process, which ensures that 

Barclays always maintains adequate capital to meet its minimum 

regulatory capital requirements. Barclays’ capital requirements 

are actively managed on a centralized basis and also at a local 

entity level, taking into account all the regulatory, economic and 

commercial environments in which Barclays operates.

CRD IV had to be implemented within the EU with effect from 

January 1, 2014. The rules are supplemented by Regulatory 

Technical Standards and, in the UK, the PRA’s rulebook, which 

includes rules providing transitional arrangements from the 

previous rules. However, rules and guidance are still subject 

to change as certain aspects of CRD IV are dependent on final 

technical standards and clarifications which are still to be 

issued by the European Banking Authority (EBA) and adopted 

by the European Commission and implemented by the PRA. 

All capital, RWA and leverage calculations reflect Barclays’ 

interpretation of the current rules.

The Group continues to be in excess of overall capital 

requirements. The CET1 ratio was 13.8% as at December 31, 

2019. On this reporting date, the Group’s Overall Capital 

Requirement for CET1 is 12.1% comprising a 4.5% Pillar 1 

minimum, a 2.5% Capital Conservation Buffer (CCB), a 1.5% 

Global Systemically Important Institution (G-SII) buffer, a 

3.0% Pillar 2A requirement and a 0.6% Countercyclical Capital 

Buffer (CCyB).

As of July 1, 2020, we noted the following changes that 

have been announced relating to the Group’s overall capital 

requirements for CET1: 

• Amid the disruption caused by COVID-19, to create lending 

capacity for the banking industry, on March 11, 2020, the 

Financial Policy Committee (FPC) set the CCyB rate for UK 

exposures at 0% with immediate effect, noting that any 

subsequent increase would not take effect until March 2022 

at the earliest. This reduced the CCyB for the Group to 0.0%. 

The Group’s Overall Capital Requirement for CET1 was 

revised to 11.5% accordingly. The Group reported a CET1 

ratio at 13.1% for Q1 2020, representing a 160bps headroom 

above this requirement level.30

• Furthermore, on May 7, 2020, the PRA announced it will 

be setting all Pillar 2A requirements as a nominal amount, 

instead of a percentage of total RWAs. As RWA inflation is 

expected on the back of lending growth and heightened 

volatility, this change further reduced Pillar 2A requirement 

in ratio terms, and accordingly, the Overall Capital 

Requirement for the Group. Subject to regulatory approval, 

the revised requirements will be disclosed in the future 

reporting cycles.31

Barclays’ Capital Resources Summary32

Capital Resources December 31, 2019 (£mm)

Common Equity Tier 1 £40.8

Total Tier 1 £52.2

Total Regulatory Capital £63.6

Barclays’ Key Capital Ratios32

Key Capital Ratios December 31, 2019

Common Equity Tier 1 13.8%

Tier 1 17.7%

Total Regulatory Capital 21.6%

30. Barclays PLC Q1 2020 Results Announcement can be found in the following link: https://home.barclays/content/dam/home-barclays/documents/investor-relations/ 

ResultAnnouncements/2020Q1/20200429-B-PLC-Q1-2020-RA.pdf. 

31. For the latest view of Barclays PLC’s latest financial results including capital requirements and positions, please refer to the Investor Relations website at https://home.barclays/

investor-relations/reports-and-events/latest-financial-results/. 

32. CET1, T1 and T2 capital, and RWAs are calculated applying the transitional arrangements of the CRR as amended by CRR II applicable as at the reporting date. This includes IFRS9 

transitional arrangements and the grandfathering of CRR and CRR II non-compliant capital instruments. Total RWAs calculated under this approach were £295.1bn as of December 31, 2019.
45 | Barclays PLC 2020 US Resolution Plan – Public Section

Capital management in Barclays remains a dynamic process 

and we continue to be in close dialogue with the regulators. 

Any further amendment to capital requirements will be 

actively managed to, and we will provide update to the market 

as and when appropriate.33 

One of the main objectives of managing risk is to ensure 

that Barclays achieves an adequate balance between capital 

requirements and resources. Capital management is integral 

to Barclays’ approach to financial stability and sustainability 

management, and is therefore embedded in the way Barclays’ 

businesses and Material Entities operate and in the way 

Barclays manages risk.

Barclays adopts a forward-looking, risk-based approach to 

capital risk management. BBPLC is the primary funding source 

for its Material Entities and subsidiaries. Regulated Material 

Entities are, at a minimum, allocated adequate capital to meet 

their current and forecast regulatory and business requirements. 

Each regulated Material Entity retains its own capital resources 

to meet its regulatory minimum capital requirements, which 

are monitored and controlled by the BPLC Board and Barclays 

Treasury. Barclays currently maintains a buffer over its minimum 

regulatory capital requirements. Treasury Capital and Leverage 

Management personnel are assigned to each regulated Material 

Entity to review and challenge its forecast capital positions 

and assess its compliance with Treasury Capital and Leverage 

Management policies.

Liquidity Management

The efficient management of liquidity is essential to the 

Group in retaining the confidence of the financial markets and 

maintaining that the business is sustainable. There is a control 

framework in place for managing liquidity risk and this is 

designed to meet the following objectives: 

• Maintain liquidity resources that are sufficient in amount and 

quality and a funding profile that is appropriate to meet the 

liquidity risk appetite as expressed by the Board

• Maintain market confidence in the Group’s name

This is achieved via a combination of policy formation, 

review and governance, analysis, stress testing, limit setting 

and monitoring. Together, these meet internal and 

regulatory requirements.

The Treasury and Capital Risk function is responsible for the 

management and governance of the liquidity risk mandate 

defined by the Board and the production of Internal Liquidity 

Adequacy Assessment Processes (ILAAPs). Treasury has the 

primary responsibility for managing liquidity risk within the set 

risk appetite. The CRO for Treasury and Capital Risk reports to 

the Group CRO.

Barclays’ comprehensive control framework for managing the 

Group’s liquidity risk is designed to deliver the appropriate term 

and structure of funding consistent with the Liquidity Risk 

Appetite (LRA) set by the Board. The Board sets the LRA based 

on the internal liquidity risk model and external regulatory 

requirements namely the LCR. The LRA is represented as 

the level of risk the Group chooses to take in pursuit of its 

business objectives and in meeting its regulatory obligations. 

The approved LRA is implemented in line with the control 

framework and policy for liquidity risk.

The control framework incorporates a range of ongoing 

business management tools to monitor, limit and stress test 

the Group’s balance sheet and contingent liabilities and the 

Recovery Plan. Limit setting and transfer pricing are tools that 

are designed to control the level of liquidity risk taken and drive 

the appropriate mix of funds. Together, these tools reduce the 

likelihood that a liquidity stress event could lead to an inability 

to meet the Group’s obligations as they fall due. The control 

framework is subject to internal conformance testing and 

internal audit review.

The liquidity stress tests assess the potential contractual and 

contingent stress outflows under a range of scenarios, which 

are then used to determine the size of the liquidity pool that 

is immediately available to meet anticipated outflows if a 

stress occurs. The Group maintains a range of management 

actions for use in a liquidity stress; these are documented in 

the Group Recovery Plan. Since the precise nature of any stress 

event cannot be known in advance, the actions are designed 

to be flexible to the nature and severity of the stress event and 

provide a menu of options that can be drawn upon as required. 

The Barclays Group Recovery Plan also contains more severe 

recovery options to generate additional liquidity in order to 

facilitate recovery in a severe stress. Any stress event would 

be regularly monitored and reviewed using key management 

information by key Treasury, Risk and business representatives.

The Group liquidity pool as at December 31, 2019 was £211bn 

(2018: £227bn). During 2019, the month-end liquidity pool 

ranged from £211bn to £256bn (2018: £207bn to £243bn), 

and the month-end average balance was £235bn (2018: 

£225bn). The liquidity pool is held unencumbered and is not 

used to support payment or clearing requirements. Such 

requirements are treated as part of our regular business 

funding. The Group plans to maintain a liquidity surplus to 

the internal and regulatory stress requirements at an efficient 

level, while considering risks to market funding conditions 

and its liquidity position. The liquidity pool is intended to 

offset stress outflows, and comprises the following cash and 

unencumbered assets. The continuous reassessment of these 

risks may lead to appropriate actions being taken with respect 

to sizing of the liquidity pool.

33. For the latest view of Barclays PLC’s latest financial results including capital requirements and positions, please refer to the Investor Relations website at https://home.barclays/

investor-relations/reports-and-events/latest-financial-results/ 
Barclays PLC 2020 US Resolution Plan – Public Section | 46

Composition of Barclays’ Liquidity Pool 

 Composition December 31, 2019 

(£bn)

Cash and deposits with central banks £153

Total government bonds £36

Other £22

Total £211

The basis for sound liquidity risk management is a solid 

funding structure that reduces the probability of liquidity 

stress leading to an inability to meet funding obligations as 

they fall due. The Group’s overall funding strategy is to develop 

a diversified funding base (geographically, by type and by 

counterparty), maintain access to a variety of alternative 

funding sources, and to provide protection against unexpected 

fluctuations, while minimizing the cost of funding. Within 

this, the Group aims to align the sources and uses of funding. 

As such, retail and corporate loans and advances are largely 

funded by customer deposits, with the surplus primarily 

funding the liquidity pool. Other assets, together with other 

loans and advances to customers and unencumbered assets, 

are funded by wholesale debt and equity. The majority of 

reverse repurchase agreements are matched by repurchase 

agreements. Derivative liabilities and assets are largely 

matched. A substantial proportion of balance sheet derivative 

positions qualify for counterparty netting and the remaining 

portions are largely offset once netted against cash collateral 

received and paid.

The Group maintains access to a variety of sources of 

wholesale funds in major currencies, including those available 

from term investors across a variety of distribution channels 

and geographies, money markets, and repo markets. The 

Group has direct access to US, European and Asian capital 

markets through its global investment banking operations 

and long-term investors through its clients worldwide, and is 

an active participant in money markets. As a result, wholesale 

funding is well diversified by product, maturity, geography 

and major currency. As of December 31, 2019, the Group’s 

total wholesale funding outstanding (excluding repurchase 

agreements) was £147.1bn (2018: £154.0bn), of which £19.6bn 

(2018: £22.5bn) was secured funding and £127.5bn (2018: 

£131.5bn) unsecured funding. Unsecured funding includes 

£51.1bn (2018: £47.3bn) of privately placed senior unsecured 

notes issued through a variety of distribution channels 

including intermediaries and private banks.

Barclays enters into repurchase and other similar secured 

borrowing agreements to finance its trading portfolio assets. 

The majority of reverse repurchase agreements are matched 

by offsetting repurchase agreements entered into to facilitate 

client activity. The remainder is used to settle trading portfolio 

liabilities. Due to the high quality of collateral provided against 

secured financing transactions, the liquidity risk associated 

with this activity is significantly lower than unsecured 

financing transactions. Nonetheless, Barclays manages to 

gross and net secured mismatch limits to limit refinancing risk 

under a severe stress scenario and a portion of the Group’s 

liquidity pool is held against stress outflows on these positions. 

The Group-secured mismatch limits are calibrated based on 

market capacity, liquidity characteristics of the collateral and 

risk appetite of the Group.

Description of Derivatives and 

Hedging Activities 

Barclays enters into derivative contracts to satisfy the needs 

of its clients, for trading purposes and to manage Barclays’ 

exposure to market and credit risks resulting from its trading 

and market making activities. As part of its Risk Management 

policies, Barclays manages risks on an aggregate basis; 

however, entity level management exists to ensure that 

exposures of each individual entity are managed 

appropriately. Barclays uses industry standard derivative 

contracts whenever appropriate.

Derivatives are used to hedge interest rate, exchange rate, 

credit and equity exposures, as well as exposures to certain 

indices, such as house price indices and retail price indices 

related to non-trading positions. Where derivatives are held for 

risk management purposes, and when transactions meet the 

required criteria for documentation and hedge effectiveness, 

Barclays applies fair value hedge accounting, cash flow 

hedge accounting or hedging of a net investment in a foreign 

operation, as appropriate, to the risks being hedged.

BCI, a US registered broker-dealer and FCM, engages in 

execution and clearing of exchange traded derivatives primarily 

on US exchanges and with US registered Derivatives Clearing 

Organizations (DCOs). BCI provides execution and clearing 

services, on behalf of clients, as well as Barclays’ own trading 

activity in BCI and other Barclays affiliates. Exchange traded 

derivatives are marked to market daily and BCI places collateral 

with the clearinghouses in support of this activity. BCI is also a 

clearing member of derivatives clearing organizations, clearing 

eligible OTC derivatives products in the US.

Under Title VII of the Dodd-Frank Act, any swap or securitybased swap that has been identified by the CFTC or SEC as 

being subject to mandatory central clearing must be centrally 

cleared through a regulated clearinghouse. Certain OTC 

derivative transactions that are subject to mandatory central 

clearing should also be executed on a Swap Execution Facility 

(SEF) or Designated Contract Market (DCM). Phase-in of 

mandatory central clearing of swaps began on March 11, 2013. 

The participants in these markets are required to register with 

the CFTC as ‘swap dealers’ or ‘major swap participants’ and/

or with the SEC as ‘security-based swap dealers’ or ‘major 

security-based swap participants’, dependent on where they 

fall in relation to designated thresholds, and are subject to 

CFTC and SEC regulation and oversight.

Barclays PLC 2020 US Resolution Plan – Public Section | 48

Material Supervisory Authorities

Supervision in the US

The Barclays Group’s US activities and operations are subject 

to umbrella supervision by the Board of Governors of the 

Federal Reserve System (FRB), as well as additional supervision, 

requirements and restrictions imposed by other federal and 

state regulators and self-regulatory organizations (SROs). 

Barclays PLC, Barclays Bank PLC and their US branches 

and subsidiaries are subject to a comprehensive regulatory 

framework involving numerous statutes, rules and regulations. 

In some cases, US requirements may impose restrictions on 

Barclays’ global activities in addition to its activities in the US.

Barclays PLC and Barclays Bank PLC, and Barclays US LLC 

(BUSLLC) are regulated as bank holding companies (BHCs) by 

the FRB. BUSLLC is the Barclays Group’s top-tier US holding 

company that holds substantially all of the Barclays Group’s 

US subsidiaries and assets (including Barclays Capital Inc. and 

Barclays Bank Delaware). BUSLLC is subject to requirements 

in respect of capital adequacy, capital planning and stress 

testing, risk management and governance, liquidity, leverage 

limits, large exposure limits, activities restrictions and financial 

regulatory reporting. Barclays Bank PLC’s US branches are 

also subject to enhanced prudential supervision requirements 

relating to, among other things, liquidity and risk management.

Barclays PLC, Barclays Bank PLC and BUSLLC have elected to be 

treated as financial holding companies (FHCs) under the Bank 

Holding Company Act of 1956. FHC status allows these entities 

to engage in a variety of financial and related activities, directly 

or through subsidiaries, including underwriting, dealing and 

market making in securities. Failure to maintain FHC status 

could result in increasingly stringent penalties and, ultimately, 

in the closure or cessation of certain operations in the US. 

In addition to umbrella oversight by the FRB, many of the 

Barclays’ Group branches and subsidiaries are regulated by 

additional authorities based on the location or activities of 

those entities. The New York branch of Barclays Bank PLC 

is subject to extensive supervision and regulation by, as 

applicable, the NYSDFS as well as the Federal Reserve Bank 

of New York. Barclays Bank Delaware, a Delaware chartered 

commercial bank, is subject to supervision and regulation 

by the Delaware Office of the State Bank Commissioner, 

the Federal Deposit Insurance Corporation (FDIC), and the 

Consumer Finance Protection Bureau (CFPB). The deposits of 

Barclays Bank Delaware are insured by the FDIC and Barclays 

PLC. Barclays Bank PLC and BUSLLC are required to act as a 

source of strength for Barclays Bank Delaware. This could, 

among other things, require these entities to inject capital into 

Barclays Bank Delaware if it fails to meet applicable regulatory 

capital requirements. Barclays Bank Delaware is subject to 

direct supervision and regulation by the CFPB, which has the 

authority to examine and take enforcement action related to 

compliance with US consumer financial laws and regulations.

The Barclays Group’s US securities broker / dealer and 

investment banking operations, primarily conducted through 

Barclays Capital Inc., are also subject to ongoing supervision 

and regulation by the Securities and Exchange Commission 

(SEC), the Financial Industry Regulatory Authority (FINRA) and 

other government agencies and SROs under US federal and 

state securities laws. 

The Barclays Group’s US commodity futures, commodity 

options and swaps-related and client clearing operations 

are subject to ongoing supervision and regulation by the 

Commodity Futures Trading Commission (CFTC), the National 

Futures Association and other SROs. Barclays Bank PLC is also 

a US registered swap dealer and is subject to the FRB swaps 

rules with respect to margin and capital requirements.
49 | Barclays PLC 2020 US Resolution Plan – Public Section

Principal Officers

The tables below provide a list of the principal officers of our 

covered company, BPLC.

Barclays PLC Board of Directors34

Executive Title

Nigel Higgins Group Chairman

Jes Staley Group Chief Executive; Executive Director

Tushar Morzaria Group Finance Director; Executive Director

Mike Ashley Non-Executive Director

Tim Breedon Non-Executive Director

Sir Ian Cheshire Non-Executive Director

Mary Anne Citrino Non-Executive Director

Mohamed A. El-Erian Non-Executive Director

Dawn Fitzpatrick Non-Executive Director

Mary Francis Non-Executive Director

Crawford Gillies Senior Independent Director

Brian Gilvary Non-Executive Director

Diane Schueneman Non-Executive Director

Barclays PLC Executive Committee34

Executive Title

Jes Staley Group Chief Executive Officer

Mark Ashton-Rigby Group Chief Operating Officer

Paul Compton President of Barclays Bank PLC

Alistair Currie Head of Corporate Banking

Stephen Dainton Global Head of Markets

Matt Hammerstein Chief Executive Officer, Barclays UK

Bob Hoyt Group General Counsel

Tushar Morzaria Group Finance Director

Joe McGrath Global Head of Banking

Laura Padovani Group Chief Compliance Officer

Tristram Roberts Group Human Resources Director

Ashok Vaswani Global Head of Consumer Banking and Payments

C.S. Venkatakrishnan Group Chief Risk Officer

34. As at December 31, 2019
Barclays PLC 2020 US Resolution Plan – Public Section | 50

Barclays’ Corporate Governance 

Barclays has a well-embedded governance structure, subject 

to continual review and comprising three primary tiers:

• Board35 level oversight 

• Group Executive Committee oversight 

• Business level executive management monitoring 

and oversight 

Each of the three tiers has the following responsibilities: 

• Board level oversight: The Board’s principal duty is to 

promote the long-term success of Barclays by creating 

and delivering sustainable shareholder value. It does this 

by setting strategy and overseeing its implementation 

by management. While the ultimate focus is long-term 

growth, the Board seeks to ensure that management strikes 

an appropriate balance between promoting long-term 

growth and delivering short-term objectives. In setting and 

monitoring the execution of strategy, the Board aims to 

ensure that Barclays maintains an effective system of internal 

control and an effective risk management and oversight 

process across Barclays, delivering growth in a controlled and 

sustainable way 

• Group Executive Committee oversight: Oversight for the dayto-day management of the business activities of Barclays is 

delegated by the BPLC Board to the Barclays Chief Executive. 

In turn, the Barclays Chief Executive delegates certain of 

his powers and authorities, through a series of personal 

delegations to the Group Executive Committee to assist him 

in the execution of his responsibilities 

• Business level executive management monitoring and 

oversight: Business level executive management performs 

activities in accordance with defined responsibilities. 

Responsibilities may include oversight of regulatory 

matters and reviewing the status of actions in response to 

outstanding external regulatory and audit findings 

Management Information Systems

Barclays is committed to investing in management information 

systems (MIS) and reporting capabilities to ensure a robust 

catalog of management information around risk, finance, 

funding and liquidity, regulatory and operations is maintained. 

MIS includes business-aligned technology and enterprisewide technology solutions to ensure effective and efficient 

management, promote standardized processes and procedures 

across the organization and deliver quality services.

A broad range of critical MIS is utilized by Barclays to provide 

flexible client and business intelligence reporting, enabling 

the firm to compete at the highest level in an evolving 

business and regulatory climate. Key MIS generate multiple 

reports to support the business and senior management in 

comprehensively monitoring Barclays’ business. Management’s 

use of MIS in strategic decision making effectively mitigates 

potential risks inherent in its operations and ensures the 

soundness of Barclays’ businesses.

Barclays’ 2020 Plan includes the scope, content and 

frequency of key financial, operational and risk management 

internal reports utilized in BAU for Barclays’ Material Entities 

and Core Business Lines. Upon commencement of 

insolvency or resolution proceedings, pertinent management 

reports and access to information systems will be made 

available to regulatory authorities and consultants with 

bankruptcy expertise.

Barclays’ Compliance, Finance, Treasury, Risk, Operations, 

Front Office, Technology and Legal functions utilize key 

MIS and applications as part of BAU operations for risk 

management, accounting, financial and regulatory reporting 

for its Material Entities. Applications are provided through 

three key sources:

• In-House Applications: Applications developed (i.e., software 

code written) within Barclays. These are referred to as 

Barclays’ internal applications 

• Standard Third-Party Applications: Applications licensed 

from a third party that have not been customized to meet 

Barclays’ requirements beyond basic configurations required 

for installation and integration. Such applications are licensed 

to Barclays’ entities and are subject to contractual terms with 

the licensor 

• Customized Third-Party Applications: Third-party 

applications that have been customized to meet 

Barclays’ requirements 

The Plan provides detailed information regarding capabilities 

of Barclays’ MIS to collect, maintain and report information in 

a timely manner for its Material Entities. Policies and minimum 

standards apply for MIS required for business operations in 

order to ensure consistency in planning and implementation in 

a managed and secure manner. 

35. Board is defined as the Barclays PLC Board of Directors.
51 | Barclays PLC 2020 US Resolution Plan – Public Section

Key MIS provides:

• Risk: Reporting capabilities across all Barclays’ risk types, 

including the production of key market risk indicators (VaR), 

counterparty credit risk accounting and exposures such as 

credit valuation adjustments and specialized risk capabilities 

for other product segments, creditworthiness of clients and 

trading partners and overall credit exposures, and other 

metrics on utilizations, limits and trends across all principal 

risk types 

• Finance: Support of product control, financial control, and 

regulatory reporting, as well as shared data information, 

including the production of profit and loss statements and 

the general ledger 

• Treasury and liquidity: Liquidity, funding, and capital sizing 

and allocation processes, including early warning indicators, 

stress testing results and a wide range of funding reporting 

• Procurement: Global procurement information, including 

contracts and vendors 

• IB business reporting and operations: Risk platforms that 

produce consistent and aggregated snapshots of valuations, 

risk and profit and loss at regular intervals throughout 

the day and at end-of-day, including valuation and pricing 

services, trade booking, straight-through-processing, 

lifecycle management, corporate action processing and 

downstream settlements for all cash and derivative products 

• Compliance: Risks arising from compliance with regulations, 

including anti-money laundering, sanctions, surveillance and 

case management tools 

• Legal: Processes include client onboarding, document 

negotiation and document management 

Barclays is always looking to identify opportunities to enhance 

its MIS portfolio to provide greater transparency, improved 

control and increased accuracy of information in a cost-efficient 

manner for management decision making for analysis by 

external stakeholders and for regulatory review.

53 | Barclays PLC 2020 US Resolution Plan – Public Section

Term Definition

IDI Insured Depository Institution 

IFRS International Financial Reporting Standards 

IGA Intra-Group Agreement

IHC Intermediate Holding Company 

ILAAPs Internal Liquidity Adequacy Assessment 

Processes

IR Investor Relations

ISDA International Swaps and Derivatives 

Association

IT Information Technology

IVU Independent Validation Unit

LCR Liquidity Coverage Ratio

lOSCO International Organization of Securities 

Commissions 

LRA Liquidity Risk Appetite

MFD Material Financial Distress 

MIS Management Information Systems 

MOL Minimum Operating Liquidity

MREL Minimum Requirement for Own Funds and 

Eligible Liabilities

NC Net Capital

NSCC National Securities Clearing Corporation

NYBR Barclays Bank PLC New York Branch

NYSDFS New York State Department of Financial 

Services

OCC Options Clearing Corporation

OCIR Operational Continuity in Resolution

OTC Over the Counter

PCS Payment, Clearing and Settlement 

PFN Peak Funding Need

PONV Point of Non-Viability

PRA Prudential Regulation Authority 

QA Quantitative Analytics

QFC Qualified Financial Contract

RCAP Resolution Capital Adequacy and Positioning

RCEN Resolution Capital Execution Need

Term Definition

Regulation YY 

12 CFR Part 252, Regulation YY, Enhanced 

Prudential Standards for Bank Holding 

Companies and Foreign Banking 

Organizations, Final Rule, effective June 1, 2014

RLAP Resolution Liquidity Adequacy and 

Positioning

RLEN Resolution Liquidity Execution Need

RWAs Risk Weighted Assets

Section 165(d)

12 CFR Parts 243 and 381, Resolution Plans 

Required, issued by the Agencies and 

effective November 11, 2011

SEC Securities and Exchange Commission 

Shortcoming

A weakness or gap that raises question 

about the feasibility of a covered company’s 

resolution plan, but does not rise to the level 

of a deficiency for both the FRB and the FDIC

SFTs Secured Financing Transactions

SOS Shared and Outsourced Services

SPOE Single Point of Entry

SRO Self-Regulatory Organizations

SSA Secured Support Agreement 

TLAC Total Loss-Absorbing Capacity

TLAC Final Rule 12 CFR Part 252, Subpart P

TNC Tentative Net Capital

TRO Treasury Risk Oversight

UK United Kingdom

US United States

US ExCo US Executive Committee

US LER US Legal Entity Rationalization 

US Operations 

Collectively as the US Intermediate Holding 

Company (IHC), its IHC subsidiaries and US 

Branches of BBPLC

US RE1 US Real Estate Holdings No. 1 Limited

US RE2 US Real Estate Holdings No. 2 Limited

US RE3 US Real Estate Holdings No. 3 Limited

US RRP US Recovery and Resolution Planning 

function

USD US Dollar

VaR Value at Risk