ETPs: Expanding Investor Access to Crypto
Exchange-traded products (ETPs) offer a convenient, regulated, and low-cost way for both retail and institutional investors to access a range of underlying investments — and crypto is no exception.
Since the launch of the first bitcoin tracker in Sweden in 2015, crypto ETPs have grown from a largely European phenomenon to an expanding global footprint and from a range of just 17 products at the end of 2020 to circa 180 trading today. As more TradFi institutions join the crypto-native firms in their issuance, the role of ETPs in not only expanding investor access to crypto but in crypto’s overall acceptance and integration in global financial markets is becoming increasingly clear.
This article provides an overview of crypto ETPs, including the types of products currently available, the operating model, regional overviews, and developments we’re watching in this rapidly evolving landscape.
Overview of crypto ETPs
What are crypto ETPs?
Exchange-traded products (ETPs) are a category of financial products bought and sold on regulated stock exchanges daily throughout regular trading hours, tracking the return of an underlying benchmark, asset, or portfolio.
There are three main types of ETPs: exchange-traded funds (ETFs), exchange-traded notes (ETNs), and exchange-traded commodities (ETCs). While ETFs are investment funds, ETNs and ETCs are debt securities, with ETCs tracking physical commodities such as gold and oil and ETNs used for all other types of financial instruments. Since the creation of the first ETF in 1993, thirty years ago this year, ETPs have grown from equity market trackers to arguably one of the most innovative categories of investment products providing investors with exposure to a range of innovative underlying.
Note: While ‘ETPs’ is the umbrella term for this category of products, the term ETP is sometimes used as a category term for debt security exchange-traded products.
Particularly over the past twenty years, these types of products have experienced continued growth, reaching 11,859 products and 23,931 listings globally from 718 providers listed on 81 exchanges in 63 countries; of these, ETFs make up the lion’s share of assets, accounting for $10,747 Bn or 98% of the total $10,990 Bn in ETP assets (data from ETFGI as of end Nov 2023). Oliver Wyman expects growth in ETFs to accelerate in growth from recent years, forecasting the market to grow at 13 to 18% p.a. from 2022 to 2027.
The convenience and accessibility of ETPs make them a popular tool for opening new asset classes and investment strategies to investors — here, crypto is no exception.
The first ever Bitcoin ETP was launched in 2015 on the Swedish NASDAQ by XBT Provider (later acquired by Coinshares). Growth in the market remained relatively modest until the latter half of 2020, when a strong uptick in the number of products began, which continues today, both from new crypto-native entrants and traditional issuers. In February 2021, Canada won the race for the world’s first Bitcoin ETF, with Purpose Investment’s launch of its Purpose Bitcoin ETF on the Toronto Stock Exchange. While crypto ETPs, structured as debt securities, still far surpass crypto ETFs both in number and AUM, we expect to see this start to shift, particularly as the market for US spot ETFs opens.
The number of crypto products has grown steadily, particularly within the last three years, reaching 176 Crypto ETFs and ETPs as of November 2023, based on data from ETFGI. Assets invested in these products rose 120% in the first 11 months of the year, growing from $5.79 Bn at the end of 2022 to $12.73 Bn at the end of November 2023.
Why crypto ETPs?
The idea of a crypto ETP may seem counterintuitive to crypto natives: introducing intermediaries, which this technology enables us to remove. However, as well-understood and regulated investment products, ETPs open up the opportunity for crypto exposure to a much larger investor audience who, for various reasons, may otherwise be unable to access the asset class. For instance, retail investors may lack the tools, time, risk tolerance, and technical expertise to invest directly in crypto. The structure of ETPs as traditional securities opens them to institutional investors who may be restricted to only investing in these types of instruments or who wish to avoid directly holding crypto assets, be that for regulatory, compliance, technical, or other reasons.
There are also potential disadvantages and considerations (as not all investors would consider these to be disadvantages) with these products in comparison with purchasing crypto directly. These include the fact that crypto ETPs to date have had much higher fees than is typical for these products (although these are already falling with increasing competition), the limited trading availability of traditional exchanges vs. crypto’s 24/7 markets, access restrictions based on jurisdiction and investor type as per regulatory approvals, counterparty, tracking error, and exchange rate risks, and settlement times.
Note: examples of geographical restrictions include that European crypto ETPs are generally not registered under the US Securities Act of 1933 and therefore cannot be offered to US investors; the UK FCA prohibits the sale of crypto ETPs to retail investors
Product structure and offerings
Broadly speaking, crypto ETPs fall into two product categories and types: ETF or ETP and physical, also referred to as asset-backed, or synthetic.
Crypto ETF structures
ETFs are structured as funds, with ETF holdings being shares in a fund. There is typically a legal separation of the funds from their issuing entities through the use of trusts, investment companies, or limited partnerships to ensure that investors’ holdings are protected in the event of the parent company/issuer’s bankruptcy. ETFs are typically subject to additional rules and transparency requirements depending on their jurisdiction; for example, ETFs domiciled in the EU and marketed to EU investors are generally required to comply with UCITS (Undertakings for Collective Investment in Transferable Securities) regulations, which brings diversification requirements, such as that no single asset can represent more than 10% of the fund.
Most crypto ETFs today are either spot or futures products. Spot ETFs have direct ownership of the underlying crypto assets, secured with independent custodians. With the futures ETFs, the issuers are not holding the underlying crypto but instead purchasing futures contracts for the assets. As such, these products don’t directly track the spot price of the underlying assets and are generally considered to bring greater complexity and cost, and to be less transparent and intuitive for investors.
Crypto ETP structures
Crypto ETPs (in this instance, using the term to refer to products other than ETFs) are structured as debt securities. While their structuring requirements are less stringent than those of ETFs, their disclosure requirements are very similar.
Physical crypto ETPs are secured debt obligations 100% backed by holdings of the underlying cryptocurrency they track. The crypto assets are physically bought and held with independent third-party custodians under the oversight and control of a designated trustee, who holds the rights and entitlements on behalf of the ETP holders and the responsibility for organizing redemptions in the event of an issuer insolvency.
Synthetic ETPs are unsecured debt obligations, meaning the issuer is not required to hold the underlying assets the product is tracking and instead uses derivatives and swaps to track the performance (exact structure and terms will vary). Synthetic ETPs, therefore, bear greater counterparty risk as there is no legal requirement for the products to be backed 1-to-1 by the underlying physical asset. XBT Provider (a Coinshares company) and Valour are two crypto ETP issuers offering synthetic products.
By and large, most crypto ETPs on the market are physical products, as many investors prefer the transparency and reduced counterparty risk provided by this structure.
Crypto Product Offerings
Crypto ETPs initially began as single digital asset trackers, and today, the range of crypto ETPs available on the market also includes basket, staking, inverse, and leveraged products, as well as certain indices designed to manage volatility.
In terms of underlyings, using data recently compiled by BitMEX Research, removing equity and OTC-traded funds and adding in additional data, we find that out of 162 crypto ETPs, bitcoin, ethereum, and basket products account for 58%, with the other 42% consisting of the long tail single digital assets, as well as short, volatility and leverage products.
Of these 162 products, 121 are ETPs and 41 are ETFs, of which 16 are futures ETFs and 11 are the US spot bitcoin ETFs awaiting launch. Staking products, meaning investors benefit from the staking yield generated by their holdings, currently total 14: thirteen ETPs and one ETF.
Largest products by AUM
The largest crypto ETP by AUM is the ProShares Bitcoin Strategy ETF, a US-based futures product holding assets of US$1.68 billion, based on available data as of 2 Jan 2024. As shown in the table below, nine of the 14 top crypto ETPs by assets track bitcoin (64%); of the remaining five, they include three ethereum, one solana and one Binance coin tracker.
Of these 14 products, four are domiciled in Switzerland (all from issuer 21Shares), three are domiciled in Canada, two in Jersey, one in Germany, one in the US, and one in Liechtenstein.
Four of the top 14 products by assets are ETFs: three spot and one futures. Of the ETPs, eight are physical and two are synthetic products.
Product innovation
There are several constraints to consider when bringing new crypto ETPs to market. These include regulatory and stock exchange requirements and approvals, liquidity requirements, investor demand, and the availability of public price data and fiat trading pairs. That said, we’re seeing continued product innovation from both issuers and index providers as more players enter the market and look to capture market share and differentiate themselves and as regulatory, service provider, and investor understanding and acceptance of this asset class increases.
Crypto ETP Operating Model
Creating an ETP begins with the issuer, meaning the investment company or trust that will issue the products, writing a prospectus document to be approved by the regulator. These can vary by jurisdiction, but in general, they include the details of the issuer, including the identities of its directors and financial statements, the product and program design, including an overview of the underlying assets, intended markets, and service providers, comprehensive overview of the potential risks, details of the asset valuation (NAV) and NAV calculation methodologies, fees, and redemption processes.
Following approval by a regulatory authority and successful engagement of the necessary service providers, the issuer must apply for listings on the desired stock exchanges. The rules regarding which types of products, i.e. asset-backed or futures, and underlyings, i.e. cryptoassets, are eligible to be listed vary by exchange.
The operating model and range of service providers can vary by product type, jurisdiction, and the program design of the issuer. A high-level overview of a typical model is as follows:
- On the primary market, the Issuer exchanges shares of the product with the APs in return for either the underlying crypto assets (“in-kind”) or the cash equivalent, with underlying crypto assets delivered to and from the designated custodians as required. Depending on the structure, a transfer agent and trustee may be involved in liquidating the collateral and transferring funds.
- As the APs manage primary market creation and redemption, market makers provide liquidity in the secondary market, ensuring continuous, efficient trading.
- Investors buy and sell the products on the secondary market, typically placing their orders via their bank or broker, who in turn execute their orders on the relevant stock exchange, either directly or via other intermediaries.
Operational stakeholders and service providers
Issuers
Issuers are responsible for the overall design and creation of the ETPs, coordinating and managing the relevant intermediaries across the product lifecycle. Regulatory oversight of issuers varies by jurisdiction and may not necessarily be a requirement. However, the regulator evaluates the issuer as part of the prospectus approval process, as does the exchange during the listing process, where requirements may include corporate governance, capital requirements, and regular audits. The issuer usually establishes a stand-alone special purpose vehicle (SPV) to issue the products. Initially, the majority of crypto ETP issuers were crypto native firms such as Coinshares, 21Shares, 3iQ, Hashdex, and Valour, joined in recent years by an increasing number of traditional finance firms, including WisdomTree, VanEck, Invesco, Fidelity, and, pending SEC approval, BlackRock and Franklin Templeton.
Custodians
Custodians hold the underlying cryptocurrency for physically-backed products. Custodians used by ETP issuers include Coinbase, Fidelity Digital Assets, Komainu, BitGo, Copper, Swissquote, Tetra Trust, Zodia Custody, and Gemini.
Market Makers
Market Makers (MMs) are the liquidity providers engaged by the issuers to provide the necessary liquidity for the ETPs by providing two-sided quotes on the exchanges at the agreed terms set out contractually. These include Flow Traders and GHCO.
Authorized Participants
Authorized Participants (APs), typically banks or broker-dealers, have the right to create and redeem shares of the products on a daily basis directly with the issuer. They do this by delivering the underlying assets or their cash equivalent to the issuer in exchange for newly created ETP shares or by returning shares to the issuer in exchange for the underlying assets or cash. The appetite of APs to engage in crypto, in particular to cover assets outside of BTC and ETH, may vary based on factors such as regulatory uncertainty and market conditions. APs who have been active in crypto ETPs include Flow Traders, GHCO, Virtu Financial, DRW, Bluefin, and Enigma Securities. JP Morgan, Jane Street, and Cantor Fitzgerald & Co have recently been named as APs in the US spot bitcoin ETF filings.
Index Providers
Index providers are responsible for creating, designing, calculating, and maintaining indices and benchmarks that ETPs track. These provide both issuers and investors with transparency and reliability. In certain jurisdictions, index providers are subject to regulatory oversight, for instance, in the EU with the European Benchmark Regulation (BMR). Index providers active in crypto ETPs include MarketVector Indexes, CF Benchmarks (acquired by Kraken in 2019), Vinter (a crypto-native index provider out of Sweden), Bloomberg, and Compass.
Exchanges and Multilateral Trading Facilities (MTFs)
The willingness of exchanges and MTFs to list crypto ETPs will first be mandated by their local regulations and regulatory approval of the issuer’s prospectus, after which it becomes a business decision determined by their respective issuer and product eligibility requirements, which typically includes evaluation of the underlying asset across parameters such as liquidity, compliance, publicly available pricing information, and risk mitigation. The rules regarding which types of products are eligible for listing will vary by trading venue; for example, Xetra in Germany only lists asset-backed ETPs, and SIX Swiss Exchange has specific rules regarding eligible crypto underlyings.
Trustees
A trustee may be responsible for safeguarding the assets and representing the interests of the ETP holders or investors. Their exact role and responsibilities can vary depending on the specific structure and legal arrangements of the ETP. Trustees active in crypto ETPs include Law Debenture Trust Corporation, Apex Corporate Trust Services, Bankhaus von der Heydt, and Griffin Trust.
Administrators
Administrators support the overall operational management of the ETPs. Their services may include accounting, regulatory compliance, financial reporting, and shareholder services. Administrators active in crypto ETPs include State Street, JTC Fund Solutions, The Bank of New York Mellon, Formidium, NAV Consulting, Theorem Fund Services and CIBC Mellon Global Securities Services.
Additional service providers
Other service providers that may play a role within the ETP program and product lifecycle include, but are not limited to, Paying Agents, responsible for registering new units of the ETPs and obtaining ISINs from local agencies, Transfer Agents, which may be used to maintain records of shareholders and other duties, Calculation Agents, for the calculation of the NAV of the underlying assets, and Registrars, for shareholder recordkeeping. These various roles and responsibilities may overlap and/or be covered by different parties depending on the product type, issuer, and jurisdiction.
A note on fees
ETPs charge management fees, also referred to as expense ratios or sponsor fees, to cover the costs of managing and operating the products, which are calculated annually as a percentage of holdings and deducted from the NAV daily or periodically. Many of the early crypto ETPs were able to charge high fees of up to 2.5%, whereas typically, ETPs fall within the range of 0.05% to 0.75% for fees. The AUM of crypto ETPs charging 2.5% when alternatives charge as low as 0% speaks to the stickiness and first-mover advantage of these products.
We expect fees to be a key differentiator going forward with new products, as is seen now with the US spot ETF. The first fees announced were Invesco/Galaxy, who are waiving fees for the first six months and the first $5b in assets, and Fidelity, offering a fee of 0.39%, and as of 8th Jan, the announcements from the other issuers confirmed that the fee wars are indeed on:
Regional offerings
Europe
Crypto ETPs originated in Europe, with the first bitcoin product launched in Sweden in 2015, a synthetic tracker ETP issued by XBT Provider (acquired by Coinshares in 2017). In Europe, crypto ETP issuers benefit from the single market, as once an ETP prospectus is approved by one European country regulator, upon notification and approval, the products may also be made available in other member states (referred to as “passporting” the prospectus). Sweden’s SFSA remains a popular choice for European crypto ETP prospectus approvals. Germany is another jurisdiction that has approved crypto ETP prospectuses and where crypto ETPs have good availability across trading venues, for example from leading exchange groups such as Deutsche Boerse and Boerse Stuttgart Group.
ETPs remain the dominant product type in Europe and the reason for the lack of a true crypto ETF in Europe is largely due to the UCITS (Undertakings for Collective Investment in Transferable Securities) regulations. By and large, the majority of European ETFs are UCITS compliant in order to benefit from pan-European passporting, which allows their sale to retail investors in other EU member states in addition to the country of registration, and the assurances and investor protections these regulations provide. The UCITS rules and requirements, however, are currently incompatible with single asset tracker products such as a bitcoin ETF. For example, UCITS diversification requirements include that no single asset shall represent more than 10% of the fund and underlyings must be a qualifying financial instrument. In June 2023, the European Commission tasked the European Securities and Market Authority (ESMA) with investigating whether updates to the UCITS rules are required and noting crypto assets. However, the intention of this exercise seems to be to determine whether more rules and investor protections are required, rather than expanding the eligible product types. The deadline for ESMA’s input is 31 Oct 2024.
Switzerland
In 2016, Switzerland became the second jurisdiction after Sweden to approve and list a crypto ETP, a bitcoin tracker certificate by Bank Vontobel launched on the SIX Swiss Exchange. The world’s first crypto index product was then launched in Switzerland in November 2018, a physically-backed basket ETP comprised of bitcoin (BTC), ethereum (ETH), ripple (XRP) and litecoin (LTC) from issuer 21Shares (then named Amun). The SIX Swiss Exchange has specific rules for crypto underlyings including “that at the time of applying for provisional admission to trading, the cryptocurrency must be among the 15 largest cryptocurrencies, as measured by market capitalization in USD” and from our research has the widest range of products with crypto underlyings of any trading venue globally. Swiss stock exchange BX Swiss also permits products with crypto underlyings, with rules including that the underlying must be within the top 50 cryptocurrencies by market cap.
UK
In October 2020, the UK’s Financial Conduct Authority (FCA) banned the selling, marketing, and distributing to retail investors of any derivatives or ETNs that reference “unregulated transferable cryptoassets.” A number of crypto ETPs are listed in the UK on Aquis Exchange, available to professional investors only.
Canada
Canada was the first country to approve a bitcoin ETF, with the first product launched by Purpose Investments on the Toronto Stock Exchange (TSX) in February 2021, followed in April of that year by the ethereum ETFs. In October 2023, 3iQ launched staking in their ethereum ETF, with the staking rewards accrued into the fund, a first in North America. Other Canadian crypto ETF issuers include Fidelity Investments Canada, CI Global Asset Management (CI GAM) in partnership with Galaxy, and Evolve Funds.
Brazil
Canada’s approval of a bitcoin ETF was quickly followed by Brazil when the Brazil Securities and Exchange Commission (CVM) approved the first bitcoin exchange-traded fund (ETF) in the Latin American region in March 2021. Brazilian crypto ETF issuers include crypto asset managers Hashdex and QR Capital, and Itaú Asset Management in partnership with Galaxy.
USA
To date, only crypto futures ETFs have been approved by the SEC and made available to investors. The first bitcoin futures ETF, by ProShares, launched on 19 October 2021 as one of the most heavily traded fund launches in market history, attracting more than $1bn in assets within the first days of trading.
Two years later, on 2 October 2023, the first US ethereum futures ETFs were launched by ProShares, VanEck, and Bitwise. Futures products generally require greater investor understanding and carry additional expense and risk of tracking error and performance erosion due to frequent rebalancing. The fact that the underlying futures contracts are traded on the Chicago Mercantile Exchange (CME) under the regulation of the Commodity Futures Trading Commission (CFTC) is a popular theory as to the reason the futures ETFs were approved in advance of spot products.
The first filing for a US spot bitcoin ETF was made in July 2013 by the Winklevoss twins and, over subsequent years, has been repeatedly rejected. One decade later, on June 15, 2023, BlackRock, the world’s largest asset manager, made its filing for the iShares Bitcoin Trust. The weight of their brand, together with their stellar track record (according to Bloomberg Senior ETF Analyst Eric Balchunas, BlackRock has only been rejected once out of 575 ETF applications) changed the game and has helped make the US bitcoin spot ETF one of the most anticipated launches ever.
The tides shifted further on August 29th, 2023, when the US Court of Appeals for the District of Columbia Circuit, in case Grayscale v. SEC, 22–1142, ruled in Grayscale’s favor, stating that the SEC’s decision to block its proposed bitcoin ETF was “arbitrary and capricious.”
Fast forward to today, 11 issuers now have applications for a spot bitcoin ETF under review by the SEC (links to S-1 forms, which are the prospectus documents as well as additional information & exhibits gathered by the SEC, as filed on 26, 28 & 29 December 2023): BlackRock (iShares), Grayscale (conversion of the existing OTC trust), 21Shares & ARK Invest, Bitwise, VanEck, WisdomTree, Invesco Galaxy, Fidelity, Valkyrie, Hashdex, and Franklin Templeton. In recent weeks, meetings between the SEC and issuers have increased, and the SEC has required all issuers to move to cash creations, meaning that the asset exchange for the creation and redemption of ETF shares must be done in cash, as opposed to in-kind, meaning exchanging for the underlying bitcoin. Typically, the exchange of assets between the AP and the ETF issuer in creations and redemptions is done in-kind for efficiency reasons. While the SEC has not publicly stated their reasoning for requiring cash only, it is most likely that the SEC does not want to be seen to be approving APs (typically large banks and brokers) to be transacting in crypto.
As of the evening of Friday 5th January, 2024, all 11 filers had submitted their amended 19b-4s, which propose rule changes for the exchanges to enable trading of the products. These must be approved by the SEC Division of Trading and Markets.
Excerpt of US Spot Bitcoin ETF status as per Bloomberg, 5 Jan 2024
The final step would be the SEC sign-off of the final S-1 forms. Current market expectations are for this to happen circa Wednesday 10th January, and listings and trading could follow as quickly as 24–48 hours thereafter.
We will be closely following the flows of funds and volumes within the first week of trading in order to assess the competitive dynamics that will be at play across the 11 issuers. Larger ETFs are preferred by investors for a number of reasons, including cost efficiencies, liquidity, and reduced closer risk. The amount of seed capital in an ETF can therefore provide a competitive advantage. Bitwise’s S-1 filing of Dec 29th indicates initial interest of up to $200m and Blackrock’s reveals seed sales of $10m. Of note, on Jan. 5th it was rumored they may have $2bn lined up for the first week of trading, which Bloomberg Senior ETF Analyst Eric Balchunas noted as “on brand” for the asset manager given seeding of other funds, although that amount would far exceed any previous ETF launches.
Filings for US ethereum spot ETFs have also been made by BlackRock, VanEck, Ark & 21Shares, Fidelity, Hashdex, Invesco & Galaxy, and Grayscale, for which the first final SEC deadline is May 23rd, 2024.
Hong Kong
One year following the US SEC, Hong Kong’s Securities and Futures Commission (SFC) approved crypto futures ETFs in October 2022, with the first two funds, one bitcoin and one ethereum from asset manager CSOP launching on December 16, 2022. In December 2023, the SFC and Hong Kong Monetary Authority issued a joint circular setting out guidelines for crypto investment products, noting that “in light of the latest market developments” the SFC will now accept applications for crypto spot ETFs. The updated SFC guidelines note that both in-kind and cash creation and redemption models will be permitted. Crypto ETPs issued overseas and not specifically approved by the SFC would remain available to professional investors only.
What’s next for Crypto ETPs
A growing number of investors want crypto in their portfolios, and ETPs provide a familiar, convenient, and regulated avenue to access that exposure. Driven by this demand, both crypto-native and traditional asset managers continue to engage and innovate with these products. In 2024, the expected US spot ETF approvals will likely serve as a catalyst for their growth and availability worldwide.
As this space continues to evolve, areas we’ll be watching include:
- The effects of increasing issuer competition (and the strength of that competition) on fees, as well as on flows from ETPs in other geographies and issuers, and, in the longer term, potential consolidation and/or exit of smaller players
- Shifts in both consumer and institutional awareness and acceptance of crypto, supported by the marketing power of leading global asset managers such as BlackRock
- Rise in the number of exchanges, asset managers, distributors, and other institutional players and service providers willing to work with crypto as a result
- The timeline for acceptance and integration of these products into advisory models
- Developments in institutional staking, including the growth in staking products available for investors, as well as the development of liquidity solutions for issuers, such as Validator NFTs recently launched by institutional staking provider Kiln*
- The growth of onchain structured products: it’s no secret that we believe the future is onchain and the recent partnership between 21Shares parent company 21.co and Index Coop* shows how ETP issuers are starting to move in this direction
If you’re working in the crypto ETP or asset management space, please feel free to reach out to @dianacbiggs — I’d love to learn more.
Note: Over-the-counter (OTC) closed-ended crypto funds, such as those offered by Grayscale, have not been included as part of this research
* denotes 1kx portfolio company
Disclaimer: This article is for general information purposes only and should not be construed as or relied upon in any manner as investment, financial, legal, regulatory, tax, accounting, or similar advice. Under no circumstances should any material at the site be used or be construed as an offer soliciting the purchase or sale of any security, future or other financial product or instrument. Views expressed in posts are those of the individual 1kx personnel quoted therein and are not the views of 1kx and are subject to change. The posts are not directed to any investors or potential investors, and do not constitute an offer to sell or a solicitation of an offer to buy any securities, and may not be used or relied upon in evaluating the merits of any investment. All information contained herein should be independently verified and confirmed. 1kx does not accept any liability for any loss or damage whatsoever caused in reliance upon such information. Certain information has been obtained from third-party sources. While taken from sources believed to be reliable, 1kx has not independently verified such information and makes no representations about the enduring accuracy or completeness of any information provided or its appropriateness for a given situation.
Many thanks to Frances Edwards, Jonathan Bier, Dev, Wei Dei, and Robert Koschig for your input and review of drafts.
