EXHIBIT 33.1

Barclays Bank Delaware
Report on Assessment of Compliance with Servicing Criteria

1. Barclays Bank Delaware (the “Asserting
Party”) is responsible for assessing compliance with the servicing criteria applicable to it under paragraph (d) of Item 1122 of
Regulation AB, as of and for the period from January 1, 2021 to December 31, 2021 (the “Reporting Period”), as set forth in
Appendix A hereto. The transactions covered by this report include asset-backed securities transactions backed by credit card receivables,
for which transactions the Asserting Party acted as servicer, that were registered with the Securities and Exchange Commission pursuant
to the Securities Act of 1933, as amended, where the related asset-backed securities were outstanding during the Reporting Period (the
“Platform”), as listed in Appendix B hereto;

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

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

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

5. The Asserting Party has complied, in all
material respects, with the applicable servicing criteria as of December 31, 2021 and for the Reporting Period with respect to the Platform
taken as a whole; and

6. KPMG LLP, an independent registered
public accounting firm, has issued an attestation report on the Asserting Party’s assessment of compliance with the applicable
servicing criteria as of December 31, 2021 and for the Reporting Period.

March 25, 2022



| | BARCLAYS BANK DELAWARE
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| | By:                   
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APPENDIX A

|Servicing Criteria                    | Applicable Servicing Criteria for Servicer                                                                                                                                                                                                                        | Non/Applicable Servicing Criteria
|------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------
|Performed Directly by Asserting Party | Performed by vendor(s) for which Asserting Party is the Responsible Party                                                                                                                                                                                        
|Reference                             | Criteria                                                                                                                                                                                                                                                          |                                  
|                                      | General Servicing Considerations                                                                                                                                                                                                                                  |                                  
|1122(d)(1)(i)                         | Policies and procedures are instituted to monitor any performance or other triggers and events of default in accordance with the transaction agreements.                                                                                                          | x                                
|1122(d)(1)(ii)                        | If any material servicing activities are outsourced to third parties, policies and procedures are instituted to monitor the third party’s performance and compliance with such servicing activities.                                                              | x                                
|1122(d)(1)(iii)                       | Any requirements in the transaction agreements to maintain a back-up servicer for the pool assets are maintained.                                                                                                                                                 |                                  
|1122(d)(1)(iv)                        | A fidelity bond and errors and omissions policy is in effect on the party participating in the servicing function throughout the reporting period in the amount of coverage required by and otherwise in accordance with the terms of the transaction agreements. |                                  
|1122(d)(1)(v)                         | Aggregation of information, as applicable, is mathematically accurate and the information conveyed accurately reflects the information.                                                                                                                           | x                                









|Servicing Criteria                    | Applicable Servicing Criteria for Servicer                                                                                                                                                                                                                                                                                                                                      | Non/Applicable Servicing Criteria
|------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------
|Performed Directly by Asserting Party | Performed by vendor(s) for which Asserting Party is the Responsible Party                                                                                                                                                                                                                                                                                                      
|Reference                             | Criteria                                                                                                                                                                                                                                                                                                                                                                        |                                  
|                                      | Cash Collection and Administration                                                                                                                                                                                                                                                                                                                                              |                                  
|1122(d)(2)(i)                         | Payments on pool assets are deposited into the appropriate custodial bank accounts and related bank clearing accounts no more than two business days of receipt, or such other number of days specified in the transaction agreements.                                                                                                                                          | x1                               
|1122(d)(2)(ii)                        | Disbursements made via wire transfer on behalf of an obligor or to an investor are made only by authorized personnel.                                                                                                                                                                                                                                                           |                                  
|1122(d)(2)(iii)                       | Advances of funds or guarantees regarding collections, cash flows or distributions, and any interest or other fees charged for such advances, are made, reviewed and approved as specified in the transaction agreements.                                                                                                                                                       |                                  
|1122(d)(2)(iv)                        | The related accounts for the transaction, such as cash reserve accounts or accounts established as a form of overcollateralization, are separately maintained (e.g., with respect to commingling of cash) as set forth in the transaction agreements.                                                                                                                           | x2                               
|1122(d)(2)(v)                         | Each custodial account is maintained at a federally insured depository institution as set forth in the transaction agreements. For purposes of this criterion, “federally insured depository institution” with respect to a foreign financial institution means a foreign financial institution that meets the requirements of Rule 13k-1(b)(1) of the Securities Exchange Act. |                                  
|1122(d)(2)(vi)                        | Unissued checks are safeguarded so as to prevent unauthorized access.                                                                                                                                                                                                                                                                                                           |                                  

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| | 1	The | Asserting Party was responsible for sending payments on the pool assets to U.S. Bank National Association, as indenture trustee (the
“Trustee”), for the transactions included in the Asserting Party’s Platform. The Trustee was responsible for depositing
such payments on the pool assets into the appropriate custodial bank accounts.
| | ----- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

| | ● | BBD has engaged certain vendors – Wells Fargo & Company and Deluxe Corporation – that performed specific and limited
payment processing activities addressed by criterion 1122(d)(2)(i) during the period from January 1, 2021 to December 31, 2021.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | 2	The | Trustee was responsible for opening and maintaining such custodial bank accounts at the direction of the Asserting Party.
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|Servicing Criteria                    | Applicable Servicing Criteria for Servicer                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   | Non/Applicable Servicing Criteria
|------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ---------------------------------
|Performed Directly by Asserting Party | Performed by vendor(s) for which Asserting Party is the Responsible Party                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   
|Reference                             | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                  
|1122(d)(2)(vii)                       | Reconciliations are prepared on a monthly basis for all asset-backed securities related bank accounts, including custodial accounts and related bank clearing accounts. These reconciliations (A) are mathematically accurate; (B) are prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) are reviewed and approved by someone other than the person who prepared the reconciliation; and (D) contain explanations for reconciling items. These reconciling items are resolved within 90 calendar days of their original identification, or such other number of days specified in the transaction agreements. | x                                
|                                      | Investor Remittances and Reporting                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           |                                  
|1122(d)(3)(i)                         | Reports to investors, including those to be filed with the Commission, are maintained in accordance with the transaction agreements and applicable Commission requirements. Specifically, such reports (A) are prepared in accordance with timeframes and other terms set forth in the transaction agreements; (B) provide information calculated in accordance with the terms specified in the transaction agreements; (C) are filed with the Commission as required by its rules and regulations; and (D) agree with investors’ or the trustee’s records as to the total unpaid principal balance and number of pool assets serviced by the Servicer.                                                      | x3                               
|1122(d)(3)(ii)                        | Amounts due to investors are allocated and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | x4                               

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3Servicing
criterion 1122(d)(3)(i) is applicable to the activities performed by Barclays Bank Delaware with respect to the Platform only as it relates
to clauses (A) and (C) and the monitoring of Barclays Bank PLC’s preparation and filing of investor reports and the signing of investor
reports.  Such activities do not include any activities relating to the calculation of information contained in reports to investors.

4Servicing
criterion 1122(d)(3)(ii) is applicable to the activities performed by Barclays Bank Delaware with respect to the Platform only as it relates
to the forwarding of allocation and remittance instructions prepared by Barclays Bank PLC to the Trustee.  Such activities do not
include any activities relating to the calculation of information contained in reports to investors.









|Servicing Criteria                    | Applicable Servicing Criteria for Servicer                                                                                                                                                                                                                                                                                                                                                                   | Non/Applicable Servicing Criteria
|------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ---------------------------------
|Performed Directly by Asserting Party | Performed by vendor(s) for which Asserting Party is the Responsible Party                                                                                                                                                                                                                                                                                                                                   
|Reference                             | Criteria                                                                                                                                                                                                                                                                                                                                                                                                     |                                  
|1122(d)(3)(iii)                       | Disbursements made to an investor are posted within two business days to the Servicer’s investor records, or such other number of days specified in the transaction agreements.                                                                                                                                                                                                                              |                                  
|1122(d)(3)(iv)                        | Amounts remitted to investors per the investor reports agree with cancelled checks, or other form of payment, or custodial bank statements.                                                                                                                                                                                                                                                                  |                                  
|                                      | Pool Asset Administration                                                                                                                                                                                                                                                                                                                                                                                    |                                  
|1122(d)(4)(i)                         | Collateral or security on pool assets is maintained as required by the transaction agreements or related pool asset documents.                                                                                                                                                                                                                                                                               | x                                
|1122(d)(4)(ii)                        | Pool assets and related documents are safeguarded as required by the transaction agreements.                                                                                                                                                                                                                                                                                                                 | x                                
|1122(d)(4)(iii)                       | Any additions, removals or substitutions to the asset pool are made, reviewed and approved in accordance with any conditions or requirements in the transaction agreements.                                                                                                                                                                                                                                  | x                                
|1122(d)(4)(iv)                        | Payments on pool assets, including any payoffs, made in accordance with the related pool asset documents are posted to the Servicer’s obligor records maintained no more than two business days after receipt, or such other number of days specified in the transaction agreements, and allocated to principal, interest or other items (e.g., escrow) in accordance with the related pool asset documents. | x                                
|1122(d)(4)(v)                         | The Servicer’s records regarding the pool assets agree with the Servicer’s records with respect to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                    | x                                
|1122(d)(4)(vi)                        | Changes with respect to the terms or status of an obligor’s pool asset (e.g., loan modifications or re-agings) are made, reviewed and approved by authorized personnel in accordance with the transaction agreements and related pool asset documents.                                                                                                                                                       | x                                









|Servicing Criteria                    | Applicable Servicing Criteria for Servicer                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            | Non/Applicable Servicing Criteria
|------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------
|Performed Directly by Asserting Party | Performed by vendor(s) for which Asserting Party is the Responsible Party                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            
|Reference                             | Criteria                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |                                  
|1122(d)(4)(vii)                       | Loss mitigation or recovery actions (e.g., forbearance plans, modifications and deeds in lieu of foreclosure, foreclosures and repossessions, as applicable) are initiated, conducted and concluded in accordance with the timeframes or other requirements established by the transaction agreements.                                                                                                                                                                                                                                                                                | x                                
|1122(d)(4)(viii)                      | Records documenting collection efforts are maintained during the period a pool asset is delinquent in accordance with the transaction agreements. Such records are maintained on at least a monthly basis, or such other period specified in the transaction agreements, and describe the entity’s activities in monitoring delinquent pool assets including, for example, phone calls, letters and payment rescheduling plans in cases where delinquency is deemed temporary (e.g., illness or unemployment).                                                                        | x                                
|1122(d)(4)(ix)                        | Adjustments to interest rates or rates of return for pool assets with variable rates are computed based on the related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                          | x                                
|1122(d)(4)(x)                         | Regarding any funds held in trust for an obligor (such as escrow accounts): (A) such funds are analyzed, in accordance with the obligor’s pool asset documents, on at least an annual basis, or such other period specified in the transaction agreements; (B) interest on such funds is paid, or credited, to obligors in accordance with applicable pool asset documents and state laws; and (C) such funds are returned to the obligor within 30 calendar days of full repayment of the related pool assets, or such other number of days specified in the transaction agreements. |                                  









|Servicing Criteria                    | Applicable Servicing Criteria for Servicer                                                                                                                                                                                                                                                                                                                                                      | Non/Applicable Servicing Criteria
|------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------
|Performed Directly by Asserting Party | Performed by vendor(s) for which Asserting Party is the Responsible Party                                                                                                                                                                                                                                                                                                                      
|Reference                             | Criteria                                                                                                                                                                                                                                                                                                                                                                                        |                                  
|                                      | Payments made on behalf of an obligor (such as tax or insurance payments) are made on or before the related penalty or expiration dates, as indicated on the appropriate bills or notices for such payments, provided that such support has been received by the Servicer at least 30 calendar days prior to these dates, or such other number of days specified in the transaction agreements. |                                  
|1122(d)(4)(xii)                       | Any late payment penalties in connection with any payment to be made on behalf of an obligor are paid from the Servicer’s funds and not charged to the obligor, unless the late payment was due to the obligor’s error or omission.                                                                                                                                                             |                                  
|1122(d)(4)(xiii)                      | Disbursements made on behalf of an obligor are posted within two business days to the obligor’s records maintained by the Servicer, or such other number of days specified in the transaction agreements.                                                                                                                                                                                       |                                  
|1122(d)(4)(xiv)                       | Delinquencies, charge-offs and uncollectible accounts are recognized and recorded in accordance with the transaction agreements.                                                                                                                                                                                                                                                                | x                                
|1122(d)(4)(xv)                        | Any external enhancement or other support, identified in Item 1114(a)(1) through (3) or Item 1115 of Regulation AB, is maintained as set forth in the transaction agreements.                                                                                                                                                                                                                   |                                  









APPENDIX B

Barclays Dryrock Issuance Trust

Series 2018-VFN1

Series 2018-VFN2

Series 2019-1

Series 2021-1