0001752724-20-019385.txt : 20200207
0001752724-20-019385.hdr.sgml : 20200207
20200207123018
ACCESSION NUMBER: 0001752724-20-019385
CONFORMED SUBMISSION TYPE: N-CEN
PUBLIC DOCUMENT COUNT: 5
CONFORMED PERIOD OF REPORT: 20191130
FILED AS OF DATE: 20200207
DATE AS OF CHANGE: 20200207
EFFECTIVENESS DATE: 20200207
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: EXCHANGE TRADED CONCEPTS TRUST
CENTRAL INDEX KEY: 0001452937
IRS NUMBER: 000000000
STATE OF INCORPORATION: DE
FISCAL YEAR END: 0731
FILING VALUES:
FORM TYPE: N-CEN
SEC ACT: 1940 Act
SEC FILE NUMBER: 811-22263
FILM NUMBER: 20586259
BUSINESS ADDRESS:
STREET 1: 10900 HEFNER POINTE DRIVE, SUITE 207
CITY: OKLAHOMA CITY
STATE: OK
ZIP: 73120
BUSINESS PHONE: 405-778-8377
MAIL ADDRESS:
STREET 1: 10900 HEFNER POINTE DRIVE, SUITE 207
CITY: OKLAHOMA CITY
STATE: OK
ZIP: 73120
FORMER COMPANY:
FORMER CONFORMED NAME: FAITHSHARES TRUST
DATE OF NAME CHANGE: 20090717
FORMER COMPANY:
FORMER CONFORMED NAME: FAITHSHARES INC
DATE OF NAME CHANGE: 20090225
FORMER COMPANY:
FORMER CONFORMED NAME: VERITAS FUNDS INC
DATE OF NAME CHANGE: 20081230
0001452937
S000039599
FLAG-Forensic Accounting Long-Short ETF
C000122170
FLAG-Forensic Accounting Long-Short ETF
FLAG
0001452937
S000042584
Hull Tactical US ETF
C000131678
Hull Tactical US ETF
HTUS
0001452937
S000061191
Innovation Shares NextGen Protocol ETF
C000198171
Innovation Shares NextGen Protocol ETF
KOIN
0001452937
S000061192
Ideanomics NextGen Vehicles & Technology ETF
C000198172
Ideanomics NextGen Vehicles & Technology ETF
EKAR
N-CEN
1
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0001452937
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811-22263
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EXCHANGE TRADED CONCEPTS TRUST
811-22263
0001452937
549300TXJW88BSB0KL90
10900 HEFNER POINTE DRIVE
SUITE 207
OKLAHOMA CITY
73120
US-OK
US
405-778-8377
SEI INVESTMENTS DISTRIBUTION CO.
1 Freedom Valley Drive
OAKS
19456
610-676-1000
Records as Distributor for Trust
Penserra Capital Management, LLC
4 Orinda Way
Suite 100-A
Orinda
94563
1-800-456-8850
Records as sub-advisor for Trust
Vident Investment Advisory, LLC
300 Colonial Center Parkway
Suite 330
Roswell
30076
1-404-487-1961
Records as sub-advisor for Trust
Hull Tactical Asset Allocation, LLC
141 W. Jackson Blvd.
Suite 1650
Chicago
60604
1-312-356-3150
Records as sub-advisor for Trust
Exchange Traded Concepts, LLC
10900 Hefner Pointe Drive
Suite 207
Oklahoma City
73120
1-405-778-8377
Records as Advisor for Trust
BROWN BROTHERS HARRIMAN & CO.
40 Water Street
Boston
02109
617-772-1818
Records as Custodian for Trust & Transfer Agent
The Bank of New York Mellon
240 Greenwich Street
New York
10286
1-212-495-1784
Records As Transfer Agent For Trust & Custodian for Trust
SEI INVESTMENTS GLOBAL FUNDS SERVICES
1 Freedom Valley Drive
OAKS
19456
610-676-1000
Records as Administrator for Trust
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J. Garrett Stevens
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Timothy Jacoby
N/A
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David M. Mahle
N/A
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Kurt Wolfgruber
N/A
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Mark Zurack
N/A
N
Joseph J. Scavetti, Jr.
N/A
480 Swedesford Rd.
Wayne
19406
XXXXXX
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N
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SEI INVESTMENTS DISTRIBTUION CO.
8-27897
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N/A
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N
Cohen & Company, Ltd
925
N/A
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N
N
N
N
N
N
Innovation Shares NextGen Protocol ETF
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The Bank of New York Mellon
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Pricing Direct
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Intercontinental Exchange, Inc.
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Bloomberg
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S&P
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IHS Markit
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Thomson Reuters Corporation
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The Bank of New York Mellon
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The Bank of New York Mellon
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SEI Investments Global Funds Services
801-24593
SEC File Number
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Penserra
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198.93
BTIG
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Hull Tactical US ETF
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Exchange-Traded Fund
N
N
N
N
N/A
N/A
N/A
Rule 32a-4 (17 CFR 270.32a-4)
N
N
N
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Exchange Traded Concepts, LLC
801-70485
000151197
549300BB5DRIKK8VVV91
N
Hull Tactical Asset Allocation, LLC
801-79752
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N/A
N
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Vident Investment Advisory, LLC
801-80534
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254900XSZB691Z1A6X78
2019-08-16
BROWN BROTHERS HARRIMAN & CO.
084-60256
5493006KMX1VFTPYPW14
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IHS Markit
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Thomson Reuters Corporation
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Intercontinental Exchange, Inc.
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Pricing Direct
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Bloomberg
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S&P
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BROWN BROTHERS HARRIMAN & CO.
5493006KMX1VFTPYPW14
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Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
BROWN BROTHERS HARRIMAN & CO.
8-60256
SEC File Number
N
N
N
SEI INVESTMENTS GLOBAL FUNDS SERVICES
801-24593
SEC File Number
N
N
N
MITSUBISHI SEC
008-43026
000019685
K5HU16E3LMSVCCJJJ255
208.45
NEWEDGE
008-66125
000128351
549300F35UE0BOM1WJ55
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MORGAN STANLEY & CO, INC
008-15869
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849.19
MISCHLER FINANCIAL
8-48067
000037818
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261.02999999
BTIG LLC
008-65473
000122225
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184.45
CANTOR FITZGERALD CO.
008-00201
000000134
5493004J7H4GCPG6OB62
5479
INTERACTIVE BROKERS LLC
008-47257
000036418
50OBSE5T5521O6SMZR28
695.3
MACQUARIE CAPITAL
008-47198
000036368
549300670K07JRB5UQ40
1122
10457.41999999
0
N
50460641.92
N
N
N
Ideanomics NextGen Vehicles & Technology ETF
S000061192
549300R4S2ZNH6BN6D96
N
1
0
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Exchange-Traded Fund
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0.52
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7.051804897
0.51357977
N
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Y
N
N
Bank of New York Mellon
HPFHU0OQ28E4N0NFVK49
N
N
Administrative fee
122050.64
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Rule 32a-4 (17 CFR 270.32a-4)
Y
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Exchange Traded Concepts, LLC
801-70485
000151197
549300BB5DRIKK8VVV91
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Penserra Capital Management, LLC
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The Bank of New York Mellon
N/A
HPFHU0OQ28E4N0NFVK49
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S&P
549300U4VWNITEKO2881
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Thomson Reuters Corporation
549300561UZND4C7B569
CA
N
Pricing Direct
549300WIC0TOJ7N7GD54
N
IHS Markit
549300HLPTRASHS0E726
GB
N
Bloomberg
254900BF4G8VMW8GG471
N
Intercontinental Exchange, Inc.
5493000F4ZO33MV32P92
N
N
The Bank of New York Mellon
HPFHU0OQ28E4N0NFVK49
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
The Bank of New York Mellon
HPFHU0OQ28E4N0NFVK49
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N
SEI Investments Global Funds Services
801-24593
SEC File Number
N
N
N
BTIG
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324.28
Penserra
008-67773
000145994
549300WY8ZBI168Y6Z05
17.8
342.08
0
N
1228061.1
N
N
N
FLAG-Forensic Accounting Long-Short ETF
S000039599
5493002CQU5BW07D6M90
N
1
0
0
Exchange-Traded Fund
N
N
-0.07
-1.28
2.20245794
1.84461177
N
N
Y
N
N/A
N/A
N/A
Rule 32a-4 (17 CFR 270.32a-4)
N
N
N
N
Exchange Traded Concepts, LLC
801-70485
000151197
549300BB5DRIKK8VVV91
N
Vident Investment Advisory, LLC
801-80534
000171004
254900XSZB691Z1A6X78
N
N
BROWN BROTHERS HARRIMAN & CO.
084-60256
5493006KMX1VFTPYPW14
N
N
N
Bloomberg
254900BF4G8VMW8GG471
N
Intercontinental Exchange, Inc.
5493000F4ZO33MV32P92
N
Pricing Direct
549300WIC0TOJ7N7GD54
N
S&P
549300U4VWNITEKO2881
N
Thomson Reuters Corporation
549300561UZND4C7B569
CA
N
IHS Markit
549300HLPTRASHS0E726
GB
N
N
BROWN BROTHERS HARRIMAN & CO.
5493006KMX1VFTPYPW14
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
N
BROWN BROTHERS HARRIMAN & CO.
8-60256
SEC File Number
N
N
N
SEI INVESTMENTS GLOBAL FUNDS SERVICES
801-24593
SEC File Number
N
N
N
CITIGROUP GLOBAL MARKETS
008-08177
000007059
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7.12
BNP PARIBAS
008-32682
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BTIG LLC
008-65473
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NITE SFT
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N
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Innovation Shares NextGen Protocol ETF
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FLAG-Forensic Accounting Long-Short ETF
S000039599
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132.61401707
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600.00000000
0.00000000
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0.00000000
0.00000000
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Hull Tactical US ETF
S000042584
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93.99848096
0
6.00151903
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25.26897555
21.75116253
74.73102444
21.75116253
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0.00000000
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Ideanomics NextGen Vehicles & Technology ETF
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91.33779045
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INTERNAL CONTROL RPT
2
ICL-EKAR.txt
INTERNAL CONTROL LETTER
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING
FIRM
To the Shareholders of Ideanomics NextGen Vehicles &
Technology ETF and
Board of Trustees of Exchange Traded Concepts Trust
In planning and performing our audit of the
financial statements of Ideanomics NextGen Vehicles
& Technology ETF (formerly Innovation Shares NextGen
Vehicles & Technology ETF) (the Fund), a series of
Exchange Traded Concepts Trust, as of and for the
year ended November 30, 2019, in accordance with the
standards of the Public Company Accounting Oversight
Board (United States), we considered the Funds
internal control over financial reporting, including
controls over safeguarding securities, as a basis
for designing our auditing procedures for the
purpose of expressing our opinion on the financial
statements and to comply with the requirements of
Form N-CEN, but not for the purpose of expressing an
opinion on the effectiveness of the Funds internal
control over financial reporting. Accordingly, we
express no such opinion.
The management of the Fund is responsible for
establishing and maintaining effective internal
control over financial reporting. In fulfilling
this responsibility, estimates and judgments by
management are required to assess the expected
benefits and related costs of controls. A funds
internal control over financial reporting is a
process designed to provide reasonable assurance
regarding the reliability of financial reporting and
the preparation of financial statements for external
purposes in accordance with generally accepted
accounting principles (GAAP). A funds internal
control over financial reporting includes those
policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions and
dispositions of the assets of the fund; (2) provide
reasonable assurance that transactions are recorded
as necessary to permit preparation of financial
statements in accordance with GAAP, and that
receipts and expenditures of the fund are being made
only in accordance with authorizations of management
and trustees of the fund; and (3) provide reasonable
assurance regarding prevention or timely detection
of unauthorized acquisition, use or disposition of a
funds assets that could have a material effect on
the financial statements.
Because of its inherent limitations, internal
control over financial reporting may not prevent or
detect misstatements. Also, projections of any
evaluation of effectiveness to future periods are
subject to the risk that controls may become
inadequate because of changes in conditions, or that
the degree of compliance with the policies or
procedures may deteriorate.
A deficiency in internal control over financial
reporting exists when the design or operation of a
control does not allow management or employees, in
the normal course of performing their assigned
functions, to prevent or detect misstatements on a
timely basis. A material weakness is a deficiency,
or combination of deficiencies, in internal control
over financial reporting, such that there is a
reasonable possibility that a material misstatement
of the Funds annual or interim financial statements
will not be prevented or detected on a timely basis.
Our consideration of the Funds internal control over
financial reporting was for the limited purpose
described in the first paragraph and would not
necessarily disclose all deficiencies in internal
control that might be material weaknesses under
standards established by the Public Company
Accounting Oversight Board (United States).
However, we noted no deficiencies in the Funds
internal control over financial reporting and its
operation, including controls over safeguarding
securities, that we consider to be a material
weakness as defined above as of November 30, 2019.
This report is intended solely for the information
and use of management and the Board of Trustees of
the Fund and the Securities and Exchange Commission
and is not intended to be and should not be used by
anyone other than these specified parties.
COHEN & COMPANY, LTD.
Chicago, Illinois
January 29, 2020
INTERNAL CONTROL RPT
3
ICL-FLAG.txt
INTERNAL CONTROL LETTER
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING
FIRM
To the Shareholders of FLAG-Forensic Accounting
Long-Short ETF and
Board of Trustees of Exchange Traded Concepts Trust
In planning and performing our audit of the
financial statements of FLAG-Forensic Accounting
Long-Short ETF (the Fund), a series of Exchange
Traded Concepts Trust, as of and for the year ended
November 30, 2019, in accordance with the standards
of the Public Company Accounting Oversight Board
(United States), we considered the Funds internal
control over financial reporting, including controls
over safeguarding securities, as a basis for
designing our auditing procedures for the purpose of
expressing our opinion on the financial statements
and to comply with the requirements of Form N-CEN,
but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over
financial reporting. Accordingly, we express no
such opinion.
The management of the Fund is responsible for
establishing and maintaining effective internal
control over financial reporting. In fulfilling
this responsibility, estimates and judgments by
management are required to assess the expected
benefits and related costs of controls. A funds
internal control over financial reporting is a
process designed to provide reasonable assurance
regarding the reliability of financial reporting and
the preparation of financial statements for external
purposes in accordance with generally accepted
accounting principles (GAAP). A funds internal
control over financial reporting includes those
policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions and
dispositions of the assets of the fund; (2) provide
reasonable assurance that transactions are recorded
as necessary to permit preparation of financial
statements in accordance with GAAP, and that
receipts and expenditures of the fund are being made
only in accordance with authorizations of management
and trustees of the fund; and (3) provide reasonable
assurance regarding prevention or timely detection
of unauthorized acquisition, use or disposition of a
funds assets that could have a material effect on
the financial statements.
Because of its inherent limitations, internal
control over financial reporting may not prevent or
detect misstatements. Also, projections of any
evaluation of effectiveness to future periods are
subject to the risk that controls may become
inadequate because of changes in conditions, or that
the degree of compliance with the policies or
procedures may deteriorate.
A deficiency in internal control over financial
reporting exists when the design or operation of a
control does not allow management or employees, in
the normal course of performing their assigned
functions, to prevent or detect misstatements on a
timely basis. A material weakness is a deficiency,
or combination of deficiencies, in internal control
over financial reporting, such that there is a
reasonable possibility that a material misstatement
of the Funds annual or interim financial statements
will not be prevented or detected on a timely basis.
Our consideration of the Funds internal control over
financial reporting was for the limited purpose
described in the first paragraph and would not
necessarily disclose all deficiencies in internal
control that might be material weaknesses under
standards established by the Public Company
Accounting Oversight Board (United States).
However, we noted no deficiencies in the Funds
internal control over financial reporting and its
operation, including controls over safeguarding
securities, which we consider to be a material
weakness as defined above as of November 30, 2019.
This report is intended solely for the information
and use of management and the Board of Trustees of
the Fund and the Securities and Exchange Commission
and is not intended to be and should not be used by
anyone other than these specified parties.
COHEN & COMPANY, LTD.
Chicago, Illinois
January 29, 2020
INTERNAL CONTROL RPT
4
ICL-HTUS.txt
INTERNAL CONTROL LETTER
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING
FIRM
To the Shareholders of Hull Tactical US ETF and
Board of Trustees of Exchange Traded Concepts Trust
In planning and performing our audit of the
financial statements of Hull Tactical US ETF (the
Fund), a series of Exchange Traded Concepts Trust,
as of and for the year ended November 30, 2019, in
accordance with the standards of the Public Company
Accounting Oversight Board (United States), we
considered the Funds internal control over financial
reporting, including controls over safeguarding
securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion
on the financial statements and to comply with the
requirements of Form N-CEN, but not for the purpose
of expressing an opinion on the effectiveness of the
Funds internal control over financial reporting.
Accordingly, we express no such opinion.
The management of the Fund is responsible for
establishing and maintaining effective internal
control over financial reporting. In fulfilling
this responsibility, estimates and judgments by
management are required to assess the expected
benefits and related costs of controls. A funds
internal control over financial reporting is a
process designed to provide reasonable assurance
regarding the reliability of financial reporting and
the preparation of financial statements for external
purposes in accordance with generally accepted
accounting principles (GAAP). A funds internal
control over financial reporting includes those
policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions and
dispositions of the assets of the fund; (2) provide
reasonable assurance that transactions are recorded
as necessary to permit preparation of financial
statements in accordance with GAAP, and that
receipts and expenditures of the fund are being made
only in accordance with authorizations of management
and trustees of the fund; and (3) provide reasonable
assurance regarding prevention or timely detection
of unauthorized acquisition, use or disposition of a
funds assets that could have a material effect on
the financial statements.
Because of its inherent limitations, internal
control over financial reporting may not prevent or
detect misstatements. Also, projections of any
evaluation of effectiveness to future periods are
subject to the risk that controls may become
inadequate because of changes in conditions, or that
the degree of compliance with the policies or
procedures may deteriorate.
A deficiency in internal control over financial
reporting exists when the design or operation of a
control does not allow management or employees, in
the normal course of performing their assigned
functions, to prevent or detect misstatements on a
timely basis. A material weakness is a deficiency,
or combination of deficiencies, in internal control
over financial reporting, such that there is a
reasonable possibility that a material misstatement
of the Funds annual or interim financial statements
will not be prevented or detected on a timely basis.
Our consideration of the Funds internal control over
financial reporting was for the limited purpose
described in the first paragraph and would not
necessarily disclose all deficiencies in internal
control that might be material weaknesses under
standards established by the Public Company
Accounting Oversight Board (United States).
However, we noted no deficiencies in the Funds
internal control over financial reporting and its
operation, including controls over safeguarding
securities, that we consider to be a material
weakness as defined above as of November 30, 2019.
This report is intended solely for the information
and use of management and the Board of Trustees of
the Fund and the Securities and Exchange Commission
and is not intended to be and should not be used by
anyone other than these specified parties.
COHEN & COMPANY, LTD.
Chicago, Illinois
January 29, 2020
INTERNAL CONTROL RPT
5
ICL-KOIN.txt
INTERNAL CONTROL LETTER
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING
FIRM
To the Shareholders of Innovation Shares NextGen
Protocol ETF and
Board of Trustees of Exchange Traded Concepts Trust
In planning and performing our audit of the
financial statements of Innovation Shares NextGen
Protocol ETF (the Fund), a series of Exchange Traded
Concepts Trust, as of and for the year ended
November 30, 2019, in accordance with the standards
of the Public Company Accounting Oversight Board
(United States), we considered the Funds internal
control over financial reporting, including controls
over safeguarding securities, as a basis for
designing our auditing procedures for the purpose of
expressing our opinion on the financial statements
and to comply with the requirements of Form N-CEN,
but not for the purpose of expressing an opinion on
the effectiveness of the Funds internal control over
financial reporting. Accordingly, we express no
such opinion.
The management of the Fund is responsible for
establishing and maintaining effective internal
control over financial reporting. In fulfilling
this responsibility, estimates and judgments by
management are required to assess the expected
benefits and related costs of controls. A funds
internal control over financial reporting is a
process designed to provide reasonable assurance
regarding the reliability of financial reporting and
the preparation of financial statements for external
purposes in accordance with generally accepted
accounting principles (GAAP). A funds internal
control over financial reporting includes those
policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions and
dispositions of the assets of the fund; (2) provide
reasonable assurance that transactions are recorded
as necessary to permit preparation of financial
statements in accordance with GAAP, and that
receipts and expenditures of the fund are being made
only in accordance with authorizations of management
and trustees of the fund; and (3) provide reasonable
assurance regarding prevention or timely detection
of unauthorized acquisition, use or disposition of a
funds assets that could have a material effect on
the financial statements.
Because of its inherent limitations, internal
control over financial reporting may not prevent or
detect misstatements. Also, projections of any
evaluation of effectiveness to future periods are
subject to the risk that controls may become
inadequate because of changes in conditions, or that
the degree of compliance with the policies or
procedures may deteriorate.
A deficiency in internal control over financial
reporting exists when the design or operation of a
control does not allow management or employees, in
the normal course of performing their assigned
functions, to prevent or detect misstatements on a
timely basis. A material weakness is a deficiency,
or combination of deficiencies, in internal control
over financial reporting, such that there is a
reasonable possibility that a material misstatement
of the Funds annual or interim financial statements
will not be prevented or detected on a timely basis.
Our consideration of the Funds internal control over
financial reporting was for the limited purpose
described in the first paragraph and would not
necessarily disclose all deficiencies in internal
control that might be material weaknesses under
standards established by the Public Company
Accounting Oversight Board (United States).
However, we noted no deficiencies in the Funds
internal control over financial reporting and its
operation, including controls over safeguarding
securities, that we consider to be a material
weakness as defined above as of November 30, 2019.
This report is intended solely for the information
and use of management and the Board of Trustees of
the Fund and the Securities and Exchange Commission
and is not intended to be and should not be used by
anyone other than these specified parties.
COHEN & COMPANY, LTD.
Chicago, Illinois
January 29, 2020