EXHIBIT34.1

 

Reportof Independent Registered Public Accounting Firm

TheBoard of Directors

BarclaysBank Delaware:

 

Wehave examined management’s assertion, included in the accompanying Report on Assessment of Compliance with Servicing Criteria,that Barclays Bank Delaware (the Company or the Asserting Party) complied with the servicing criteria set forth in Item 1122(d)of the Securities and Exchange Commission’s Regulation AB (the Servicing Criteria) for the asset-backed securities transactionsbacked by credit card receivables, for which transactions the Asserting Party acted as servicer as of and for the year ended December31, 2019 (the Reporting Period), that were registered with the Securities and Exchange Commission pursuant to the Securities Actof 1933, as amended, where the related asset-backed securities were outstanding during the Reporting Period (the Platform), exceptfor servicing criteria 1122(d)(1)(iii), 1122(d)(1)(iv), 1122(d)(2)(ii), 1122(d)(2)(iii), 1122(d)(2)(v), 1122(d)(2)(vi), 1122(d)(3)(iii),1122(d)(3)(iv), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii), 1122(d)(4)(xiii), and 1122(d)(4)(xv), which the Company has determinedare not applicable to the activities it performs with respect to the Platform. The Company has determined that servicing criterion1122(d)(3)(i) is applicable to the activities performed by the Company with respect to the Platform only as it relates to clauses(A) and (C), the monitoring of the preparation and filing of investor reports and the signing of investor reports. The Companyhas determined that servicing criterion 1122(d)(3)(ii) is applicable to the activities performed by the Company with respect tothe Platform only as it relates to the forwarding of allocation and remittance instructions to the trustee. Appendix B to management’sReport on Assessment of Compliance with Servicing Criteria identifies the individual asset-backed transactions and securitiesdefined by management as constituting the Platform. Management is responsible for the Company’s compliance with the ServicingCriteria. Our responsibility is to express an opinion on management’s assertion about the Company’s compliance withthe Servicing Criteria based on our examination.

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

Asdescribed in the accompanying Report on Assessment of Compliance with Servicing Criteria, for servicing criteria 1122(d)(2)(i)the Company has engaged various vendors to perform the activities required by these servicing criteria. The Company has determinedthat none of these vendors is considered a “servicer” as defined in Item 1101(j) of Regulation AB, and the Companyhas elected to take responsibility for assessing compliance with the servicing criteria applicable to each vendor as permitted

bythe SEC’s *Compliance and Disclosure Interpretation (C&DI) 200.06, Vendors Engaged by Servicers*(C&DI 200.06).As permitted by C&DI 200.06, the Company has asserted that it has policies and procedures in place designed to provide reasonableassurance that the vendors’ activities comply in all material respects with the servicing criteria applicable to each vendor.The Company is solely responsible for determining that it meets the SEC requirements to apply C&DI 200.06 for the vendorsand related servicing criteria as described in its assertion, and we performed no procedures with respect to the Company’seligibility to apply C&DI 200.06.

Inour opinion, management’s assertion that Barclays Bank Delaware complied with the aforementioned Servicing Criteria, includingservicing criteria 1122(d)(2)(i) for which compliance is determined based on C&DI 200.06 as described above, as of and forthe year ended December 31, 2019 is fairly stated, in all material respects.

/s/ KPMG LLP

 

Philadelphia,PA

March 27,2020

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