0001752724-23-021491.txt : 20230210 0001752724-23-021491.hdr.sgml : 20230210 20230210164039 ACCESSION NUMBER: 0001752724-23-021491 CONFORMED SUBMISSION TYPE: N-CEN PUBLIC DOCUMENT COUNT: 6 CONFORMED PERIOD OF REPORT: 20221130 FILED AS OF DATE: 20230210 DATE AS OF CHANGE: 20230210 EFFECTIVENESS DATE: 20230210 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: 23612781 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 S000042584 Hull Tactical US ETF C000131678 Hull Tactical US ETF HTUS 0001452937 S000061191 Capital Link Global Fintech Leaders ETF C000198171 Capital Link Global Fintech Leaders ETF KOIN 0001452937 S000061192 Capital Link Global Green Energy Transport and Technology Leaders ETF C000198172 Capital Link Global Green Energy Transport and Technology Leaders ETF EKAR 0001452937 S000068543 ETC 6 Meridian Low Beta Equity Strategy ETF C000219253 ETC 6 Meridian Low Beta Equity Strategy ETF SIXL 0001452937 S000068544 ETC 6 Meridian Mega Cap Equity ETF C000219254 ETC 6 Meridian Mega Cap Equity ETF SIXA 0001452937 S000068545 ETC 6 Meridian Small Cap Equity ETF C000219255 ETC 6 Meridian Small Cap Equity ETF SIXS 0001452937 S000068546 ETC 6 Meridian Hedged Equity-Index Option Strategy ETF C000219256 ETC 6 Meridian Hedged Equity-Index Option Strategy ETF SIXH 0001452937 S000071535 ETC 6 Meridian Quality Growth ETF C000226842 ETC 6 Meridian Quality Growth ETF SXQG 0001452937 S000075604 Optica Rare Earths & Critical Materials ETF C000234825 Optica Rare Earths & Critical Materials ETF CRIT N-CEN 1 primary_doc.xml X0404 N-CEN LIVE 0001452937 XXXXXXXX 811-22263 N-1A S000068546 true S000075604 true S000071535 true S000061191 true S000061192 true S000068545 true S000068543 true S000068544 true S000042584 true EXCHANGE TRADED CONCEPTS TRUST 811-22263 0001452937 549300TXJW88BSB0KL90 10900 HEFNER POINTE DRIVE SUITE 400 OKLAHOMA CITY 73120 US-OK US 405-778-8377 SEI INVESTMENTS GLOBAL FUNDS SERVICES 1 Freedom Valley Drive OAKS 19456 610-676-1000 Records as Administrator for Trust BROWN BROTHERS HARRIMAN & CO. 40 Water Street Boston 02109 617-772-1818 Records as Custodian for Trust & Transfer Agent Exchange Traded Concepts, LLC 10900 Hefner Pointe Drive Suite 400 Oklahoma City 73120 1-405-778-8377 Records as Advisor for Trust 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 6 Meridian LLC 8301 E 21st St. North Suite 150 Wichita 67206 316-776-4601 Records as sub-advisor for Trust SEI INVESTMENTS DISTRIBUTION CO. 1 Freedom Valley Drive OAKS 19456 610-676-1000 Records as Distributor 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 N N N N-1A 19 Y Linda Petrone N/A N J. Garrett Stevens N/A Y Stuart Strauss N/A N Timothy Jacoby N/A N Mark Zurack N/A N Matthew B. 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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 JP MORGAN - OLD BEAR STEARNS 008-35008 000000079 ZBUT11V806EZRVTWT807 12103.16999999 JANE STREET EXECUTION SERVICES 8-69254 000167280 549300HXJLXCPDWAH070 8745.71000000 BTIG 008-65473 000122225 549300GTG9PL6WO3EC51 16462.89000000 MISCHLER FINANCIAL 8-48067 000037818 2549004IPXPSM9EJFC92 22042.51000000 59354.28000000 0.00000000 N 161943393.74000001 N N N Hull Tactical US ETF S000042584 549300MKXG1WPT0STH40 N 1 0 0 Exchange-Traded Fund Fund of Funds N N Y N N/A 0.00000000 0.00000000 Rule 6c-11 (17 CFR 270.6c-11) Rule 32a-4 (17 CFR 270.32a-4) Rule 18f-4 (17 CFR 270.18f-4) Rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2)) N N N N Exchange Traded Concepts, LLC 801-70485 000151197 549300BB5DRIKK8VVV91 N Hull Tactical Asset Allocation, LLC 801-79752 000171391 N/A N N BROWN BROTHERS HARRIMAN & CO. 084-60256 5493006KMX1VFTPYPW14 N N N IHS Markit 549300HLPTRASHS0E726 GB N Pricing Direct 549300WIC0TOJ7N7GD54 N Intercontinental Exchange, Inc. 5493000F4ZO33MV32P92 N Thomson Reuters Corporation 549300561UZND4C7B569 CA N Bloomberg 254900BF4G8VMW8GG471 N S&P 549300U4VWNITEKO2881 N N BROWN BROTHERS HARRIMAN & CO. 5493006KMX1VFTPYPW14 N N Bank - 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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 fund's 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 fund's 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 fund's 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 November 30, 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 January 24, 2023 INTERNAL CONTROL RPT 3 HULL_ICL.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, 2022, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Fund's 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 Fund's 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 fund's 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 fund's 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 fund's 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 Fund's annual or interim financial statements will not be prevented or detected on a timely basis. Our consideration of the Fund's 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 Fund's 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, 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 January 24, 2023 INTERNAL CONTROL RPT 4 CRIT_ICL.txt INTERNAL CONTROL LETTER REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholders of Optica Rare Earths & Critical Materials ETF and Board of Trustees of Exchange Traded Concepts Trust In planning and performing our audit of the financial statements of Optica Rare Earths & Critical Materials ETF (the "Fund"), a series of Exchange Traded Concepts Trust, as of and for the period ended November 30, 2022, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Fund's 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 Fund's 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 fund's 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 fund's 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 fund's 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 Fund's annual or interim financial statements will not be prevented or detected on a timely basis. Our consideration of the Fund's 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 Fund's 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, 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 January 24, 2023 INTERNAL CONTROL RPT 5 EKAR_ICL.txt INTERNAL CONTROL LETTER REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholders of Capital Link Global Green Energy Transport and Technology Leaders ETF and Board of Exchange Traded Concepts Trust In planning and performing our audit of the financial statements of Capital Link Global Green Energy Transport and Technology Leaders ETF (formerly Capital Link NextGen Vehicles & Technology ETF (the "Fund"), a series of Exchange Traded Concepts Trust, as of and for the year ended November 30, 2022, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Fund's 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 Fund's 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 fund's 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 fund's 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 fund's 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 Fund's annual or interim financial statements will not be prevented or detected on a timely basis. Our consideration of the Fund's 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 Fund's 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, 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 January 24, 2023 INTERNAL CONTROL RPT 6 KOIN_ICL.txt INTERNAL CONTROL LETTER REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Shareholders of Capital Link Global Fintech Leaders ETF and Board of Trustees of Exchange Traded Concepts Trust In planning and performing our audit of the financial statements of Capital Link Global Fintech Leaders ETF (formerly Capital Link NextGen Protocol ETF) (the "Fund"), a series of Exchange Traded Concepts Trust, as of and for the year ended November 30, 2022, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Fund's 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 Fund's 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 fund's 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 fund's 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 fund's 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 Fund's annual or interim financial statements will not be prevented or detected on a timely basis. Our consideration of the Fund's 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 Fund's 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, 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 January 24, 2023