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, 2013 to December 31, 2013 (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 third parties to perform
all or a portion of certain servicing criteria set forth in paragraph (d) of Item 1122 of Regulation AB. In each such case, these
third parties have been identified as Parties Participating in the Servicing Function and, except as set forth in paragraph 3 below,
have provided assessments of compliance pursuant to Item 1122 of Regulation AB. The Asserting Party is not taking any responsibility
for assessing compliance with the servicing criteria or portion of the servicing criteria applicable to such third parties’
activities;



3. 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 Interpretation 17.06 of
the SEC Division of Corporation Finance Manual of Publicly Available Telephone 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.



4. Except as set forth in paragraph 5 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;



5. 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 with respect to the Platform;



6. The Asserting Party has complied, in all material respects, with
the applicable servicing criteria as of December 31, 2013 and for the Reporting Period with respect to the Platform taken as a
whole; and



7. PricewaterhouseCoopers LLP, a registered public accounting firm,
has issued an attestation report on the Asserting Party’s assessment of compliance with the applicable servicing criteria
as of December 31, 2013 and for the Reporting Period.



| |                        |                        
| | ---------------------- | -----------------------
| | March 17, 2014        
| |                        |                        
| | BARCLAYS BANK DELAWARE
| |                        |                        
| | By:                    | /s/ Gerald Pavelich    
| | Name:                  | Gerald Pavelich        
| | Title:                 | Chief Financial Officer













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.                                                                                                                                                                                                                                                      | ý                                
|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.                                                                                                                                                                                        | ý                                
|1122(d)(1)(iii)                       | Any
      requirements in the transaction agreements to maintain a back-up servicer
      for the credit card accounts or accounts 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.                                                                                                                     |                                  
|                                      | 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 following
      receipt, or such other number of days specified in the transaction agreements.                                                                                                                                               | ý1                               
|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.                                                                                                                                 | ý2                               
|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.                                                                                                                                                                                                                                                                                                                                   |                                  









|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 are (A) mathematically accurate; (B) prepared within 30 calendar days after the bank statement cutoff date, or such other number of days specified in the transaction agreements; (C) 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.                   | ý                                
|                                      | 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 credit card accounts serviced by the Servicer. |                                  
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                  
|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 credit card accounts is maintained as required by the transaction
      agreements or related pool asset documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | ý                                
|1122(d)(4)(ii)                        | Pool
      assets and related documents are safeguarded as required by the transaction
      agreements                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | ý                                
|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.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          | ý                                
|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.                                                                                                                                                                                                                                                                       | ý                                









|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)(v)                         | The
      Servicer’s records regarding the accounts agree with the Servicer’s
      records with respect to an obligor’s unpaid principal balance.                                                                                                                                                                                                                                                                                                                                                                                                                                    | ý                                
|1122(d)(4)(vi)                        | Changes
      with respect to the terms or status of an obligor's account  (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.                                                                                                                                                                                                                                                                                                          | ý                                
|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.                                                                                                                                                                                                                                                        | ý                                
|1122(d)(4)(viii)                      | Records
      documenting collection efforts are maintained during the period an account
      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).                                | ý                                
|1122(d)(4)(ix)                        | Adjustments to interest rates or rates of return for accounts with variable rates are computed based on the related account documents.                                                                                                                                                                                                                                                                                                                                                                                                                                                | ý                                
|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. |                                  
|1122(d)(4)(xi)                        | 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.                                                                                                                                                                                                                                                                                                                                                                                                                                                      | ý                                
|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.                                                                                                                                                                                                                                                                                                                                                                                       |                                  






1The 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 –
that performed specific and limited payment processing activities addressed by criterion 1122(d)(2)(i) during the period from January
1, 2013 to December 31, 2013.
| | - | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

2 The Trustee was responsible
for opening and maintainingsuch custodial bank accounts at the direction of the Asserting Party.









APPENDIX B



Barclays Dryrock Issuance Trust



Series 2012-1

Series 2012-2

Series 2013-1