0001752724-22-246809.txt : 20221114
0001752724-22-246809.hdr.sgml : 20221114
20221114074148
ACCESSION NUMBER: 0001752724-22-246809
CONFORMED SUBMISSION TYPE: N-CEN
PUBLIC DOCUMENT COUNT: 5
CONFORMED PERIOD OF REPORT: 20220831
FILED AS OF DATE: 20221114
DATE AS OF CHANGE: 20221114
EFFECTIVENESS DATE: 20221114
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: 221380319
BUSINESS ADDRESS:
STREET 1: 10900 HEFNER POINTE DRIVE
STREET 2: SUITE 400
CITY: OKLAHOMA CITY
STATE: OK
ZIP: 73120
BUSINESS PHONE: 405-778-8377
MAIL ADDRESS:
STREET 1: 10900 HEFNER POINTE DRIVE
STREET 2: SUITE 400
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
S000047306
EMQQ The Emerging Markets Internet & Ecommerce ETF
C000148468
EMQQ The Emerging Markets Internet & Ecommerce ETF
EMQQ
0001452937
S000063053
Vesper U.S. Large Cap Short-Term Reversal Strategy ETF
C000204524
Vesper U.S. Large Cap Short-Term Reversal Strategy ETF
UTRN
0001452937
S000073704
FMQQ The Next Frontier Internet & Ecommerce ETF
C000230780
FMQQ The Next Frontier Internet & Ecommerce ETF
FMQQ
0001452937
S000073824
Fount Metaverse ETF
C000231030
Fount Metaverse ETF
MTVR
0001452937
S000073825
Fount Subscription Economy ETF
C000231031
Fount Subscription Economy ETF
SUBS
0001452937
S000074812
India Internet & Ecommerce ETF
C000233024
India Internet & Ecommerce ETF
INQQ
N-CEN
1
primary_doc.xml
X0404
N-CEN
LIVE
0001452937
XXXXXXXX
811-22263
N-1A
S000073825
true
S000073704
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S000047306
true
S000063053
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S000073824
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EXCHANGE TRADED CONCEPTS TRUST
811-22263
0001452937
549300TXJW88BSB0KL90
10900 HEFNER POINTE DRIVE
SUITE 400
OKLAHOMA CITY
73120
US-OK
US
4057788377
SEI GLOBAL FUNDS SERVICES
1 Freedom Valley Drive
OAKS
19456
610-676-1000
Records as Administrator for Trust
EXCHANGE TRADED CONCEPTS LLC
10900 Hefner Pointe Dr
Suite 400
Okalahoma City
73120
405-778-8377
Records as Advisor for Trust
PENSERRA CAPITAL MANAGEMENT LLC
4 Orinda Way, Suite 100-A
Orinda
94563
800-456-8850
Records as Sub-Advisor for Trust
BROWN BROTHERS HARRIMAN & CO.
50 Post Office Square
Boston
02110
617-772-1818
Records as Custodian and Transfer Agent for Trust
The Bank of New York Mellon
240 Greenwich Street
New York
10286
1-212-495-1784
Records as Custodian and Transfer Agent for Trust
N
N
N-1A
21
N
Timothy Jacoby
N/A
N
Mark Zurack
N/A
N
Linda Petrone
N/A
N
J. Garrett Stevens
N/A
Y
Stuart Strauss
N/A
N
Matthew B. Fleischer
N/A
295 Madison Avenue
26th Floor
New York
10017
XXXXXX
N
N
N
N
N
N
SEI INVESTMENTS DISTRIBTUION CO.
8-27897
000010690
N/A
N
N
Cohen & Company, Ltd
925
N/A
N
N
N
N
N
N
N
Fount Subscription Economy ETF
S000073825
5493008CYHXK3K7JGU15
Y
1
0
0
Exchange-Traded Fund
N
Y
0.07
-0.44
0.593688944
0.348666511
Y
N
N
N
N/A
0.00000000
0.00000000
Rule 6c-11 (17 CFR 270.6c-11)
Rule 32a-4 (17 CFR 270.32a-4)
N
N
N
N
Exchange Traded Concepts, LLC
801-70485
000151197
549300BB5DRIKK8VVV91
N
The Bank of New York Mellon
085-05006
HPFHU0OQ28E4N0NFVK49
N
N
N
Pricing Direct
549300WIC0TOJ7N7GD54
N
Intercontinental Exchange, Inc.
5493000F4ZO33MV32P92
N
S&P
549300U4VWNITEKO2881
N
IHS Markit
549300HLPTRASHS0E726
GB
N
Thomson Reuters Corporation
549300561UZND4C7B569
CA
N
Bloomberg
254900BF4G8VMW8GG471
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
N
N
N
SEI INVESTMENTS GLOBAL FUNDS SERVICES
801-24593
SEC File Number
N
N
N
SEI Investments Distribution Co.
8-27897
000010690
N/A
0.00
MISCHLER FINANCIAL
8-48067
000037818
2549004IPXPSM9EJFC92
609.81999999
BTIG
008-65473
000122225
549300GTG9PL6WO3EC51
26.17000000
635.98999999
0.00000000
N
5799083.08000000
N
N
N
FMQQ The Next Frontier Internet & Ecommerce ETF
S000073704
549300RHTKUJDQ8LQE59
Y
1
0
0
Exchange-Traded Fund
N
Y
0.66
0.29
4.108107049
4.099125764
Y
N
N
N
N/A
0.00000000
0.00000000
Rule 6c-11 (17 CFR 270.6c-11)
Rule 32a-4 (17 CFR 270.32a-4)
N
N
N
N
Exchange Traded Concepts, LLC
801-70485
000151197
549300BB5DRIKK8VVV91
N
BROWN BROTHERS HARRIMAN & CO.
084-60256
5493006KMX1VFTPYPW14
N
N
N
Bloomberg
254900BF4G8VMW8GG471
N
Intercontinental Exchange, Inc.
5493000F4ZO33MV32P92
N
Pricing Direct
549300WIC0TOJ7N7GD54
N
IHS Markit
549300HLPTRASHS0E726
GB
N
S&P
549300U4VWNITEKO2881
N
Thomson Reuters Corporation
549300561UZND4C7B569
CA
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.
5493006KMX1VFTPYPW14
N
N
N
SEI INVESTMENTS GLOBAL FUNDS SERVICES
801-24593
SEC File Number
N
N
N
SEI Investments Distribution Co.
8-27897
000010690
N/A
0.00
BTIG
008-65473
000122225
549300GTG9PL6WO3EC51
23400.16000000
MISCHLER FINANCIAL
8-48067
000037818
2549004IPXPSM9EJFC92
990.06000000
GOLDMAN, SACHS & CO.
008-00129
000000361
FOR8UP27PHTHYVLBNG30
8.96000000
24399.18000000
0.00000000
N
10919985.78999999
N
N
N
EMQQ The Emerging Markets Internet & Ecommerce ETF
S000047306
549300ZFP551IO6DFL53
N
1
0
0
Exchange-Traded Fund
N
N
0.04
-0.47
1.166453022
1.151423736
Y
N
Y
N
N
Brown Brothers Harriman
5493006KMX1VFTPYPW14
N
N
Revenue sharing split
51762684.04999999
1635765.00
Rule 6c-11 (17 CFR 270.6c-11)
Rule 17e-1 (17 CFR 270.17e-1)
Rule 32a-4 (17 CFR 270.32a-4)
N
N
N
N
EXCHANGE TRADED CONCEPTS LLC
801-70485
000151197
549300BB5DRIKK8VVV91
N
PENSERRA CAPITAL MANAGEMENT LLC
801-80466
000159042
549300I8X5UWMSXOJ371
N
N
BROWN BROTHERS HARRIMAN & CO.
84-06072
5493006KMX1VFTPYPW14
N
N
N
S&P
549300U4VWNITEKO2881
N
Thomson Reuters Corporation
549300561UZND4C7B569
CA
N
Bloomberg
254900BF4G8VMW8GG471
N
Intercontinental Exchange, Inc.
5493000F4ZO33MV32P92
N
IHS Markit
549300HLPTRASHS0E726
GB
N
Pricing Direct
549300WIC0TOJ7N7GD54
N
N
HSBC FRANCE SA
N/A
FR
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
ITAU UNIBANCO S.A.
N/A
BR
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
CITIBK BUENOS AIRES
N/A
AR
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
DEUTSCHE NETHERLAND
N/A
NL
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
SCB (TAIWAN) LTD
N/A
TW
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
KEB HANA BANK
N/A
KR
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
HSBC LIMITED, HONG KONG
N/A
HK
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
STANDARD CHARTERED BANK, JOHANNESBURG
N/A
ZA
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
EUROCLEAR BK SA NV
N/A
BE
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
BROWN BROTHERS HARRIMAN & CO.
5493006KMX1VFTPYPW14
N
N
Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
DEUTSCHE FRANKFURT
N/A
DE
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
CITIBANK MUMBAI
N/A
IN
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
SCB (HONG KONG) LTD
N/A
HK
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
SOCGEN SOUTH AFRICA
N/A
ZA
N
Y
Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
N
BROWN BROTHERS HARRIMAN & CO.
84-06072
SEC File Number
N
N
N
SEI Investments Global Funds Services
801-24593
SEC File Number
N
N
N
PENSERRA CAPITAL MANAGEMENT LLC
8-80466
000159042
549300I8X5UWMSXOJ371
0.00
SEI Investments Distribution Co.
8-27897
000010690
N/A
0.00
CREDIT SUISSE - FIRST BOSTON
008-00422
000000816
1V8Y6QCX6YMJ2OELII46
742972.89000000
742972.89000000
0.00000000
N
884905527.25999999
N
N
N
Vesper U.S. Large Cap Short-Term Reversal Strategy ETF
S000063053
549300542L3WW9LX6T23
N
1
0
0
Exchange-Traded Fund
N
N
-0.47
-1.09
0.491306766
0.24124057
N
N
Y
N
N/A
0.00000000
0.00000000
Rule 32a-4 (17 CFR 270.32a-4)
Rule 6c-11 (17 CFR 270.6c-11)
N
N
N
N
Exchange Traded Concepts, LLC
801-70485
000151197
549300BB5DRIKK8VVV91
N
BROWN BROTHERS HARRIMAN & CO.
084-60256
5493006KMX1VFTPYPW14
N
N
N
Bloomberg
254900BF4G8VMW8GG471
N
S&P
549300U4VWNITEKO2881
N
Intercontinental Exchange, Inc.
5493000F4ZO33MV32P92
N
IHS Markit
549300HLPTRASHS0E726
GB
N
Thomson Reuters Corporation
549300561UZND4C7B569
CA
N
Pricing Direct
549300WIC0TOJ7N7GD54
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.
5493006KMX1VFTPYPW14
N
N
N
SEI INVESTMENTS GLOBAL FUNDS SERVICES
801-24593
SEC File Number
N
N
N
SEI Investments Distribution Co.
8-27897
000010690
N/A
0.00
CREDIT SUISSE FIRST BOSTON LLC.
008-00422
000000816
1V8Y6QCX6YMJ2OELII46
18193.25000000
JANE STREET EXECUTION SERVICES
8-69254
000167280
549300HXJLXCPDWAH070
85373.04999999
BTIG
008-65473
000122225
549300GTG9PL6WO3EC51
125820.43000000
JP MORGAN
008-35008
000000079
ZBUT11V806EZRVTWT807
47138.20999999
MISCHLER FINANCIAL
8-48067
000037818
2549004IPXPSM9EJFC92
109983.62000000
386508.56000000
0.00000000
N
80809344.14000000
N
N
N
Fount Metaverse ETF
S000073824
5493007EDSRFOHHNPT33
Y
1
0
0
Exchange-Traded Fund
N
Y
0.23
-0.23
1.031271325
0.962711802
Y
N
N
N
N/A
0.00000000
0.00000000
Rule 6c-11 (17 CFR 270.6c-11)
Rule 32a-4 (17 CFR 270.32a-4)
N
N
N
N
Exchange Traded Concepts, LLC
801-70485
000151197
549300BB5DRIKK8VVV91
N
The Bank of New York Mellon
085-05006
HPFHU0OQ28E4N0NFVK49
N
N
N
S&P
549300U4VWNITEKO2881
N
IHS Markit
549300HLPTRASHS0E726
GB
N
Thomson Reuters Corporation
549300561UZND4C7B569
CA
N
Pricing Direct
549300WIC0TOJ7N7GD54
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
N
N
N
SEI INVESTMENTS GLOBAL FUNDS SERVICES
801-24593
SEC File Number
N
N
N
SEI Investments Distribution Co.
8-27897
000010690
N/A
0.00
BTIG
008-65473
000122225
549300GTG9PL6WO3EC51
516.60000000
MORGAN STANLEY & CO, INC
008-15869
000008209
9R7GPTSO7KV3UQJZQ078
59.76000000
MISCHLER FINANCIAL
8-48067
000037818
2549004IPXPSM9EJFC92
4586.91000000
5163.27000000
0.00000000
N
9298328.91999999
N
N
N
India Internet & Ecommerce ETF
S000074812
549300P7Z571TLC6G485
Y
1
0
0
Exchange-Traded Fund
N
Y
-0.05
-0.71
0.884728093
0.83986574
Y
N
N
N
N/A
0.00000000
0.00000000
Rule 32a-4 (17 CFR 270.32a-4)
Rule 6c-11 (17 CFR 270.6c-11)
N
N
N
N
Exchange Traded Concepts, LLC
801-70485
000151197
549300BB5DRIKK8VVV91
N
BROWN BROTHERS HARRIMAN & CO.
084-60256
5493006KMX1VFTPYPW14
N
N
N
S&P
549300U4VWNITEKO2881
N
Thomson Reuters Corporation
549300561UZND4C7B569
CA
N
Bloomberg
254900BF4G8VMW8GG471
N
Intercontinental Exchange, Inc.
5493000F4ZO33MV32P92
N
Pricing Direct
549300WIC0TOJ7N7GD54
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.
5493006KMX1VFTPYPW14
N
N
N
SEI INVESTMENTS GLOBAL FUNDS SERVICES
801-24593
SEC File Number
N
N
N
SEI Investments Distribution Co.
8-27897
000010690
N/A
0.00
MISCHLER FINANCIAL
8-48067
000037818
2549004IPXPSM9EJFC92
1059.88999999
1059.88999999
0.00000000
N
733833.16000000
N
N
N
Fount Subscription Economy ETF
S000073825
Y
25000.00000000
1.79363100
0.41556575
98.20636899
0.41556575
4.06661317
2.52366281
95.93338682
2.52366281
0.00000000
500.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
500.00000000
0.00000000
0.00000000
500.00000000
0.00000000
Y
FMQQ The Next Frontier Internet & Ecommerce ETF
S000073704
Y
25000.00000000
45.54008685
14.86914828
54.45991314
14.86914828
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
986.36363636
0.00000000
0.00000000
986.36363636
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
N
EMQQ The Emerging Markets Internet & Ecommerce ETF
S000047306
Y
50000.00000000
37.06591637
0.00000000
62.93408362
0.00000000
40.02420766
6.16480059
59.97579233
6.16480059
0.00000000
750.00000000
0.00000000
0.00000000
750.00000000
0.00000000
0.00000000
750.00000000
0.00000000
0.00000000
750.00000000
0.00000000
N
Vesper U.S. Large Cap Short-Term Reversal Strategy ETF
S000063053
N
50000.00000000
0.35104711
0.15249464
99.64895288
0.15249464
3.30023941
4.62295280
96.69976058
4.62295280
0.00000000
152.43902439
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
38.46153846
0.00000000
0.00000000
0.00000000
0.00000000
Y
Fount Metaverse ETF
S000073824
Y
25000.00000000
17.29307557
4.74373778
82.70692442
4.74373778
20.23335827
5.45246329
79.76664172
5.45246329
0.00000000
575.00000000
0.00000000
0.00000000
575.00000000
0.00000000
0.00000000
575.00000000
0.00000000
0.00000000
575.00000000
0.00000000
N
India Internet & Ecommerce ETF
S000074812
Y
10000.00000000
86.07607634
0.83027106
13.92392365
0.83027106
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
750.00000000
0.00000000
0.00000000
750.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
0.00000000
N
false
false
true
false
false
false
INTERNAL CONTROL RPT
2
INQQ_ICL.txt
INTERNAL CONTROL LETTER
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING
FIRM
To the Shareholders of India Internet & Ecommerce
ETF and
Board of Trustees of Exchange Traded Concepts Trust
In planning and performing our audit of the
financial statements of India Internet & Ecommerce
ETF (the Fund), a series of Exchange Traded Concepts
Trust, as of and for the period ended August 31,
2022, in accordance with the standards of the Public
Company Accounting Oversight Board (United States)
(PCAOB), 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 PCAOB. 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 August 31, 2022.
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.
Cleveland, Ohio
October 27, 2022
INTERNAL CONTROL RPT
3
EMQQ_FMQQ_ICL.txt
INTERNAL CONTROL LETTER
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING
FIRM
To the Shareholders of EMQQ The Emerging Markets
Internet & Ecommerce ETF and FMQQ The Next Frontier
Internet & Ecommerce ETF and
Board of Trustees of Exchange Traded Concepts Trust
In planning and performing our audit of the
financial statements of EMQQ The Emerging Markets
Internet & Ecommerce ETF and FMQQ The Next Frontier
Internet & Ecommerce ETF (the Funds), each a series
of Exchange Traded Concepts Trust, as of and for the
year or period ended August 31, 2022, in accordance
with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), 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 Funds 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 PCAOB. 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 August 31, 2022.
This report is intended solely for the information
and use of management and the Board of Trustees of
the Funds 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.
Cleveland, Ohio
October 27, 2022
INTERNAL CONTROL RPT
4
SUBS_MTVR_ICL.txt
INTERNAL CONTROL LETTER
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING
FIRM
To the Shareholders of Fount Subscription Economy
ETF and Fount Metaverse ETF and
Board of Trustees of Exchange Traded Concepts Trust
In planning and performing our audit of the
financial statements of Fount Subscription Economy
ETF and Fount Metaverse ETF (the Funds), each a
series of Exchange Traded Concepts Trust, as of and
for the period ended August 31, 2022, in accordance
with the standards of the Public Company Accounting
Oversight Board (United States) (PCAOB), 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 Funds 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 PCAOB. 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 August 31, 2022.
This report is intended solely for the information
and use of management and the Board of Trustees of
the Funds 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.
Cleveland, Ohio
October 27, 2022
INTERNAL CONTROL RPT
5
UTRN_ICL.txt
INTERNAL CONTROL LETTER
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING
FIRM
To the Shareholders of Vesper U.S. Large Cap Short-
Term Reversal Strategy ETF and
Board of Trustees of Exchange Traded Concepts Trust
In planning and performing our audit of the
financial statements of Vesper U.S. Large Cap Short-
Term Reversal Strategy ETF (the Fund), a series of
Exchange Traded Concepts Trust, as of and for the
year ended August 31, 2022, in accordance with the
standards of the Public Company Accounting Oversight
Board (United States) (PCAOB), 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 PCAOB. 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 August 31, 2022.
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.
Cleveland, Ohio
October 27, 2022