ERISA Plans Disclosures

Barclays Bank PLC, Barclays Capital Inc. and Affiliates (“Barclays”): Certain Disclosure for Clients, Including Covered ERISA Plans Under Section 408(b)(2) of ERISA


This document provides an overview of the services provided by Barclays Bank PLC (“BBPLC”), Barclays Capital Inc. (“BCI”) and its affiliates (each a “Barclays Entity,” and collectively “Barclays”), and of the fees and other compensation received by Barclays from those clients of Barclays with whom Barclays has a direct relationship, including clients which are employee benefit plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) (each, a “Plan”).

These materials are intended to provide clients with information about our services and compensation and are intended also to include information for Plans (and their representatives) described under final U.S. Department of Labor Regulations issued under Section 408(b)(2) of ERISA. This document should be read in conjunction with other fee disclosures, notices, agreements and other materials furnished by a Barclays Entity.

With respect to Plan clients, if you are not the “responsible plan fiduciary” authorized to engage service providers for the Plan, please forward these materials to the appropriate Plan fiduciary.

This document is not an agreement for services, nor is it intended to replace or amend any agreement or other contract Barclays may have with or in respect of a client, written or otherwise, nor is it any guarantee with respect to the pricing of any of our services. In the event of any discrepancy between the information contained in these materials, and the terms that govern our contractual relationships with respect to direct relationships with clients, the latter will govern.

If you are a customer of an introducing broker not affiliated with Barclays, please contact that broker for any required disclosures. We invite interested clients (and particularly Plan clients) to periodically check this website (http://www.barclays.com/disclosures/erisa.html), which may include additional or supplementary information from time to time as the occasion arises. Please note that this document does not relate to the products and services obtained through the Barclays Wealth and Investment Management platform.

To the extent any client has a relationship with Barclays Wealth and Investment Management, they should consult their representative at Barclays Wealth and Investment Management.


BCI is both a U.S. registered broker-dealer and a U.S. registered investment adviser under the Investment Advisers Act of 1940, as amended. Except as provided in writing (and only to such extent) Barclays does not expect to be acting in an advisory capacity (for purposes of the Investment Advisers Act) or as a fiduciary within the meaning of Section 3(21) of ERISA with respect to Plans.

General Description of Services

As a global financial firm, Barclays offers a full spectrum of products and services to help meet its clients’ needs.

The services Barclays provides to clients may generally be divided into the following categories: (1) establishment and maintenance of a securities brokerage account with or without custody at a Barclays Entity, (2) the provision of short-term “sweep” or other money market enhancements for available credit balances pending reinvestment or redistribution on behalf of a client account custodied or maintained at a Barclays Entity,ii (3) the execution of agency transactions in U.S. securities and certain foreign securities, U.S. futures and certain foreign futures, and certain over-the-counter (“OTC”) products, including agency transactions in U.S. fixed income securities by or through BCI, (4) the provision of executing, clearing, settlement, financial intermediation, and delivery services for foreign exchange commodities and OTC derivatives, and (5) matching trades, effecting settlement and payments and facilitating deliveries.

Certain services listed herein may include other sub-services such as sub-custodians and subclearers that are not specifically delineated. Barclays also provides a number of ancillary services, for example, research reports, analytics through Barclays Live, as well as our direct market access (“DMA”) capabilities and electronic execution. Please refer to any Barclays contracts or agreements for further details concerning a client’s access to any such services and the terms and conditions pursuant to which they are provided.

A Barclays Entity may also provide client account activity reports and other confirmations of transactions, and estimated price or indicative valuations, in any case, without undertaking to render investment advice, manage money or act as a fiduciary with respect to the Plan accounts.

Also, a Barclays Entity may offer services to help Plans and other clients transition portfolios of securities and other positions. The terms and conditions that govern such arrangements, along with the fees and other commissions will be provided under the terms of the applicable transition services agreement (or similar agreement).

This document provides in tabular form: (1) a description of the services that a Barclays Entity may provide under a contract or arrangement with a Plan, (2) a description of the fees and compensation for such services (or where they may otherwise be found), (3) a description of indirect compensation, potential conflicts of interest and other commercial considerations with respect to such services and (4) a description of payments which may be made among related parties or subcontractors with respect to such services.

Description of Services offered by Barclays

Products and Services

Description of Services offered by Barclays

Barclays Acting as Client's Agent in Securities Transactions ("Cash Equities")

BCI will provide services to clients as either a broker or clearing agent (or both) in connection with the purchase and sale (including short sales) of exchange listed or OTC securities or options executed on an agency basis, including, but not limited to, US equities (including “ADRs”), exchange-traded funds (“ETFs”) and foreign securities (“ORDs”). In some limited cases, BCI may directly or through others, including affiliates, also provide similar agency related execution services in connection with fixed income securities. Where applicable, BCI or an identified affiliate may also provide custody related services, and the provision of short-term “sweep” or other money market enhancements for available credit balances pending reinvestment or redistribution on behalf of a client account custodied or maintained at a Barclays Entity.

Barclays Acting as Client's Agent in Executing and/or Clearing Futures Transactions ("Futures")

Please refer to the relevant Futures and Options Customer Account Agreement and all amendments, annexes, addenda and schedules thereto ("Futures Agreement") as well as any International Uniform Brokerage Execution Services Agreement ("Give Up Agreement") for a description of the services provided and the terms and conditions which govern BCI and other parties involved with respect to such services.


Where applicable, BCI or another Barclays Entity may also provide custody related services, and the provision of short-term "sweep" or other money market enhancements for available credit balances pending reinvestment or redistribution on behalf of a client account custodied or maintained at BCI or another Barclays Entity.


To the extent BBPLC or other identified Barclays Entity provides financial intermediation, the terms and conditions of such service will be detailed in a separate agreement.


See also section entitled "OTC Derivatives Execution/Clearing/Settlement/Delivery" as applicable.

OTC Derivatives Execution/Clearing/Settlement/Delivery ("OTC Clearing")

Please refer to the relevant Cleared Derivatives Transactions Addendum ("Cleared Derivatives Addendum") of any Futures Agreement (or other applicable agreement relating to execution and clearing) for a description of the terms and conditions which govern BCI's or an affiliate’s clearing and other services on the client’s behalf of swaps, forwards, currency, commodities, options or similar transactions ("OTC Clearing") entered into by a client in the OTC market, and/or on an execution facility or on a designated contract market that are submitted for clearing at a derivatives clearing organization. The Cleared Derivatives Addendum supplements and forms a part of the Futures Agreement.

Prime Brokerage

The services a Barclays Entity may provide with respect to Prime Brokerage clients are detailed in the Prime Brokerage Services Agreement, including all attached terms, schedules, supplements and exhibits thereto (collectively "Prime Brokerage Agreement"). For further information, see the no-action letter dated January 25, 1994 issued by the Division of Market Regulation of the Securities and Exchange Commission. These services may include execution of securities and futures transactions, clearing, custody, and asset servicing, certain customized technology or research, provision of risk analytic technology, sometimes supplemented by consultations with senior risk professionals of a Barclays Entity, introductions to other financial market participants where there may be an interest in exploring mutually beneficial commercial opportunities, the maintenance of accounts for the purpose of carrying, custodying or financing positions in securities, futures, loans (including whole mortgage loans and bank debt), currencies, commodities or derivatives, and all transactions in which a Barclays Entity provides clearing, custody or settlement services to or for a client (including as prime broker in connection with prime broker transactions or fixed income clearing transactions, or in connection with any give-up, free delivery or unsettled transaction, or when acting as a clearance and/or settlement agent in any clearing system, market, or exchange, domestic or international) or transactions in, or the custody of, cash made in connection with, or in contemplation of, any of the foregoing. A Barclays Entity may further assist with account maintenance duties, including account set up and updating, client trading and processing journals, and other account maintenance-related services. A Barclays Entity may also provide transaction statements under the terms and conditions provided in the Prime Brokerage Agreement applicable to a client account. On a principal basis, a Barclays Entity may also assist clients by lending clients funds or securities or otherwise extending credit.


Also, please see the sections entitled "Barclays Acting as Client’s Agent in Securities Transactions" and "Barclays Acting as Client's Agent in Executing and/or Clearing Futures Transactions."

Direct compensation

Products and Services

Direct compensation

Cash Equities

With respect to securities related transactions, this section relates to only those arrangements where BCI has a direct relationship with a client, including a Plan that is not covered under a Prime Brokerage Agreement. For securities transactions executed in connection with any Prime Brokerage relationship, please see “Prime Brokerage” below.


BCI will generally receive a commission from clients with respect to any trade executed on an agency basis for which BCI or another identified Barclays Entity acts as broker or clearing agent. The aggregate amount of the commission will be provided to the client at the time it (or the responsible Plan fiduciary) contacts BCI to place an order and will be confirmed in a written confirmation statement that will be received after the trade has been executed. Commissions may depend on a variety of factors, including market conditions, volume, quantities bought or sold, and exchange or other clearing and settlement considerations. Because many factors beyond the control of Barclays can affect the pricing of any securities executed by BCI (or another identified Barclays Entity) as agent on behalf of any client, it is difficult to predict with any sort of precision or certainty as to what a given client, including any Plan, may expect to pay BCI (or such other Barclays Entity) in the form of commissions for such services and Barclays believes it may not be possible to predict with certainty the jurisdictions in which any given client may execute any such transactions outside of the United States. In addition to dynamic market conditions, commission rates may often be affected by changes in trading strategies, trading volume, and/or trading frequency.


By way of illustration only, and looking at BCI’s prior one year ending December 31, 2011, BCI has typically charged no more than 5 cents per share for US and Canadian executions and 3 cents per contract for U.S. listed options, and typically received no more than 25 cents or basis points a share for equities transactions in developed markets, and 50 cents or basis points a share for equities transactions in developing markets. Please also note that BCI or an affiliate may act as principal (or act on a riskless principal basis) on certain transactions. In such cases, BCI or an affiliate receives compensation from clients by adding a mark-up to purchases, and deducting a mark-down from sales. This mark-up or mark-down will be reflected in the price when BCI or an affiliate acts as principal.


BCI or another identified Barclays Entity will generally receive a commission with respect to any trade for which such Barclays Entity acts as the client’s broker or clearing broker or agent. The terms governing commissions and other similar charges the client pays will be set forth in the client’s Futures Agreement (including any fee schedule related thereto that is provided to a client or its representative) or otherwise set forth in a writing (including e-mail) provided to the client or its representative. As provided in applicable agreements or arrangements, clients, including Plan clients, are required to pay brokerage and commission charges, give up fees, ticket charges, administrative charges, exchange fees, and service fees as Barclays may from time to time charge, all Transaction Facility (as defined in the Futures Agreement), clearing firm or National Futures Association (“NFA”) fees or charges, or any other transaction fees, regulatory fees and service charges incurred with respect to each contract executed thereunder, as well as other items specifically referred to in the Futures Agreement. Such fees are set forth in the relevant Futures Agreement and fee schedule or related addendum associated with the client’s Futures and OTC Clearing documentation. See also OTC Clearing to the extent applicable.


To the extent BBPLC or other identified Barclays Entity provides financial intermediation, the terms and conditions of such service will be detailed in a separate agreement.

OTC Clearing

When BCI or an identified Barclays affiliate acts as a client’s clearing agent or executes transactions as agent in connection with OTC derivatives and/or other transactions that are cleared or may be required to be cleared pursuant to applicable law, fees will be detailed in a client’s Futures Agreement, or supplemented by any Cleared Derivatives Addendum, or similar document, including any fee schedules or addenda related thereto, or otherwise as provided in writing.


Also please see the materials described with respect to Cash Equities and Futures where applicable to the Prime Brokerage relationship.

Prime Brokerage

Commissions or fees payable to BCI in connection with securities transactions executed on an agency basis with or through a Barclays Entity, along with ticket charges, administrative charges and certain fees for exercises of options, and fees for the clearing and custody of international assets (where applicable), as well as compensation received in connection with certain financing or other principal transactions are generally disclosed in a “Price Proposal” (or similar document or documents) in combination with the Prime Brokerage Agreement. Any changes to the Price Proposal are timely provided. Finally, all fees are posted to client accounts on a monthly basis, typically within the first several days of the new month. Commissions received in connection with BCI’s acting as broker or clearing agent for futures transactions will be disclosed in a client’s Futures Agreement and related documentation or schedule or in the Price Proposal. In addition, certain charges such as administrative fees, cancel and correct fees, wire fees, transfer fees and other fees may be charged as disclosed to a client in writing. Finally, certain debt fees for borrowed cash and securities lending fees (which could be paid in the form of rebates in cash) may be paid for borrowed securities, as detailed in the Price Proposal.


Also, please see the sections entitled Cash Equities and Futures.

Indirect compensation, potential conflicts of interest and other commercial considerations

Products and Services

Indirect compensation, potential conflicts of interest and other commercial considerations


In certain cases, BCI and other Barclays Entities may derive a benefit in connection with providing services to clients, including earnings on funds awaiting investment or reinvestment or funds pending distribution (i.e., float). In general, the amount of float earned is the difference between the rates stated in the governing documents and schedules or addenda for the appropriate product or service to be received by the client (e.g., for Prime Brokerage, the Price Proposal or related documentation) and the rate which a Barclays Entity earns at its own risk. Historically, such amounts earned by BCI or another Barclays Entity have typically tracked relatively short term interest rate benchmark, including but not limited to Fed Funds or LIBOR.


BCI and/or one or more of its affiliates may have ownership interests in one or more U.S. or foreign exchanges, execution facilities and clearing houses, consortium- owned alternative trading platforms (“ATS”) or similar venues that a client may trade on or that may clear the client’s trades (“Market Venues”). As a result, the client (including Plans and their responsible fiduciaries) should be aware that BCI and its affiliates might receive financial benefits related to its ownership interest in such Market Venues or revenue sharing arrangements amongst members when trades are executed on or cleared at such a Market Venue. Clients should contact an appropriate Barclays Entity representative directly if they would like to know whether any Barclays Entity has an ownership interest in a particular Market Venue. See also the discussion in Cash Equities and the information provided in Exhibit A.


Certain of these Market Venues offer BCI (and its affiliates) rebates, credits for orders that provide liquidity to their books and assess fees for orders that take liquidity from their books, provide discounts to a Barclays Entity for volume of trading, or pay a Barclays Entity for order flow. Additionally, there are some Market Venues that give credits for orders that take liquidity and assess fees for orders that provide liquidity. Whether any Market Venue offers Barclays a net credit or imposes net charges is dependent on a number of market and institution-wide factors, including the volume of trading a Barclays Entity sends to the Market Venue over a pre-established period. Accordingly, Barclays does not believe that the availability or amount of any such credit or rebate is based on the activity of any one account. Barclays believes that the discounts, rebates and other potential benefits derived from Market Venues have historically fluctuated often and are reasonably expected to change over time depending on market conditions and other factors. These operational facts, when combined with the multiple execution strategies Barclays typically employs across Market Venues over time for best execution make it difficult to predict the value (if any) Barclays expects it may receive from such Market Venues.


From time to time, employees of BCI, BBPLC or their affiliates may receive non-monetary compensation such as gifts and entertainment from vendors with whom they may engage in business dealings on behalf of clients. However, given the nature of Barclays’ businesses, Barclays reasonably believes that any gifts and entertainment received by employees of a Barclays Entity are typically received in the context of a general business relationship and should not be viewed as attributable or allocable to any transactions engaged in on behalf of their clients. BCI and BBPLC have historically maintained policies and procedures relating to gifts and entertainment activities in response to numerous laws and regulations with both local and global applicability.

Cash Equities

In connection with brokerage services, BCI may route orders to Market Venues (as defined above) such as national securities exchanges, alternative trading systems, electronic communications networks, as well as to broker-dealers.


Pursuant to SEC Rule 606, we disclose, on a quarterly basis, covered Market Venues to which we route customer orders for execution as required by Rule 606. Please follow the attached hyperlink to our latest report. http://www.barcap.com/site-footer/regulatory-disclosures.html. In addition, although BCI believes it is unable to predict with any meaningful degree of certainty what Market Venue, if any, may be used in connection with any client’s order or execution, the United States and Canada equities and listed options Market Venues contained in Exhibit A are listed by BCI for general consideration and may contain certain pricing and fee information that have been developed by the venue for a number of purposes. As Barclays does not typically control the content or timing of updates of information provided by any particular Market Venue, clients are advised to contact these Market Venues directly for information.


In connection with its execution and clearing services in futures and/or OTC Clearing to its clients, a Barclays Entity may direct orders to persons or organizations unaffiliated with it, such as floor brokers and other futures executing institutions or market makers as brokers or agents for the client or with respect to execution facilities for OTC cleared derivatives. BCI or other Barclays Entities may have certain agreements with some of these institutions or persons, and, where permitted, BCI or other Barclays Entities may receive volume discounts or similar concessions or rebates as a function of the volume of transactions directed to such persons or organizations. However, BCI believes that given its execution activities, it is not possible to meaningfully determine in advance the existence of, or amount of any such compensation with respect to any given client.


As described in the applicable Futures Agreement, a client generally grants BCI the right to borrow, pledge, re-pledge, transfer hypothecate, re-hypothecate, engage in repurchase or reverse repurchase transactions with respect to, invest or loan, either separately or with the property of other clients, to either BCI or to others, any securities or other property held by BCI on margin for a client account or as margin or collateral therefor. As the Cleared Derivatives Addendum supplements and forms part of the relevant Futures Agreement, a client generally grants BCI the same rights described in the immediately preceding sentence for purposes of OTC Clearing. CFTC regulations limit the instruments in which BCI can invest a client’s collateral. Accordingly, the return that BCI earns by investing that collateral will be limited to the returns on such instruments and market conditions. Pursuant to CFTC Rule 1.25, a registered futures commission merchant (“FCM”), such as BCI, may invest margin in U.S. government securities, municipal securities, U.S. agency obligations, certificates of deposits of certain banks, commercial paper fully guaranteed as to principal and interest by the United States under the Temporary Liquidity Guarantee Program as administered by the Federal Deposit Insurance Corporation, corporate notes or bonds fully guaranteed as to principal and interest by the United States under the Temporary Liquidity Guarantee Program as administered by the Federal Deposit Insurance Corporation (corporate notes or bonds), and interests in money market mutual funds, or, in certain cases, agreements for resale or repurchase of certain instruments as well as obligations issued by the Federal National Mortgage Association or the Federal Home Loan Mortgage Association while such entities operate under the conservatorship or receivership of the Federal Housing Finance Authority with capital support from the United States. CFTC Rule 1.25 contains additional details and requirements and may be updated from time to time.


Finally, BCI may earn amounts from a client’s financing of its margin obligations. BCI may derive income in the form of the spread between the interest paid to a client on equity balances in excess of required margin and the interest BCI earns from any short-term financing, at its own risk and return. BCI may also earn float on a client’s account balance deficits. The relevant interest rates are set forth on the interest or fee schedule associated with the client’s Futures Agreement.

OTC Clearing

See the section entitled Futures

Prime Brokerage

In connection with Prime Brokerage relationships, clients, including Plan clients having a direct Prime Brokerage relationship with BCI, or such other Barclays Entity identified in its applicable agreement, may grant BCI (and its affiliated entities) the right, to the extent permissible under applicable law, to hold and re-register collateral posted by or on behalf of the client, pledge, repledge, hypothecate, rehypothecate, sell, lend, or otherwise transfer or use any amount of the collateral, separately or together with other assets or other amounts of the collateral, with all attendant rights of ownership (including the right to vote securities), and to use or invest cash collateral at BCI’s (or its affiliate’s) own reward (which may be without limitation) and risk. The amounts which may be rehypothecated under a Prime Brokerage relationship with BCI are generally limited to 140% of, or other applicable regulatory limits on, outstanding liability (i.e., the debit balance) to the Prime Broker. Please see Appendix A for selected information concerning Market Venues. For the purposes of the return of any collateral to customer, the Prime Brokerage Agreement provides for the return of collateral by delivering securities or other financial assets of the same issuer, class and quantity as the collateral initially transferred. Additional terms and conditions applicable to Plan accounts may be found in the Prime Brokerage Agreement.


Also, please see the sections entitled Cash Equities and Futures.

Payments which may be made among related parties and subcontractors

Products and Services

Payments which may be made among related parties and subcontractors


Cash Equities; Futures; OTC Derivatives

To the extent a client executes trades on a foreign exchange, BCI, BBPLC, or an affiliate of BCI or BBPLC may act as broker or clearing agent or both with respect to securities transactions. In connection with any such transaction, BCI or BBPLC may allocate a portion of the amount received from the client to such affiliate for the execution or clearing services such affiliate performs. Applicable tax laws require that the fees retained by such Barclays Entities reflect the fees that would be paid in arm’s length negotiations. In most instances, Barclays believes such allocations do not involve actual payments.


Similarly, in connection with its execution and clearing services in futures to its clients, BCI may direct orders to affiliates of BCI, which will act as brokers and agents of the client. In connection with any such transaction, a portion of its commission that is actually received may be allocated to such affiliate, based on a fee schedule and based on the services such affiliate performs.


All or a portion of the execution, clearing and settlement fees may be passed on to introducing brokers, floor brokers, clearinghouses or settlement or execution facilities as set forth on the relevant fee schedule.


In the context of Futures and OTC Derivatives, clients should consult the fee schedules or other related addenda associated with the Futures Agreement or Cleared Derivatives Addendum for additional information or otherwise contact their BCI representative for more information.


See also Prime Brokerage, if applicable

Prime Brokerage

Portions of the domestic clearing and settlement fees may be passed on to clearinghouses or settlement facilities (such as DTC). These may include, for example, fees for exercises and assignments of options and ticket charges for settlement of trades in equities and fixed income products. Portions of international clearing and custody fees may also be passed on to affiliated or unaffiliated local sub-custodians, agents or clearinghouses to compensate for services in clearance of trades or custody of securities in certain markets.


BCI, or an affiliate, or as otherwise denoted in the Prime Brokerage Agreement, may also hire sub-custodians, including those listed below. A link to their schedule of fees is also included, where available. Clients should check these websites for periodic updates.


Depository Trust Company (acting together with its clearing affiliates, the National Securities Clearing Corporation and Fixed Income Clearing Corporation);


The Options Clearing Corporation; http://www.optionsclearing.com/membership/schedule-of-fees/


Euroclear Bank SA/NV; https://www.euroclear.com/en.html


These sub-custodians (“Primary Sub-custodians”) offer services themselves as well as through their significant networks of members and participants. It is Barclays’ belief that the Primary Sub-custodians occupy a position in the market, which, together with their networks, effectively makes them essential utilities for clearing, settlement, custody and other related services of the type provided through Prime Brokerage.


While it is Barclays’ belief that the above mentioned Primary Sub-custodians can be expected to occupy a substantial position in the marketplace, other sub-custodians in other jurisdictions may charge a variety of other custody, transaction and related fees. Some of these other sub-custodians perform special services, depending on the legal, regulatory and operational environment of the jurisdiction involved. Many of these other sub-custodians are banks which are retained to hold securities where the Primary Sub-custodians are either not permitted by law to do so or are otherwise ineligible. It is Barclays’ experience that these other sub-custodians are compensated on an arm’s length basis depending on the fees and other services as specified in the relevant sub-custodial (or other relevant) agreement.For a list of sub-custodians, including where any BCI affiliate is used, please contact a BCI representative. The amount of any such fees is typically provided in the Price Proposal.

Where manner of payment and termination provisions may be located*

Products and Services

Where manner of payment and termination provisions may be located*

Cash Equities

Manner of payment is not typically addressed contractually for these relationships. Unless otherwise agreed to by the parties, payments in the United States are typically made at the time of the transaction.

Futures/OTC Clearing

See Futures Agreement; Cleared Derivatives Addendum and any applicable fee schedules thereto.

Prime Brokerage

See Prime Brokerage Agreement and Price Proposal.

*Termination of Arrangements. Barclays will not generally receive any compensation for the termination of Plan relationships other than the payment of commissions, fees or costs that have been incurred but not yet paid, unless otherwise disclosed in the applicable agreement.

Schedule C of Form 5500. Based on Q&As 3&4 of the U.S. Department of Labor’s FAQs About The 2009 Form 5500 Schedule C, we generally expect all services that we may provide to covered ERISA plans to constitute ordinary operating expenses for Form 5500 purposes. Ordinary operating expenses do not constitute indirect compensation that is reportable on Form 5500. Thus, Barclays does not expect to provide any covered ERISA clients with any Form 5500 related information in connection with any services a Barclays Entity may provide. See http://www.dol.gov/ebsa/faqs/faq_scheduleC.html

Market value

Market value


Link with information developed by venue for general purposes


BATS Exchange


Boston Options Exchange



Chicago Board of Options


International Securities Exchange




NASDAQ Options Market






NYSE ARCA Options Exchange




Toronto Stock Exchange



i Barclays Capital Inc., an affiliate of Barclays Bank PLC. Barclays Capital Inc. is a registered broker dealer and investment adviser, regulated by the U.S. Securities and Exchange Commission. Member FINRA/SIPC. Barclays Bank PLC, registered in England and Wales (no. 1026167), has a registered office at 1 Churchill Place, London, E14 5HP, United Kingdom, and is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.

Except as expressly provided herein, the information contained in this disclosure does not relate to products and services sold or distributed through Barclays Wealth and Investment Management.

ii Barclays may determine not to pay interest on free credit balances representing (a) uncollected funds; (b) funds that are deposited and subsequently withdrawn prior to the expiration of the minimum time period required by Barclays; or (c) any credit balances created or increased solely for the purpose of receiving interest thereon.